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Maintaining a safe work environment may be more challenging than employers think, especially if workers are being exposed to hot temperatures. Heat stress is caused by a number of interacting factors, including environmental conditions, clothing, workload, and the individual characteristics of the worker. Whether it’s the result of seasonal fluctuations or the type of work performed, extreme temperatures can affect the body’s natural ability to handle heat, which can lead to heat illness. Since everyone reacts differently to heat, it is difficult to predict who will be affected. Although encouraging employees to drink fluids and take frequent rest breaks are important, you cannot overlook other methods to protect employees from heat exposure.
Scope
The heat illness prevention regulation, Title 8 CCR 3395, applies to all outdoor places of employment. This includes employees in industries such as agriculture; construction; landscaping; oil and gas extraction; and transportation or delivery of agricultural products, construction materials, or other heavy materials (i.e. furniture, lumber, freight, cargo, cabinets, industrial or commercial materials). There is an exception for employment that consists of operation an air-conditioned vehicle and does not include loading or unloading.
Although Title 8 CCR 3395 is not applicable to indoor work environments, Cal/OSHA says that employers with employees near sources of heat or inside buildings with limited cooling capabilities must ensure that their Injury and Illness Prevention Program (IIPP) is effective and in writing. This means that the IIPP must ensure that work areas with risk of heat illness have been identified and evaluated, and appropriate corrective measures and training have been implemented to protect workers. The IIPP regulation at Title 8 CCR 3203 directs employers to address all health or safety hazards within their worksite — including heat illness. Other regulations that apply include, but are not limited to: Title 8 CCR 3363 Water Supply, and Title 8 CCR 3400 Medical Services and First Aid.
Another law to be aware of when it comes to heat illness prevention is 226.7 of the Labor Code. This law has been updated with requirements that make it against the law to require an employee to work during a meal or rest or recovery period — including the cooldown period that must be afforded to an employee to prevent heat illness.
Regulatory citations
- Title 8, CCR 3395 — Heat Illness Prevention
- Title 8, CCR 3203 — Injury and Illness Prevention Program
- Title 8, CCR 3363 — Water Supply
- 226.7 California Labor Code — Meals and rest periods
Key definitions
- Acclimatization: Temporary adaptation of the body to work in the heat that occurs gradually when a person is exposed to it. Acclimatization peaks in most people within four to fourteen days of regular work for at least two hours per day in the heat.
- Environmental risk factors for heat illness: Working conditions that create the possibility that heat illness could occur, including air temperature, relative humidity, radiant heat from the sun and other sources, conductive heat sources such as the ground, air movement, workload severity and duration, protective clothing and personal protective equipment worn by employees.
- Heat cramps: Painful, involuntary muscle spasms that usually occur during heavy exercise in hot environments. Fluid and electrolyte loss often contribute to heat cramps.
- Heat exhaustion: A condition whose symptoms may include heavy sweating and a rapid pulse, a result of the body overheating. Causes of heat exhaustion include exposure to high temperatures, particularly when combined with high humidity, and strenuous physical activity. Without prompt treatment, heat exhaustion can lead to heatstroke, a life-threatening condition.
- Heat illness: A serious medical condition resulting from the body's inability to cope with a particular heat load, and includes heat cramps, heat exhaustion, heat syncope and heat stroke.
- Heat stroke: When the body becomes unable to control its temperature: the body’s temperature rises rapidly, the sweating mechanism fails, and the body is unable to cool down. Body temperature may rise to 106°F or higher within 10 to 15 minutes. Heat stroke can cause death or permanent disability if emergency treatment is not provided.
- Heat syncope (fainting): A mild form of heat illness that often results from physical exertion when it is hot. It occurs when the body, in an effort to cool itself, causes the blood vessels to dilate to such an extent that blood flow to the brain is reduced and fainting occurs.
- High heat: Temperatures that equal or exceed 95°F.
- Personal risk factors for heat illness: Factors such as an individual's age, degree of acclimatization, health, water consumption, alcohol consumption, caffeine consumption, and use of prescription medications that affect the body's water retention or other physiological responses to heat.
- Potable water: Fit to drink.
- Shade: Blockage of direct sunlight. One indicator that blockage is sufficient is when objects do not cast a shadow in the area of blocked sunlight. Shade is not adequate when heat in the area of shade defeats the purpose of shade, which is to allow the body to cool. For example, a car sitting in the sun does not provide acceptable shade to a person inside it, unless the car is running with air conditioning. Shade may be provided by any natural or artificial means that does not expose employees to unsafe or unhealthy conditions and that does not deter or discourage access or use.
- Temperature: The dry bulb temperature in degrees Fahrenheit obtainable by using a thermometer to measure the outdoor temperature in an area where there is no shade. While the temperature measurement must be taken in an area with full sunlight, the bulb or sensor of the thermometer should be shielded while taking the measurement, e.g., with the hand or some other object, from direct contact by sunlight.
Summary of requirements
In general, the standard requires covered employers to provide for:
- Availability of the written heat illness prevention plan. Employers must establish, implement, and maintain, a written heat illness prevention plan. The plan must be in English and the language understood by the majority of the employees. It must be made available at the worksite to employees and to Cal/OSHA representatives upon request.
- Access to water. Water is a key preventive measure against heat illness. Employees must be encouraged to frequently drink water, especially during a heat wave.
- Access to shade. Shade is an important way to allow employees to cool down.
- High-heat procedures. The employer shall implement high-heat procedures when the temperature equals or exceeds 95°F.
- Emergency Response Procedures. The Employer shall implement effective emergency response procedures. These procedures must be part of the written plan and include steps to be followed to ensure a rapid response.
- Acclimatization. This method allows for a gradual adjustment of the body to work in the heat.
- Training. All employees and supervisors need to know the importance of frequent drinking of water and resting in cooled areas, the signs and symptoms of heat illness, and how to respond in an emergency.