State Heat Standards and Regulations
A comprehensive and protective OSHA heat standard that will serve both indoor and outdoor workers affected by heat would be a big help. Currently, a proposed rule for a federal heat standard is in limbo, but states can create their own heat standard.
Until we get a strong federal rule states can use the existing California, Oregon, and Washington outdoor heat standards and Minnesota's indoor heat standards along with the American Conference of Governmental Industrial Hygienists (ACGIH) or NIOSH’s heat stress and strain recommendations to build their own comprehensive standard that empowers workers authorizes workers to protect themselves and their co-workers.
Of the existing state rules, there are areas of improvement in each rule that should be addressed. California’s heat rule does not account for workers who are employed in incarcerated facilities. Colorado's heat rule only pertains to agricultural workers, excluding an immense number of outdoor workers unprotected.
Some Best Practices in a Heat Illness Prevention Plan
Access to shade or cool-down areas
Access to shade or cool-down areas helps workers regulate their body temperature and avoid heat-related illnesses. It’s important for shade and cool down areas to be within proximity to the worksite. Shaded areas should be large enough to accommodate the total number of on-site workers. Shade can be artificial: tents, pavilions, etc. Or shade can come from natural resources such as trees. But shade should not be from equipment structures that provide blockage from the natural sunlight. If the shade or cool-down areas are indoors (trailer, vehicle, structure) there should be functioning air conditioning inside as well. California’s outdoor heat standard enforces that in outdoor workplaces, shade must be present when temperatures are greater than 80°F, and when temperatures are less than 80°F, shade must be available upon request. California’s standard also suggests shade and cool-down areas must be blocked from direct sunlight, large enough to accommodate the number of workers on rest breaks so they can sit comfortably without touching each other, and close as possible to the work area.
Rest Breaks
Rest breaks are important because they help improve worker well-being, productivity, and reduce the chances of workplace injuries. Oregon has a good model for regulating rest breaks during high temperature days. Oregon mandates the provisions of a cool-down rest break in the shade of 10 minutes for every two hours of work when the heat index is 90-94; or 20 minutes every hour (for heat index 95-99); or 30 minutes every hour (for heat index 100-104); or 40 minutes every hour (for heat index 105 or greater).
Acclimatization
Acclimatization can improve workers' physical work capabilities, comfort, and protect vital organs from heat injury. It can also reduce physiological strain on the heart and cardiovascular system. Acclimatization occurs when the body makes several physiological adaptations, including sweating, circulation, heart rate, and body temperature. The CDC recommends new workers should start by spending only about an hour and a half in the heat on their first day, and slowly increase their exposure time by no more than 20% per day.
Insight from NACOSH Working Group on Heat
While the OSHA proposal for a heat standard is comprehensive, the National Advisory Committee on Occupational Safety and Health (NACOSH) working group on heat suggests some better alternatives in the name of protecting workers. Listed below are some key points of contrast where NACOSH makes better worker protection recommendations:
Heat Injury and Prevention Plans
- OSHA proposal: If any workers are at risk of heat stress, the employer must develop and implement a site-specific prevention plan. If the employer has more than ten employees, the plan must be written.
- NACOSH recommendation: The exposure control plan/HIPP applies to all employees of any employment duration or employer entity size.
Training
- OSHA proposal: Refrains from training those workers who are not susceptible to heat stress, though they might work with people who will experience heat stress.
- NACOSH recommendation: All employees should be trained to look out for signs of heat stress and illness.
Environmental Monitoring (includes humidity, accounts for the temperature inside of work trucks, trailers, etc)
- OSHA proposal: No recommendations.
- NACOSH recommendation: Workers are trained to participate in environmental monitoring, and actively participate in environmental monitoring. They have the authority to stop work if conditions are deemed too dangerous.