OSHA “HOT” OVER HEAT STRESS - New Enforcement Initiative Is Here

Submitted by Bob Dunlevey of Taft/Law



With summer here, heat stress issues can rear their ugly head – not only on outdoor worksites but also in production facilities. Don’t be caught ill-prepared for an incident and a subsequent visit by OSHA – establish your heat stress program today. Beware, OSHA has started implementing a new enforcement initiative on heat related hazards and developing a National Emphasis Program on heat inspections. OSHA Area Directors have been instructed to prioritize inspections of heat related complaints and expand the scope of investigations to look for heat hazards. This summer will be OSHA’s first season to carry out its initiative. Simply telling your employees that it is a hot day and they should take breaks when they need to and drink as much water as necessary will not meet OSHA’s expectations and could very easily result in a citation.

The risk of heat stress depends upon many factors related to the individual employee and this makes the challenge of making a safe workplace for all even more challenging. Those risk factors include the employee’s physical condition, the temperature and humidity, clothing worn, the pace of work and how strenuous it may be, exposure to sun and environmental conditions such as air movement.

OSHA expects more from employers than merely offering water, rest and shade – additional steps to address heat in the workplace need to be taken. OSHA also insists upon: (1) implementing an “acclimatization program” for new employees and those returning from extended time away, such as vacations or leaves of absence; (2) implementing a work/rest schedule; and (3) even providing a climate controlled area for cool down. For those employers utilizing temporary employees, there is a greater risk of heat-related illness and OSHA would urge greater care in adopting an acclimatization program for them.

Your heat stress program can have many components, including:

TRAINING

· Hazards of stress

· Responsibility to avoid heat stress

· Recognition of danger signs/symptoms because employees may not recognize their own

· First aid procedure

· Effects of certain medications in hot environment

PERSONAL PROTECTIVE CLOTHING/EQUIPMENT

· Light summer clothing allowing free movement and sweat evaporation

· Loosely worn reflective clothing to deflect heat

· Hats and helmets

· Cooling vest and wetted clothing for special circumstances

· Fans

ADMINISTRATIVE/ENGINEERING CONTROLS

· Assess the demands of all jobs and have monitoring and control strategies in place for hot days and hot workplaces

· Schedule hot jobs for cooler parts of the day

· Reduce physical demands

· Permit employees to take intermittent rest breaks with water breaks and use relief workers

· Have air conditioning and shaded areas available for breaks/rest periods with ice available

· Increase air movement

· Exhaust hot air and steam

HEALTH SCREENING/ACCLIMATIZATION

· Let employees get used to hot working conditions by using a staggered approach over several days, such as beginning work with 50% of the normal workload and time spent in the hot environment and then generally increase it over five days

· Make employees aware that certain medications, such as Diuretics, anti-hypertensives (blood pressure), anti-cholinergics (pulmonary disease – COPD), and alcohol abuse, can exacerbate problems.

OSHA is also inclined to cite an employer if prompt remedial action is not taken when an employee falls victim to heat stress. Establish specific procedures for heat-related emergencies and provisions for First Aid when symptoms appear. Remember, employees may resist First Aid because of the confusion caused by their heat stress. So, training on the signs and symptoms is also encouraged.

Consider the OSHA-NIOSH Heat Index App as a tool for helping supervisors recognize when additional preventive measures should be taken - Heat App.


Read OSHA’s comprehensive Review Commission decision in Secretary of Labor v. A.H. Sturgill Roofing, Inc., OSHRC Docket No. 13-0224, which overturned heat citations and provides something to assist every employer in successfully defending against heat citations - see Decision. Sturgill was represented throughout the case by Bob Dunlevey of Taft/Law.

For more information regarding heat stress programs and workplace safety law, contact Bob Dunlevey, Taft/Law, (937) 641-1743.

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