For the first time, the Occupational Safety and Health Administration (OSHA) has launched a National Emphasis Program (NEP) to protect workers from injuries and illnesses caused by heat hazards. OSHA’s new NEP ramps up the inspection and enforcement of workplaces in industries deemed to be high risk for heat stress. Appendix A of the NEP Document outlines the list of 70 industries affected. Here is everything you need to new about the OSHA’s new EPA.
What Are the New OSHA Heat Hazards Regulations?
OSHA’s inspections prioritize sites with complaints of employer-related heat hazards. Additional inspections occur on days the National Weather Service issues a heat warning or advisory local to that area. Employers to inspect are randomly selected from the list of high-risk industries. On “heat priority days” when the heat index is 80°F or higher, OSHA field staff initiate compliance assistance to help employers keep workers safe on the job. Also, during these days, OSHA inspectors search for and address heat hazards during inspections of all workplaces, regardless of their industry.
The compliance safety and health officers (CSHOs) review records of heat-related employee incidents. They interview workers for symptoms that may indicate heat-related illnesses or injuries. Working conditions that could contribute to heat stress such as dealing with hot air or driving a hot vehicle are recorded. Workers’ proximity to furnaces and other hot equipment are noted. They also identify the use of heavy or bulky equipment, including personal protective equipment (PPE). CSHOs categorize the exertion of work depending on the duration and level of strenuous activity. They take both average and peak workloads into consideration.
Under the NEP, OSHA has not set any specific standards to comply with. This is because the stages of official rule-making can take multiple years. The NEP is an initiative to make progress while the new rules finalize in court. Although there are no specific guidelines to follow yet, they have outlined general ways to comply in their documentation. The NEP starts on April 8, 2022 and will continue until April 8, 2025 unless cancelled or extended.
How Do I Comply with the Standards of These Inspections?
Create a written plan for heat hazard prevention and response. Define how you plan to monitor the heat index of your site and its impact our your workers’ safety. Next, make sure to outline the precautions you are taking to prevent heat stress. Record all incidents, complaints, and concerns with heat illnesses or injuries. Then, document a clear procedure on how to respond to these cases and clearly note each occurrence.
According to Appendix B of the NEP, CSHOs will ensure that the air conditioning is adequate enough to provide a cool place to rest during weekdays. In Appendix D, as an example it is recommended to use air conditioning, proper ventilation, and cooling fans. However, it is also noted that you should tailor your efforts specifically to what you need at your site. Renting portable air conditioners, air filters, and fans/air movers is a great way to be safe and help prevent heat hazards. If you are in the Midwest, On Site Companies is a great resource for these types of climate control rentals.
Schedule rested breaks for hydration and provide access to unlimited cool water for your staff. Give access to shaded areas for employees that spend work time outdoors. Consider using earlier or later start times with rotating shifts to limit exposure to sun. Make sure to give proper PPE, including breathable clothing, as well as hats and sunglasses to protect from the sun.
Provide your staff with training and resources for heat hazard education. Train them on topics such as the symptoms of heat illness, heat stress prevention, the importance of hydration, first aid, and emergency response procedures. Also, consider using a “buddy” system for staff to check in with each other.
What Are My Resources for OSHA Heat Hazards Compliance?
The full NEP linked above contains all of the new policies in entirety. However, this NEP Fact Sheet summarizes the most important information into one page. For more in-depth rational and data behind the reasoning for these changes, OSHA references the CDC’s publication, Criteria for a Recommended Standard: Occupational Exposure to Heat and Hot Environments.
OSHA’s area offices are engaging with unions, employers in “high risk” industries, and other advocacy groups for assistance. Their On-Site Consultation Program is a free resource for small and medium-sized businesses. This is separate from and does not result in punishment from OSHA. Consultants work with employers to identify potential hazards and assist in developing plans for OSHA compliance. Employers can request this program by contacting their local consultant.
The Heat Illness Prevention Campaign educates employers and employees on the dangers of heat stress. On their website, OSHA has additional information on the dangers of heat exposure and how to prevent heat stress. Use the Health Safety App to calculate the heat index and view the risk level of your job site on your phone. The OSHA Technical Manual (OTM) is another great resource for training on health, safety, and construction hazards. Also, the National Heat Integrated Heat Health Information System (NHIHHIS) has several helpful tools and articles to assist in your heat hazard prevention plan.
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