Compliance Just Got Easier: Stay ahead of regulatory changes with instant notifications on updates that matter.

FREE TRIAL UPGRADE!
Thank you for investing in EnvironmentalHazmatHuman ResourcesHuman Resources, Hazmat & Environmental related content. Click 'UPGRADE' to continue.
CANCEL
YOU'RE ALL SET!
Enjoy your limited-time access to the Compliance Network!
A confirmation welcome email has been sent to your email address from ComplianceNetwork@t.jjkellercompliancenetwork.com. Please check your spam/junk folder if you can't find it in your inbox.
YOU'RE ALL SET!
Thank you for your interest in EnvironmentalHazmatHuman ResourcesHuman Resources, Hazmat & Environmental related content.
WHOOPS!
You've reached your limit of free access, if you'd like more info, please contact us at 800-327-6868.

Do you have a heat injury and illness prevention program?

With OSHA’s proposed heat illness prevention rule ready for review, now is a great time to evaluate how you are protecting your workers from the heat! Workers must be protected, and the proposed rule is intended to guide employers conducting outdoor and indoor work in all general industry, construction, maritime, and agriculture sectors in doing just that. As temperatures soar, we are reminded that extreme heat exposure can result in occupational illness and injuries like heat stroke, heat exhaustion, dizziness, fatigue, and accidents resulting from decreased reaction time.

While the agency’s rulemaking process indicates that it can take between 2-5 years to analyze records and develop a final rule, OSHA’s recent focus on a heat standard suggests the process may very well be fast-tracked. As a matter of fact, the proposal even says that, once the final rule is published (anticipated in the next couple of months), it will take effect within 60 days of its publication in the Federal Register. Additionally, employer compliance with the final rule would be required 150 days after publication to the Federal Register.

Anticipating a shorter-than-normal turnaround from the proposed rule to publishing in the Federal Register, we wanted to spotlight OSHA’s forecasted expectations for employers. So, over a four-week period, we polled our Compliance Network subscribers to see who has a heat injury and illness prevention program and get others thinking about it. Here’s what we discovered:

  • 35.4 percent have a written program;
  • 47.9 percent have procedures in place during hot weather, but don’t have a formal program;
  • 10.4 percent don’t have anything yet, but were seeking more information or waiting for OSHA’s final ruling; and
  • 6.3 percent were seeking more information on requirements.

Historically, OSHA has relied on the General Duty Clause when issuing citations for heat-related hazards, but with the passing of this proposed rule, specific regulations may be here sooner than you think. Now is the time for employers to begin reviewing or developing an effective heat-related illness prevention program as part of a broader safety and health program and ensure compliance with the new requirements.

What to expect with the new rule

Key elements in OSHA’s proposed rule will require employers to:

  • Develop a site-specific Heat Illness and Illness Prevention Plan (HIIPP) that addresses risk assessments, monitoring, exposure controls, emergency response to heat stress, training, and documentation.
  • Evaluate the HIIPP annually;
  • Identify and respond to heat hazards for outdoor and indoor environments affected by excessive heat (e.g., at 80 degrees, employers must provide water and rest breaks and at 90 degrees, employers must monitor signs of heat illness and provide mandatory 15-minute breaks every two hours);
  • Establish heat metric(s) and monitoring systems for protecting employees from excessive heat;
  • Designate a heat safety coordinator;
  • Institute “water – rest – shade” procedures to ensure workers can cool down when necessary.
  • Develop heat illness and heat-related emergency response plans;
  • Implement engineering controls such as ventilation and air conditioning and administrative controls including acclimatization and water – rest – shade;
  • Provide initial and refresher training for supervisors, heat safety coordinators, and employees to ensure understanding of heat hazards, personal risk factors, recognition of early symptoms of heat stress, and activation of emergency services when necessary; and
  • Maintain written or electronic records of monitoring results for six months.

More about the HIIPP

The proposed standard would require:

  • Employers with more than 10 employees to have their plan in writing;
  • The HIIPP to readily available and in a language understood by employees; and
  • An annual review of the HIIPP to evaluate the effectiveness and update accordingly.

Developing a comprehensive workplace heat illness prevention program is crucial to ensure employee safety and well-being. Establishing a written plan as part of a comprehensive program clarifies expectations for employees and helps employers effectively mitigate heat risks. By prioritizing employee health and safety, organizations can create a cooler, more productive work environment.

Keys to remember: OSHA’s heat illness prevention proposed rule is headed to the Federal Register, and it applies to all employers who oversee outdoor and indoor work within the agency’s jurisdiction. When temperatures reach trigger points, employers would be expected to implement heat illness prevention measures, like a hazard assessments, written plans, and training.

Interested in learning more about OSHA’s proposed heat rule?

See our Compliance Network article “Proposed heat illness prevention rule leaves OMB” at Proposed heat illness prevention rule leaves OMB | J. J. Keller® Compliance Network (jjkellercompliancenetwork.com)

Or are you in need of more heat illness prevention resources?

Check out our Industry News article at OSHA adds new heat illness prevention resources | J. J. Keller® Compliance Network (jjkellercompliancenetwork.com).