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Cal/OSHA Urges Employers to Protect Outdoor Workers Against Heat Illness

As we get closer to another scorching California summer, Cal/OSHA is reminding employers with outdoor workers to take precautions to protect them against the heat.

California employers need to be especially mindful as Cal/OSHA has workplace safety regulations governing the prevention of heat illness and the agency actively enforces its heat illness prevention standard.

Employers should also comply for the safety and well-being of their workers, as heat illness can be deadly.

Cal/OSHA is urging employers to take the following steps to prevent heat-related illness among their employees who work outdoors:

Plan — Develop and implement an effective written heat illness prevention plan (HIPP) that is specific and customized to your specific operations.

The plan must include the following heat illness prevention and response procedures:

Training — Train all employees and supervisors on heat illness prevention. Nobody should be working outside in heat if they have not been trained in heat illness prevention and emergency procedures.

Water — Provide drinking water that is fresh, pure, suitably cool and free of charge so each worker can drink at least 1 quart per hour, and encourage workers to do so. Water should be located as close as practicable to where employees are working.

Access to shade — When temperatures reach 80 degrees, you must have and maintain one or more areas of shade at all times, when employees are present. Locate the shade as close as practical to the area where employees are working and provide enough to accommodate the number of employees on meal, recovery or rest periods at any time

Even if temperatures are less than 80 degrees, you must permit access to shade for workers to rest.

The importance of rest — Encourage workers to take a cool-down rest in the shade for at least five minutes when they feel the need to do so to protect themselves from overheating. Workers should not wait until they feel sick to cool down.

If an employee starts feeling unwell, they must be monitored for symptoms of heat illness and emergency procedures should be initiated if they don’t improve.

High-heat procedures — During heatwaves (when the mercury reaches 95 degrees), employers must institute high-heat procedures that include monitoring of employees, regular communication, more frequent reminders to drink water and rest, and additional cool-down rest periods.

Emergency response procedures should be site-specific and include who/how to call emergency services and steps to respond to signs and symptoms of heat illness. 

Observe all employees and any newly assigned to a high-heat area. You should consider giving employees who have not been working in high temperatures time to adapt to the new conditions. You can do this by initially providing them with lighter work, frequent breaks or shorter hours.

 

Get the plan right

Your heat illness prevention plan must be in writing and include all of the above. The HIPP must be written both in English and in the language understood by the majority of employees. It must also be available to employees at the work site.

Additional information about heat illness prevention, including details on upcoming training sessions throughout the state, are posted on Cal/OSHA’s Heat Illness Prevention page.

The agency also has extensive multilingual materials for employers, workers and trainers on its “Water. Rest. Shade.” public awareness campaign website.

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Cal/OSHA Making Changes to Heat Illness Prevention Rules

Cal/OSHA has released draft language that would require employers of outside workers to take additional steps to ensure their safety when working in high heat conditions.

The proposed rules were written to implement legislation — AB 2243 — signed into law in 2022 to address heat and wildfire smoke protections for workers. The draft rules, which address only heat, will complement existing heat illness prevention regulations that employers of outdoor workers are already required to follow.

The draft would require some employers to implement extra high heat illness prevention steps when temperatures reach 80 degrees for both indoor and outdoor employers. Under current rules, employers must provide shade for outdoor workers when temperatures reach 80 degrees, but additional high heat protections aren’t required until the mercury reaches 95 degrees.

 

Acclimatization

One part of the draft heat rules revises acclimatization procedures. Under current rules, a supervisor or designee must closely observe all employees during a heat wave, and workers who are newly assigned to a high-heat area must be closely observed during their first 14 days on the job. The draft language changes the term “high heat area” with “an area where the temperature equals or exceeds 95 degrees Fahrenheit.”

The draft also would require employers to either implement high-heat procedures for five working days or adopt a proposed work schedule for new and returning employees assigned to an area where the temperature is at least 80 degrees.

If an employer chooses the work schedule option, an employee’s heat exposure would be restricted for the first four days as follows:

  • 20% on day one,
  • 40% on day two,
  • 60% on day three, and
  • 80% on day four.

 

Employers would not need to implement these acclimatization procedures if they can prove that the new employee has consistently worked under the same or similar conditions in the prior 14 days.

Additionally, the proposed rules would require employers to distribute a copy of their heat illness prevention plan:

  • To new employees upon hire,
  • During heat illness prevention training, and
  • To every employee at least once a year.

 

At no time is an employer required to furnish a copy of the HIPP more than twice a year.

 

Current rules refresher

For outdoor workplaces, shade must be present when temperatures are greater than 80°F. When temperatures are less than 80°F, shade must be available upon request.

For indoor workplaces, provide access to at least one cool-down area that is kept at a temperature below 82°F and shielded from high-radiant heat sources.

Shade and cool-down areas must be:

  • Blocked from direct sunlight.
  • Large enough to accommodate the number of workers on rest breaks so they can sit comfortably without touching each other.
  • As close as possible to the work areas.

 

Employers shall encourage workers to take preventative cool-down rest periods and allow those who ask for one to take it. Employers are also required to monitor workers during rest periods for symptoms of heat-related illness.

When the temperature reaches 95°F, employers are required to implement high-heat procedures which must include:

  • Observing and communicating effectively with workers.
  • Reminding workers to drink water and take cool-down rest breaks.

 

Employers are also required to:

  • Establish, implement and maintain an effective written outdoor HIPP that includes procedures for providing drinking water, shade, preventative rest periods, close observation during acclimatization, high-heat procedures, training and prompt emergency response.
  • Provide first aid or emergency response to any worker showing signs or symptoms of heat illness, including contacting emergency medical services.
  • Closely observe new workers and newly assigned workers in hot areas during a 14-day acclimatization period, as well as all employees working during a heat wave.
  • Provide training on the HIPP to both workers and supervisors.
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