Cal/OSHA Proposes Ground-Breaking Indoor Heat Illness Prevention Standard

Cal/OSHA has proposed its long-awaited indoor heat illness prevention standard as increasingly hot summers are affecting workers in indoor spaces like warehouses, production operations, restaurants and more.

The proposed standard, largely based on the state agency’s outdoor regulations, will require employers whose workplaces at times are at least 82 degrees to have a written Indoor Heat Illness Prevention Plan.

The standard, once it takes effect, will affect employers throughout the state and many will have to take steps and invest in equipment and planning to ensure compliance. The Occupational Safety and Health Standards Board heard public comment on the proposed standard May 18, 2023. The Standards Board is scheduled to vote on the proposed regulation in the first quarter of 2024 so that the new regulation could be in place for summer 2024.

The Occupational Safety and Health Standards Board, which writes the Golden State’s workplace safety regulations, hired RAND Corp. to conduct an impact study of the proposal, which predicted that the rules would save 10 lives and prevent more than 2,000 heat illness cases in the first 10 years after implementation.

The preventative measure to which most employers will likely resort is air-conditioning. The Standards Board wrote in its proposal, according to the Cal-OSHA Reporter trade publication: “There is likely to be a particular need to reduce temperatures in large warehouses, manufacturing and production facilities, greenhouses, and wholesale and retail distribution centers.”

Other facilities that would likely also need to install HVAC units include restaurant kitchens and dry cleaners. They may also need to improve air circulation in their operations.

Under the proposal, the following regulations apply to a workplace where the indoor temperature exceeds 82 degrees:

Access to clean drinking water

Employers are required to provide access to potable water that is fresh, suitably cool and free of charge.

It must be located as close as practicable to the work area, as well as indoor cool-down areas where employees can rest. If an employer doesn’t provide water continuously, it will be required to provide at least one quart per hour per employee per shift.

Employers should encourage frequent water consumption.

Access to cool-down areas

Employers will be required to provide at least one cool-down area at all times when employees are present, and to allow employees who ask for a cool-down break to take one if they feel they need it. They should also be encouraged to take frequent cool-down breaks.

Workers taking cool-down breaks shall be monitored and asked to stay in the area if they are experiencing heat illness symptoms. As long as symptoms persist, they may not be ordered back to the work they were doing.

Also, employers will be required to provide first aid or emergency response to any workers showing heat illness signs or symptoms.

Assessing and measuring heat

Employers shall measure the temperature and heat index and record the readings, as well as identify environmental risk factors for heat illness. This is an important step to ensure that employers know when to implement prevention protocols.

Control measures

Employers can implement a number of measures to protect their workers against heat illness and to comply with the proposed standard, including:

Engineering controls — This can include barriers between heat sources and employees, isolating hot processes from workers, air-conditioning, cooling fans, mist fans, swamp coolers, ventilation, etc.

Administrative controls — This can include limiting exposure by adjusting work procedures, practices or schedules (working during cooler periods, using work/rest schedules or reducing the speed or intensity of work).

Personal heat-protective equipment — This could include water and air-cooled garments, cooling vests, heat-reflective clothing and supplied air personal-cooling systems.

Emergency response procedures

Employers will need to develop and have in place emergency response procedures that workers and supervisors can follow in case they are experiencing heat illness. This includes:

• An effective communication system to allow workers to contact a supervisor or emergency services.
• Steps for responding to signs and symptoms of heat illness, including first aid and providing emergency medical services.
• Emergency response procedures for severe heart illness. Symptoms could include limited consciousness, loss of balance, vomiting, disorientation or irrational behavior.
• Monitoring employees exhibiting signs of heat illness, and not leaving them alone without offering them on-site first aid or medical services.

Acclimation steps

Employees should be closely observed during heat waves, and new workers must be closely observed during their first 14 days of work to ensure they are acclimating.

Training

Employees and supervisors will need to be trained on:

• Personal risk factors for heat illness.
• Their employer’s procedures for complying with the regulation.
• The importance of frequent water consumption.
• The importance of acclimation.
• Signs and symptoms of heat illness, and first aid or emergency response procedures.