Heat Injury and Illness Prevention Update: Compliance with OSHA

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July 2, 2024: OSHA is proposing to issue a new standard, Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. The standard would apply to all employers conducting outdoor and indoor work in all general industry, construction, maritime, and agriculture sectors. It may soon require employers to create a plan to evaluate and control heat hazards in their workplace. This aims to more clearly set forth employer obligations and the measures necessary to effectively protect employees from hazardous heat. This proposed rule will undergo a 120-day comment period, and then go to review. If finalized, the proposed standard would require employers to comply with all requirements of the standard 90 days after the effective date (150 days after the date of publication of the final standard in the Federal Register). The proposed compliance date is intended to allow adequate time for employers to undertake the necessary planning and preparation steps to comply with the standard. OSHA has preliminarily concluded that 90 days is sufficient time for employers to develop a Heat Injury and Illness Prevention Plan (HIIPP), identify heat hazards in their workplace(s), implement the protective measures required under the standard, and provide required training to employees.

Steps for compliance

  • Develop Heat Injury and Illness Prevention Plan
  • Identifying heat hazards
  • Mind the “initial heat trigger”
  • Mind the “high heat trigger”
  • Heat illness and emergency response and planning
  • Training
  • Recordkeeping
  • Implemented at no cost to employees

Recommendation: Employers should implement these safeguards which will include things like rest breaks, access to shade and water, and heat acclimatization for new employees.

Reference

Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings (n.d.). Dept. of Labor, Occupational Safety and Health Administration. https://www.osha.gov/sites/default/files/Heat-NPRM-Final-Background-to-Sum-Ex.pdf