['Heat and Cold Exposure']
['Heat Stress']
11/10/2023
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Employers must train all employees, both supervisory and non-supervisory, on the policies and procedures established to comply with this regulation. Training must be provided before the beginning of work involving a risk of heat illness. This means that at a minimum training should be provided when an employee is hired, with refresher training as needed. Training that is given close in time to the hot season is more effective than training given during colder seasons without follow-up refresher training. As a best practice, some employers use a daily "tailgate meeting" approach, starting out each work day with a brief safety reminder about issues considered particularly relevant to the work to be performed that day.
The basic test of training is its effectiveness. Cal/OSHA evaluates compliance by examining both content and how it is presented. To be effective, training must be understood by employees and given in a language the employees understand. The test of compliance is whether training has occurred, whether the required content has been provided, and whether the training has been effective in communicating the essentials to employees.
To evaluate compliance, Cal/OSHA personnel ask supervisory and non-supervisory employees about required training elements. The questions are designed to determine whether employees received training through methods generally recognized as effective and whether they understood its content. Inspectors will not expect all answers to be correct but will look for indicators that the employer has made a good-faith effort to communicate all the essential information. Employers must ensure that their work procedures are consistent with the information provided in the training.
Cal/OSHA requires employers to maintain records of the training required in this subsection, as specified in 8 CCR 3203 (on Injury and Illness Prevention Programs).
There are additional topics that supervisors must be trained on, and the importance of supervisory training cannot be overstated. The 2006 Cal/OSHA Heat Illness Case Study showed that 63% of the supervisors of employees who died from heat stroke had not been trained in the prevention of heat illnesses. In addition to the elements required for employee training, the supervisor’s training must include:
- Complete mastery of the training content provided to the employees;
- The procedures the supervisor must follow to implement the company’s Heat Illness Prevention Plan;
- The procedures to follow when an employee exhibits or reports symptoms consistent with possible heat illness, including which steps to follow to provide first aid and immediate medical treatment; and
- How to monitor weather reports and how to respond to hot weather advisories.
All employees and supervisors must be trained on every detail of the employer's emergency response procedures.
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