Let’s talk about heat! At least, OSHA is …

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On April 8, 2022, the Occupational Safety and Health Administration issued a National Emphasis Program on Outdoor and Indoor Heat-Related Hazards. You can access OSHA’s Instruction sheet here.

What does this mean? It is a part of OSHA’s efforts to combat heat-related illnesses and injuries. OSHA intends to focus on targeted enforcement, compliance assistance, and outreach efforts to encourage employers’ early interventions to prevent heat-related illnesses and deaths.

As part of the campaign to reduce heat-related illnesses and deaths, OSHA had also published advance notice of a proposed new rule which would relate to heat injury and illness prevention in outdoor and indoor work settings. OSHA explained its reasoning for the rule here:

On October 27, 2021, OSHA published an Advance Notice of Proposed Rulemaking (ANPRM) for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings in the Federal Register. With this publication, OSHA is beginning the rulemaking process to consider a heat-specific workplace standard. A standard specific to heat-related injury and illness prevention would more clearly set forth employer obligations and the measures necessary to more effectively protect employees from hazardous heat. The ultimate goal is to prevent and reduce the number of occupational injuries, illnesses, and fatalities caused by exposure to hazardous heat.

The Instruction document from OSHA summarized its targeted enforcement process as follows.

To increase the likelihood of preventing heat-related illnesses and deaths and make efficient use of OSHA resources, compliance safety and health officers (CSHOs) who are investigating for other purposes, shall open or refer a heat related inspection for any hazardous heat conditions observed, recorded in the OSHA 300 logs or 301 Incident Reports, or where an employee brings a heat related hazard(s) to the attention of the CSHO (such as, employees or temporary workers being exposed to high temperature conditions without adequate training, acclimatization or access to water, rest, and shade).

What are some of the outdoor and indoor industries where heat-related illnesses have occurred? While certainly not limited to the industries listed below, this chart from OSHA’s website provides some insight as to certain industries which are conducive to these heat-related hazards.

Outdoors Indoors
Agriculture Bakeries, kitchens, and laundries (sources with indoor heat-generating appliances)
Construction – especially, road, roofing, and other outdoor work Electrical utilities (particularly boiler rooms)
Construction – roofing work Fire Service
Landscaping Iron and steel mills and foundries
Mail and package delivery Manufacturing with hot local heat sources, like furnaces (e.g., paper products or concrete)
Oil and gas well operations Warehousing

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