OSHA is turning up the heat — steps to keep workers safe and remain compliant.

With summer temperatures rising comes an increase in heat-related work injuries that can be devastating. 2023 experienced the hottest summer on record, and with temperatures rising each year, heat stress becomes more and more of a concern in the workplace. According to the Bureau of Labor Statistics (BLS), between 2011 and 2021, there have been almost 34,000 work-related heat injuries and illnesses involving days away from work. Considering the impact on workers and your organization, it is clear that preventing these illnesses and injuries is in everyone’s best interest.

While best practices are commonly used, there is currently no formal federal OSHA (Occupational Safety and Health Administration) standard for employers to adhere to when it comes to heat safety. Currently, heat-related hazards are enforced through state-specific mandates, as well as OSHA’s General Duty Clause, which requires employers to provide a work environment free from recognized hazards. This may change soon — in the past two years, OSHA has conducted nearly 5,000 inspections as part of its National Emphasis Program (NEP) to evaluate heat illnesses and injuries for indoor and outdoor workers and is developing a national heat stress rule to protect workers. The final rule has yet to be determined, but OSHA has outlined the potential requirements that are being considered, including:

identifying heat hazards

Monitoring weather conditions may sound like a given, but understanding the specific heat hazards present can get more complicated. The new rule may require measuring the wet bulb globe temperature (WGBT). WGBT determines the heat stress in direct sunlight, considering temperature, humidity, wind speed, sun angle, and cloud cover. This differs from the heat index, which is calculated for shady areas. Many nations and military agencies use the WGBT to guide working in direct sunlight. Using this standard to trigger employer obligations, the new rule could contain heat index thresholds, with initial temperatures as low as 76°F and as high as 83°F.

control measures

Certain control measures are defined in the proposed ruling to keep workers at safe body temperature levels.

engineering controls

By providing cool-down areas with fans, shade, air conditioning, and barriers around heat sources, employers can help lower the temperature for their employees.

administrative controls

In addition to cool-down areas, employers would be required to provide cool water and rest breaks, acclimatize new workers, alter work schedules to cooler times of day, and implement emergency response procedures.

personal protective equipment (PPE)

Cooling vests and wetted garments are examples of PPE that should be used to protect employees from the heat.

training and recordkeeping

A large component of heat safety is ensuring proper training for employees on how to prevent and respond to heat stress. Both employees and employers must understand the environmental factors, warning signs, and symptoms of injuries and illnesses. The proposed ruling would aim to provide guidance for employers on how to make sure their staff understands what protective measures are in place and how to implement them. Another key element in preventing heat-related injuries and illnesses is keeping records on temperature data, illnesses and injuries, and acclimatization records. This data must include a log of all incidents, even if they only require first aid.

written heat illness prevention program

Along with adhering to the guidelines, employers may be required to draft a written Heat Injury and Illness Prevention Program (HIIPP). An effective HIPP would include assessing hazards, evaluating how and when heat is measured, guidance on acclimatizing new and returning workers, determining what controls are implemented, and what training will be provided.

coordination at multi-employer worksites

Joint-employer or multi-employer worksites present certain complications when it comes to compliance with regulations. In the case of OSHA’s proposed ruling, host employers would be required to communicate to all workers on-site — including contractors and those employed by staffing agencies — about heat hazard procedures.

how can employers prepare?

A good starting place for any employer would be to take a look at some state specific regulations to get a preview of what a federal program may look like. California’s Outdoor Hear Illness Prevention Standard and Heat Illness Prevention Special Emphasis Program are good examples that employers can follow to ensure they are not caught off guard when a final ruling is made. We’ve compiled some best practices to begin today to make sure your workers remain safe this summer.

1. plan ahead

Review OSHA’s Heat Illness Prevention resources to get a full understanding of the risks, responsibilities, and rights surrounding heat injury and illness.

2. assess your risk

Begin by recording and understanding the conditions of your workplace. Evaluate past incidents and future areas of risk to address. Consider environmental factors, workload, employee PPE, and any excess heat sources such as machinery or furnaces.

3. know the signs and symptoms

Familiarize yourself and your staff with the warning signs of heat stress and heat stroke. Heat stroke is a medical emergency that can be fatal if not promptly and properly treated.

4. make a prevention plan

Develop a mandatory break schedule and provide adequate hydration that is easily accessible. Implement controls like cooling systems and ventilation to maintain safe temperatures and use wet bulb globe temperature measurements to monitor the environment. Leverage resources like OSHA’s Water, Rest, Shade guidance for a simple and effective prevention plan.

5. establish a training program

Onboarding and training employees is more important than ever during the summer months where seasonal employees may be less familiar with safety standards. Develop a comprehensive program to prepare them on proper safety precautions, as this is crucial to improving safety metrics. Consider using new hire checklists to standardize expectations.

6. partner up

Working with a staffing partner like Randstad that is up to date in the latest health and safety regulations is a great way to support your safety program with resources like Safety Coaches and safety incentive programs that reinforce positive behaviors in the workplace.

key takeaways

The increasing risk and cost of heat-related injuries and illnesses is a concern for every employer. With careful planning and prevention, heat stress can be managed and workers can stay safe and productive. OSHA’s proposed ruling aims to formalize the best practices that many employers already implement by formalizing standards for prevention. Workplace incidents - heat related or not - are a serious matter and understanding risks and taking steps to avoid them is crucial for every employer looking to reduce the impact to their business and their employees. Download our guide on Why Accidents Happen and How to Avoid Them to understand the common culprits of workplace incidents and what steps you can take to keep safety top of mind.