OSHA is Turning Up the Heat: Will Your Heat Illness Prevention Program be Cool and Compliant?

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By Amy Leung, CSP, ARM, CRIS
Risk Control Advisor

Having an effective Heat Illness Prevention Program has been a given for a number of years.  However, recently there have been some significant changes and requirements that became effective on May 1, 2015.  Is your program up to date with these changes?  Have you re-trained your employees with this new information?

Some of the key requirements of an effective Heat Illness Prevention Program have been amended including: addressing access to water, shade, high heat procedures, written procedures, acclimatization, weather monitoring, and employee and supervisory training.

  • Trigger Temperature for the Provision of Shade – Shade is now required when the temperature reaches 80 degrees (it was previously 85 degrees). Employers are expected to know if the temperature is expected to exceed the trigger temperature and need to plan accordingly.

 

  • Shade – The language was amended to include a provision that shade, whether artificial or natural, does not expose employees to unsafe or unhealthy conditions and “…that it does not deter nor discourage access or use.” Basically, shade must be easy for employees to reach. Workers should not encounter any obstacles or hazardous or unreasonably unpleasant conditions while moving toward the shade or resting in the shade. There now should be enough shade available for the number of employees who could take a preventative cool down rest, break or meal period at any one time.

 

  • Provision of Water – The language was amended to specify that water is to be provided free of charge as is to be fresh, pure, suitably cool and located as close as possible to where employees are working. The purpose of these specific conditions is to encourage workers to drink water often and to avoid significant interruption in an employee’s work in order to do so.

 

  • High Heat Procedures – High Heat Procedures need to be implemented when the temperature reaches 95 degrees. Part of the revised language includes wording that the employer must implement one or more of the following: they must have a supervisor/designee observe the employees, or institute a mandatory buddy system or have regular communication with the employee. Holding a pre-shift meeting is required where, among other topics, employees are encouraged to drink plenty of water throughout their shift and are reminded that they have the right to take a cool-down rest break when necessary.

 

  • Emergency Response Procedures – The amended language spells out that emergency medical services must be provided as quickly as possible if an employee suffers heat illness and what to do if employees cannot reach those services directly (for example, because cell phone coverage is unavailable). An emergency response procedure or plan must be developed, implemented and be part of the training for employees and supervisorial staff.

 

  • Acclimatization – Employees now need to be closely observed by a supervisor during a heat wave. “Heat wave” is defined here as any day in which the predicted high temperature for the day will be at least 80 degrees and at least ten degrees higher than the average high daily temperature in the preceding 5 days. Workloads should be adjusted accordingly to allow for physical demands.

 

  • Training – An employee’s training must include what the employer’s responsibilities are regarding provision of water, shade, cool-down rests, access to first aid, types of heat illness, environmental/personal risk factors for heat illness and emergency response procedures. Supervisory staff should also have specific training on heat illness prevention management and scope of authority on employee rest breaks and emergency response.

 

  • Written Heat Illness Prevention Plan – If there are non-English speaking employees, the plan must also be translated to the language understood by the majority of employees. A copy of the plan(s) must be available at the worksite.

A common question is: Can a single contractor/vendor supply water and/or shade for all contractors/vendors on site?  The answer is yes, but every individual employer is still responsible for implementing an effective Heat Illness Prevention Program for their respective employees.  Agreement to accept delegation or sharing of specific responsibilities of the program between parties will not absolve any violations.  Employers are ultimately responsible for their respective employees.

For further information on updating your existing program, click on the link below to the “Heat Illness Prevention Regulation Amendments – Guidance for Employers and Employees on the New Requirements” as released by Cal-OSHA on March 23, 2015.

https://www.dir.ca.gov/dosh/documents/Heat-Illness-Prevention-Regulation-Amendments.pdf