['Enforcement and Audits - OSHA', 'Heat and Cold Exposure']
['OSHA Violations and Penalties', 'Heat Stress']
04/12/2024
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Yes. In fact, effective April 8, 2022 to April 7, 2025, under an agency National Emphasis Program (NEP), OSHA compliance officers must proactively initiate inspections in any of the over 70 listed, high-risk industries (including the Warehousing and Storage Industry) in outdoor and indoor work settings when the National Weather Service issues a heat warning or advisory for a local area. Inspectors will review illness logs and other records, interview workers, determine if the employer has a heat illness program, document ambient conditions, and identify work activities relevant to heat-related hazards.
If there is sufficient evidence to issue a citation for heat-related hazards, a citation under Section 5(a)(1) (or General Duty Clause) of the Occupational Safety and Health Act will be issued. Suggested abatement measures will likely appear in the citation, and several steps to materially reduce or eliminate worker exposure to heat-related hazards are listed in the NEP.
Also under the NEP, no matter the industry, establishments that were previously inspected as a result of a heat-related fatality and were issued citations should expect a follow-up inspection. Any heat-related fatalities, complaints, or referrals will get high-priority inspections. In addition, OSHA will engage in outreach on days when the heat index is 80 degrees Fahrenheit.
Meanwhile, here’s an example of an actual heat-related enforcement case. An OSHA inspector found that a warehouse’s heat stress prevention program did not effectively ensure safe working conditions for all employees. The company was cited under the General Duty Clause (Section 5(a)(1) of the OSH Act) for exposing employees to recognized hazards of exposure to excessive heat. According to the citation, among other methods, one feasible and acceptable abatement method to correct this hazard is to create a heat stress program which includes, but is not limited to, the following:
- Establish provisions for a work/rest regimen so that exposure time to high temperatures is decreased, and/or the work rate is decreased, and/or rest periods are increased in length and frequency.
- Provide and utilize heat stress instruments to monitor the work environment temperature and humidity.
- Provide adequate amounts of cool (50-60 degrees Fahrenheit) water and/or other approved beverages with electrolyte replacement in the work area and require workers to drink frequently (one cup every 15 to 20 minutes).
- Initiate a heat acclimation program to increase heat tolerance of new workers and workers returning from an absence from work three or more days.
- Initiate a screening program to identify health conditions aggravated by temperatures.
- Allow employees to utilize a cool area where heat-affected employees may recover when signs and symptoms of heat-related stress is recognized and/or reported.
- Train online management to recognize heat stress related symptoms.
- Initiate an effective and continuing training program to inform employees of the hazards of heat-related stress, including the danger of alcohol, various drugs, etc. in heated environment, the signs/symptoms to look for, the importance of immediately reporting to management, etc.
- Provide adequate procedures to ensure employees receive immediate medical attention, by ensuring the availability of management.
- Document the procedures to be followed to ensure that all employees of authority have specific uniform steps to follow and ensure that the same information and instructions are provided to all exposed employees.
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['Enforcement and Audits - OSHA', 'Heat and Cold Exposure']
['OSHA Violations and Penalties', 'Heat Stress']
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Copyright 2024 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.