OSHA Heat Illness and Hazard Communication Updates
|
APPLIES TO All Employers Subject to OSHA |
EFFECTIVE As Indicated |
QUESTIONS? Contact HR On-Call |
Quick Look
|
Discussion
The Occupational Safety and Health Administration (OSHA) made two significant updates. First, OSHA released its proposed rule for “Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings.” Second, it announced a final rule to update the current Hazard Communication Standard. Details on the two updates are below.
Heat Injury and Illness Prevention
OSHA’s proposed rule for “Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings” is set for publication in the Federal Register. Following publication, there is a public comment period before a final rule will be issued. The rule will apply to all employers, subject to limited exception; of particular note, the rule does not apply to work environments not expected to reach 80 degrees (e.g., office environments with air conditioning maintained below 80 degrees), short duration exposures (i.e., exposure of 15 minutes or less in any 60-minute period), remote workers, or certain emergency response activities. The main requirements employers should be aware of are summarized below.
Heat Injury and Illness Prevention Plan. Employers must develop and implement a work site heat injury and illness prevention plan (HIIPP) with: (1) a list of the types of work activities covered; (2) policies and procedures required to comply with the final rule; (3) identification of the heat metric used to monitor heat conditions; (4) how to evaluate heat stress hazards from clothing that is vapor-impermeable; (5) designation of one or more heat safety coordinators to implement and monitor the HIIPP; (6) input and involvement of non-managerial employees and their representatives; (7) and review of the effectiveness of the HIIPP whenever a heat-related illness or injury occurs. The HIIPP must be in writing if the employer has more than 10 employees. The HIIPP must be available at the work site to all employees and in a language each employee, supervisor, and heat safety coordinator understands.
Monitoring Heat Conditions. Employers must monitor heat conditions at outdoor work areas by tracking local heat index forecasts from the National Weather Service or other reputable source using the heat index or ambient temperature and humidity measured separately or through wet bulb globe temperature. For indoor work areas, employers must similarly evaluate local heat index forecasts. The initial heat trigger for safety precautions is 80° Fahrenheit. The high heat trigger of 90° Fahrenheit requires additional precautions.
Access to Water. Employers must provide access to potable water for drinking that is placed in locations readily accessible to the employee, suitably cool, and of sufficient quantity to provide access to one quart of drinking water per employee per hour.
Rest Breaks and Break Areas. The employer must provide one or more areas for employees to take breaks that can accommodate the number of employees on break and that has artificial or natural shade open to outside air and blockage of direct sunlight or has air-conditioning.
Acclimatization Plan. Employers must implement a plan for acclimatizing new and returning employees during their first week on the job. The gradual acclimatization for new employees is: 20% of a normal work shift exposure duration on the first day of work, 40% on the second day of work, 60% of the third day of work, and 80% on the fourth day of work. The process for returning employees is: 50% of a normal work shift exposure duration on the first day of work, 60% on the second day of work, and 80% of the third day of work.
Heat Illness Symptom Monitoring and Emergency Response. Employers must implement at least one of the following methods of observing employees for signs and symptoms of heat-related illness: (1) a mandatory buddy system in which co-workers observe each other; (2) observation by a supervisor or heat safety coordinator, with no more than 20 employees observed per supervisor or heat safety coordinator; and (3) for employees who are alone at a work site, the employer must maintain a means of effective, two-way communication with those employees (e.g., handheld transceiver, phone, or radio) and make contact with the employees at least every two hours.
An emergency response plan must include: (1) a list of emergency phone numbers (e.g., 911, emergency services); (2) a description of how employees can contact a supervisor and emergency medical services; (3) individual(s) designated to ensure that heat emergency procedures are invoked when appropriate; (4) a description of how to transport employees to a place where they can be reached by an emergency medical provider; (4) clear and precise directions to the work site, including the address of the work site, which can be provided to emergency dispatchers; and (5) procedures for responding to an employee experiencing signs and symptoms of heat-related illness, including heat emergency procedures for responding to an employee with suspected heat stroke.
Training. Prior to any work at or above the initial heat trigger, the employer must ensure that each employee receives training on, and understands, the following: (1) heat stress hazards; (2) heat-related injuries and illnesses; (3) risk factors for heat-related injury or illness, including the contributions of physical exertion, clothing, personal protective equipment, a lack of acclimatization, and personal risk factors (e.g., age, health, alcohol consumption, and use of certain medications); (4) signs and symptoms of heat-related illness and which ones require immediate emergency action; (5) the importance of removing personal protective equipment that may impair cooling during rest breaks; (6) importance of taking rest breaks to prevent heat-related illness or injury, and that rest breaks are paid; (7) importance of drinking water to prevent heat-related illness or injury; (8) the location of break areas; and (9) the location of employer-provided water. This is a non-exhaustive list, and there are additional requirements included in the proposed rule. Supervisors must receive additional training on policies and procedures for monitoring heat conditions and procedures the supervisor or heat safety coordinator must follow if an employee exhibits signs and symptoms of heat-related illness. Employees and supervisors must also receive annual refresher training on these topics.
Recordkeeping. If the employer conducts on-site measurements at indoor work areas, they must have written or electronic records of those indoor work area measurements and retain those records for six months.
Hazard Communication Standard
Effective July 19, 2024, an updated Hazard Communication Standard will: (1) require labels on small packaging to be more comprehensive and readable; (2) make changes to help ensure trade secrets no longer prevent workers and first responders from receiving critical hazard information on safety data sheets; (3) a clearer hazard classification process to provide more complete and accurate hazard information on labels and safety data sheets; (4) update physical hazard classes to better inform users on safe handling of explosives, aerosols and chemicals under pressure; and (5) update precautionary statements on how to safely handle, store and dispose of hazardous chemicals. These changes align with the requirements of other federal agencies and Canada.
Action Items
- Review the OSHA website here for the proposed rule.
- Review updated Hazard Communication Standard here.
- Update health and safety policies and procedures.
- Develop and implement a work site heat injury and illness prevention plan.
- Have appropriate personnel trained on the requirements.
Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2024 ManagEase