Contributor: Brannon Aaron, ASP, NRP, Roco Rescue

This article was originally published on rocorescue.com on August 13, 2024.

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August 13, 2024 — With the proposed standard of Subpart J—General Environmental Controls § 1910.148 Heat Injury and Illness up for codification, it may be time to examine some of the proposed changes that may affect indoor and outdoor work in the near future. Knowing what lies ahead will always help guide your worker’s and companies’ best interests.

Who Is Not Covered

This proposed standard outlines the scope of work activities to which it does not apply. These include work activities with no reasonable expectation of exposure to high heat, short-duration employee exposures of 15 minutes or less in any 60 minutes, organizations primarily engaged in firefighting and emergency response activities, work performed in indoor areas or vehicles with consistent air conditioning keeping the temperature below 80°F, telework, and sedentary work activities at indoor work areas involving sitting, occasional standing and walking, and occasional lifting of light objects.

This is not to say that any of the jobs listed above are easy. While firefighting and emergency response organizations are not covered by this standard, protecting workers from the effects of heat related illnesses and injuries should be considered as it is reasonable to assume that workers will be stressed by heat during most emergency response situations. For this reason, it is important to keep this in mind when writing your emergency response plans.

Heat Index and Initial Heat Triggers

The proposed standard defines heat index as “Heat index means the National Weather Service heat index, which combines ambient temperature and humidity.” This would usually involve a wet bulb (WBGT) and a small amount of algebra. Luckily, we already have the OSHA-NIOSH Heat Safety Tool App (OSHA-NIOSH, 2024) to help us get a reasonable forecast of the day’s heat index for the areas where work is being performed.

The Initial heat trigger is defined as a heat index of 80°F or a wet bulb globe temperature equal to the NIOSH Recommended Alert Limit. This applies to both indoor and outdoor non-sedentary work. This summer, in many places now, temperatures are hitting 80°F well before work even starts in some areas, so start planning steps to mitigate the heat as soon as possible.

The high heat trigger is defined as a heat index of 90°F or a WBGT equal to the NIOSH recommended exposure limit (REL). Each trigger provides additional requirements on the employer to protect workers from hazardous heat. For specifics, view 1910.148 paragraphs e and f.

Heat Injury and Illness Prevention Plan (HIIPP)

One of the most critical parts of the proposed regulation is that companies must start writing and making their heat injury and illness prevention plan (HIIPP) available to workers. If you have fewer than ten employees, it doesn’t have to be written but should still be available to all employees.

The employer must review and evaluate the effectiveness of the HIIPP whenever a heat-related illness or injury occurs that results in death, days away from work, medical treatment beyond first aid, or loss of consciousness, but at least annually. Following each review, the employer must update the HIIPP as necessary. Specifics on developing a HIIPP can be found in paragraph g of the proposed standard.

Acclimatization

Acclimatization refers to the body’s adjustment to working in hot conditions as a person is exposed to heat gradually over time. New workers or individuals who are new to the site require gradual acclimatization to heat. This means that on the first day of work, the employee’s exposure to heat should be limited to no more than 20% of the normal work shift duration, 40% on the second day, 60% on the third day, and 80% on the fourth day.

Training

In addition to the many other requirements of this standard, employers must also provide training to workers and supervisors. This standard highlights 16 key elements that employers are required to train workers and supervisors on. These items range from training workers on the hazards of heat stress to related injuries and illnesses, their signs and symptoms, and risk factors associated with heat injury and illness. Paragraph h of the standard goes into greater detail on the frequency and specifics of required training.

Conclusion

I encourage everyone to review some of the other literature and do a deep dive to fully understand what has been published so far. Some of these changes may be added to or removed from the publication, so keep this in mind and be on the lookout for any further updates. Let’s keep ahead of the curve and keep our workers safe.

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