Under the Occupational Safety and Health Administration’s (OSHA) ongoing national emphasis program concerning heat illness prevention, businesses currently face elevated scrutiny of this often-overlooked health and safety issue. With national rulemaking under consideration at present, it is a great time to get a head start on compliance.
Creating a national standard
While national rulemaking is in its early stages, OSHA models its current inspection practices on National Institute for Occupational Safety and Health (NIOSH) methodology and data comparison to American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit values. Additionally, California, Colorado, Minnesota, Oregon, and Washington have already established and are enforcing state-level regulations concerning heat illness prevention that are likely to influence national standards. National standards for preventing heat-related illness and injury would implement more consistent protections for workers across the U.S.
OSHA published its advanced notice of rulemaking in October 2021, followed by a comment period that closed in January 2022. The agency completed the Small Business Regulatory Enforcement Fairness Act process in early 2023 and is currently developing the proposed rule to be published for public review and comment.
Get proactive
While businesses may not need to comply with national standards for a couple years, getting a head start on heat compliance will improve your overall safety program and save you time and scrambling when rules go into effect. There are steps you can take today to prepare.
First, consider potential hazards specific to your operations. While heat hazards are commonly associated with working outside in warm weather, indoor tasks and processes are not exempt. Machinery, inadequate ventilation, humidity, the degree of human physical activity, and even the types of clothing worn while working can all amplify heat exposure and need to be considered for potential hazard.
Once you’ve inventoried potential hazards, check out OSHA’s Employer Checklist for Outdoor and Indoor Heat-Related Injury and Illness Prevention. The checklist is designed to help employers identify risk factors and gauge preparedness. Items on the list include preventive measures, plans, and policies to avoid heat exposure, monitor employee exposure to potential heat hazards, and ensure they have the resources to avoid injury or illness on the job.
Partner with us for success
While the checklist is a great initial step, some processes may require more substantial hazard analysis. We partner with clients in a range of industries to perform a heat hazard assessment to help identify areas of concern for heat exposure. The heat hazard assessment process is closely aligned with the OSHA and NIOSH methodologies, and first includes a qualitative review to help determine potential heat hazards and tasks and work areas impacted by those hazards.
This initial review can include assessing past heat exposure incidents and previous heat hazard surveys performed, task observation, and discussion with the client on the nature of work. The information collected from the qualitative survey is used to help create a heat hazard assessment plan. The plan will be implemented to include a survey to determine the wet bulb globe temperature (WBGT) in the identified areas of concern. The survey may be performed once, but often it is best to perform the survey multiple times to assess varying conditions and influences on the work environment.
Once the survey is completed, the WBGT data is analyzed with various factors applied (clothing worn, etc.) so the data can then be compared to available published exposure limits (such as NIOSH and/or ACGIH). From this analysis, we can assist the client with the selection of potential controls to help minimize exposure, including engineering controls such as ventilation, and administrative controls such as training, establishing criteria for additional safe work measures, and the development of a heat illness prevention plan.
Integrating heat hazard protection into your health and safety program now is a win-win for keeping employees safer and preparing your organization for future OSHA standards. Reach out to Woodard & Curran to talk about how we can help you to implement a heat illness prevention program tailored to your operations.
