Heat Illness & What OSHA’s National Emphasis Program Means for Employers

Introduction

The dangers associated with heat related illness are well understood. However, deaths and serious illnesses continue to occur , and may increase in time, because of increased frequency of extreme temperatures.

To emphasize its concern and take necessary action, the Occupational Safety and Health Administration (OSHA) is implementing an enforcement initiative on heat-related hazards, developing a National Emphasis Program on heat inspections, and launching a rulemaking process to develop a workplace heat standard. In addition, the agency is forming a National Advisory Committee on Occupational Safety and Health Heat Injury and Illness Prevention Work Group to provide better understanding of challenges and to identify and share best practices to protect workers.

What Does This Mean for Employers?

OSHA Area Directors across the nation will institute the following:

• Prioritize inspections of heat-related complaints, referrals, and employer-reported illnesses and initiate an onsite investigation where possible.
• Instruct compliance safety and health officers, during their travels to job sites, to conduct an intervention (providing the agency's heat poster/wallet card, which discusses the importance of easy access to cool water, cooling areas, and acclimatization) or open an inspection when they observe employees performing strenuous work in hot conditions.
• Expand the scope of other inspections to address heat-related hazards where worksite conditions or other evidence indicates these hazards may be present.

This means OSHA will increase enforcement activities under the General Duty Clause until a Federal Heat Standard is promulgated, especially focusing on high-risk industries like construction and other strenuous activities indoors and outdoors.

Employers should evaluate their current programs on heat illness prevention and increase focus on training and recognition of the potential dangers. The program should make it clear as to when supervisors must implement enhanced “high heat” procedures that include:

• Observing individual employees for alertness.
• A mandatory “buddy system” within teams of workers.
• Effective communication with lone workers.
• Cool down rest periods every two hours.
• Performing the most strenuous tasks during the cooler hours of the shift.

Key Components of an Effective Heat Illness Prevention Program

The following components are critical for effectively protecting employees from the harmful effects of exposure to high heat and should be incorporated into an employer’s heat illness prevention program:

1. Communication of risk factors.

2. Information detailing the signs, symptoms, prevention, and treatment of heat related illnesses.

3. Engineering and administrative control methods.

4. Inclusion of effective heat illness prevention procedures:

• Emergency response procedures.
• Acclimatization.
• High heat procedures.
• Weather monitoring procedures.

5. Training for all affected employees and supervisors which should include the following topics:

• Environmental and personal risk factors to heat illness.
• Acclimatization protocol (Heat Stress and Strain Guide ACGIH – 2017)
• The importance of regular hydration throughout the workday.
• The effects of personal protective clothing such as Tyvek Suits.
• Work/rest regimen.
• Shaded break areas such as canopies with tables, chairs, and fans.
• Skin and head coverings for direct sunlight exposure.
• Importance of employees reporting heat related symptoms.
• The effects of alcohol and other lifestyle factors.
• Self-monitoring techniques such as monitoring pulse rate (Heat Stress and Strain Guide ACGIH – 2017).
• Emergency Response—taking immediate action when a worker appears to be disoriented or confused.

Resources

Consider the OSHA-NIOSH Heat Index App as a tool for helping supervisors to recognize when additional preventative precautions should be implemented. This can be downloaded for Apple and Android users. The National Weather Service Heat Index Chart (Figure 1) can also be useful as a visual aid.

Conclusion

It is important for employers to understand that heat related illnesses are currently vastly underreported, and, often, those individuals whose heat illnesses are reported were not aware of the signs and symptoms of heat stress.

Take advantage of this National Emphasis Program and use the appropriate resources to revisit and update or improve your company or organization’s existing Heat Illness Prevention Plan where applicable. If you have any questions or concerns, please contact [email protected].

Acknowledgments

We would like to thank Tom Sumner and Warren J. Guillot Jr. for providing insight and expertise that greatly assisted in this research.

Tom Sumner is Director of Health and Safety for J.S. Held Global Operations. He has over 30 years of technical/safety experience in a wide range of Environmental, Health & Safety projects. Tom is experienced in the design and implementation of health and safety programs, accident investigations and safety audits for general and marine industries, as well as extensive experience in industrial hygiene, air quality/mold, health & safety training, and litigation support in environmental health and safety cases.

Tom can be reached at [email protected] or +1 504 420 1898.

Warren J. Guillot, Jr., is a Certified Safety Professional (CSP) with experiences in many areas of the occupational health, safety, and environmental industry. His experiences include conducting both on-site regulatory compliance and behavior-based safety audits; reviewing, updating, and overall development of health and safety programs policies and procedures including topics such as, but not limited to isolation procedures for confined space entries, facility specific emergency response procedures, machine guarding, occupational noise, Hexavalent Chromium VI, contractor qualifications, bloodborne pathogens, Hazard Communications, and others.

Warren can be reached at [email protected] or +1 504 420 1922.