OSHA’s New Heat Safety Rule: A Comprehensive Guide to Protecting Workers

OSHA’s New Heat Safety Rule

In the United States, over the past decade, heat-related workplace incidents and fatalities have risen sharply, highlighting the urgent need for stronger safety measures.

  • Almost half of heat-related deaths occur on a worker’s very first day on the job​. Over 70 percent of heat-related deaths occur during a worker’s first week.
  • Between 2011 and 2022, an average of 40 workers per year died from exposure to environmental heat​. From 2011 to 2020, an estimated 33,890 work-related heat injuries and illnesses resulted in days away from work, averaging 3,389 cases per year​ (OSHA)​.

 

Until now, OSHA has relied on the General Duty Clause, which mandates that employers provide a safe workplace. However, this standard has proven inadequate, given the escalating number of heat-related injuries and deaths.

 

In response, OSHA has approved a new heat safety rule to enhance worker protection. This rule builds on state-level heat standards, such as those in California, to better safeguard workers nationwide. The proposed rule aims to provide comprehensive and enforceable measures to protect workers from the dangers of extreme heat, ensuring a safer working environment for all.

 

This blog provides a comprehensive overview of OSHA’s proposed heat safety rule, including its essential requirements, which it will apply to, and the importance of acclimatization.

The Definition of Heat-Related Illness by OSHA

According to OSHA, heat-related illness occurs when the body cannot dissipate excess heat, leading to heat exhaustion, cramps, and stroke. This can result from a combination of environmental heat and physical activity. Symptoms range from thirst and irritability to severe conditions like heat stroke, which can cause confusion, unconsciousness, or even death.

 

Immediate cooling and emergency medical attention are crucial for heat stroke cases. Some workers are more susceptible to heat-related illness due to medical conditions, lack of physical fitness, previous episodes of heat-related illness, alcohol consumption, and the use of certain medications or drugs. Management should commit to preventing heat-related illness for all employees, regardless of their heat tolerance levels. Physiologic monitoring, such as measuring heart rate, body weight, or body temperature, can provide individualized data to aid decisions about heat controls.

The Applicability and Exemptions of OSHA’s New Heat Safety Rule

Under OSHA’s jurisdiction, the proposed heat safety standard will apply to all outdoor and indoor work employers across the general industry, construction, maritime, and agricultural sectors.

Who’s Not Covered by the New Rule?

The proposed rule excludes certain categories from compliance:

  • Short-Duration Heat Exposure: Employees are exposed to heat for brief periods.
  • Sedentary Workers: Employees in indoor job sites maintained below 80°F.
  • Remote Workers: Those working from home or other remote locations.
  • Emergency Response Workers: Firefighters, search and rescue, and other emergency responders.
  • Public Employees: OSHA regulations do not cover public sector employees, so government employers are not subject to this rule.

 

These exemptions ensure that the rule targets workers most at risk from heat exposure while acknowledging specific work conditions and roles where the rule may not be necessary.

Important Questions Employers Should Consider for a Heat Illness Prevention Plan

When creating a written plan to prevent heat-related illness, employers should consider the following questions:

 

Aspect Questions
Daily Oversight ●      Who will provide daily oversight for the heat safety plan?
Developing Heat Tolerance ●      Do temporary workers require closer supervision due to higher susceptibility to heat?

●      How will workers returning from extended leave (typically more than two weeks) be monitored for increased risk?

●      How will new workers gradually develop heat tolerance?

First Aid and Medical Assistance ●      How will the employer ensure that first aid is adequate?

●      What is the protocol for summoning medical assistance in situations beyond first aid?

Engineering Controls and Work Practices ●      What engineering controls and work practices will be used to reduce heat stress?
Heat Stress Measurement ●      How will heat stress be measured and recorded?
Response to Heat Advisories ●      How will the employer respond when the National Weather Service issues a heat advisory or warning?
Hazard Determination ●      How will we determine if the total heat stress experienced by workers is hazardous?
Training ●      What training will be provided to workers and supervisors?

●      How will workers be trained to recognize early signs of heat stress and administer first aid?

 

Addressing these questions can help employers create a comprehensive and effective heat illness prevention plan to protect their workers.

The Requirements of OSHA’s New Heat Safety Rule

The OSHA heat safety rule includes several essential requirements that employers must ensure  to protect workers from excessive heat. Here are the main elements:

1. Heat Hazard Identification and Assessment

  • Conduct Regular Heat Risk Assessments: Evaluate the potential for heat exposure in various job roles and settings. Identify high-risk areas and tasks, especially during peak heat periods.
  • Monitor Workplace Temperatures: Implement systems to continuously monitor temperature and humidity levels, particularly during heat waves or periods of extreme heat.

2. Preventive Measures

  • Hydration: Provide accessible drinking water at all times. Ensure employees have frequent access to water and encourage regular hydration.
  • Rest Breaks: Implement scheduled rest breaks in cool or shaded areas to allow workers to recover from heat exposure. With rising temperatures, increase the frequency and duration of breaks.
  • Shade and Cooling Areas: Ensure shaded or air-conditioned rest areas are available close to the worksite for quick access.

3. Training and Education

  • Provide Heat Safety Training: Educate employees and supervisors about the dangers of heat-related illnesses, symptoms, and preventive measures. Include training on recognizing early signs of heat stress and appropriate first-aid responses. Provide annual refresher training and additional training after changes in exposure or company policies.
  • Offer Acclimatization Programs: Develop and implement acclimatization plans for new and returning workers. Gradually increase workloads and exposure time to build up a worker’s tolerance to heat. Employers can prevent heat-related illnesses among new workers by taking protective actions. The term “workers who are new to working in warm environments” refers to:
  • New, temporary, or existing employees start new tasks in warm or hot conditions.
  • Workers are wearing additional protective clothing.
  • Employees engaged in increased physical activity.
  • Workers return to hot environments after an absence of a week or more.
  • Employees continue to work through seasonal temperature changes, particularly in spring or early summer.
  • Workers on significantly warmer days compared to previous days, such as during a heat wave.

 

4. Creating a Heat Illness Prevention Plan

  • Designate a responsible individual for daily oversight of heat safety. Ensure this person is trained in identifying and controlling heat hazards, recognizing symptoms, and administering first aid.
  • Gradually acclimatize new workers to heat. Provide additional supervision for temporary workers and those returning from extended leave.
  • Ensure first aid is adequate and protocols for medical assistance are effective. Include procedures for summoning emergency services.

5. Continuous Supervision

  • Assign a trained individual to monitor heat conditions on-site. This person should be able to implement the heat plan and make necessary adjustments.
  • In cases where on-site monitoring is impractical, ensure remote supervisors are fully trained. Use the best methods to estimate heat stress remotely and communicate effectively with on-site workers. Responsibilities of the heat plan supervisor include:
    • Identify and mitigate heat hazards.
    • Recognize early signs of heat stress and administer first aid.
    • Activate emergency medical services quickly when needed.

Essential Steps to Protect Workers from Heat-Related Injuries

Regardless of the new rule’s outcome, here are ten essential measures employers can take to protect workers from heat-related injuries and illnesses and avoid legal scrutiny.

  1. Develop a Prevention Program: Create a comprehensive plan to mitigate heat-related injuries and illnesses. Conduct hazard analyses for job duties or positions with potential heat exposure, including outdoor and indoor workspaces. If applicable, ensure your heat illness prevention program aligns with state OSHA plan requirements.
  2. Implement Worker Training: Provide thorough training on heat illness prevention for all workers. Equip managers to identify potential problems and ensure compliance.
  3. Conduct Medical Screenings: Screen workers exposed to high-heat settings to identify any health conditions that could be aggravated by heat.
  4. Monitor Worker Health: Assign a designated person at each worksite to monitor worker health and conditions during extreme heat. Implement a buddy system on hot days and establish a procedure for reporting heat stress symptoms.
  5. Provide Rest Breaks: Allow unscheduled rest breaks and mandate work/rest periods. Best practice: Offer rest breaks of up to five minutes in the shade every hour or 10 minutes every two hours when temperatures exceed 87.8°F.
  6. Ensure Water Availability: Provide unlimited, easy access to cool water. Follow OSHA’s recommendation for workers to drink 4 to 6 ounces every 15 to 20 minutes, but no more than 1 quart/hour and 12 quarts/24 hours.
  7. Offer Shade and Cooling: Provide shaded areas and cooling fans. Supply hats for outdoor workers in the sun.
  8. Adjust Work Schedules: Consider changing start times and workdays to avoid high-heat hours. Rotate crews to minimize exposure during the hottest parts of the day.
  9. Implement Acclimatization: Introduce an acclimatization period for workers not used to heat exposure. Include new employees, those returning to heat exposure, and workers during seasonal temperature increases. Follow OSHA’s recommendations for a one-to-two-week acclimatization period with guidance on work periods, rest breaks, and job tasks.
  10. Prepare for Emergencies: Ensure access to first aid and prompt medical attention for workers exhibiting symptoms of heat-related illnesses.

 

By implementing these measures, employers can significantly enhance workplace safety and reduce the risk of heat-related health issues among their employees