As the heat index reached record highs this Summer, OSHA continued to “raise the heat” with its first ever National Heat Safety Rule and made heat illness and hazards a top enforcement priority through its Heat Hazard National Emphasis Program (NEP). The agency continues to conduct proactive inspections for heat-related hazards in the “high-risk” industries, despite budget cutbacks. These include a category that covers many manufacturing facilities besides the more obvious outdoor construction activities. Do you know how best to protect your workforce while staying in compliance with the new rule and are you preparing adequately for a possible OSHA inspection if you are in one of the “high risk’ industries?

One of the “hottest” topics related to regulations, is whether the current Administration will roll back or even eliminate entirely some of the pending requirements. The National Haet Safety Rule has not been challenged based on statutory authority (“agency overreach”) as it was first announced 7/2/2024, and it has had a long comment period with relatively few opposing viewpoints. While it warrants a careful monitoring of its regulatory status, even without this new rule, OSHA can still site heat-related violations under the General Duty Clause and under the National Emphasis Program which was recently extended through April 8, 2026.

In preparation for the National Heat Safety Rule, many industries have created written programs on what steps will be taken when the heat index increases. These include additional worker breaks in a shady, cooler area, providing adequate hydration, and heat-reducing clothing. Do you know the latest in these Best Manufacturing Practices? Will your self-assessment achieve the standard that an OSHA Inspector will be looking for to adequately protect your workers and to comply with the existing regulations?

Concerning those heat-related illnesses, do you know the symptoms and recommended actions to take when you or a co-worker develops signs of heat rash, heat cramps, heat syncope, heat exhaustion or heat stroke? Here is how to recognize heat-reated illnesses:

• Heat rash is a skin irritation caused by excessive sweating during hot, humid weather. It causes small, red pimples on the skin from continuous exposure to heat or humid air due to clogged sweat ducts.
• Heat cramps usually affect workers who sweat a lot during strenuous activity. This sweating depletes the body’s salt and moisture levels. Low salt levels in muscles causes painful cramps.

NOTE: Heat cramps may also be a symptom of heat exhaustion.

• Heat syncope is a fainting (syncope) episode or dizziness that usually occurs with prolonged standing or sudden rising from a sitting or lying position. Factors that may contribute to heat syncope include dehydration and lack of acclimatization.
• Heat exhaustion is the body’s response to an excessive loss of the water and salt, usually through excessive sweating. Workers most prone to heat exhaustion are those that are elderly, have high blood pressure, and those working in a hot environment.
• Heat stroke is the most serious heat-related disorder. It occurs when the body becomes unable to control its temperature: the body’s temperature rises rapidly, the sweating mechanism fails, and the body is unable to cool down. Heat stroke can cause death or permanent disability if emergency treatment is not given.

Do you know the personal and environmental heat stress factors that make you most susceptible to these heat-related illnesses? If so, how do you instill an effective “always watch out for yourself and your co-workers” approach?

How do you put all this together into a better heat stress program, including a written program and training? What changes to normal work practices will be implemented when the heat index reaches 80 degrees F, when Heat Alerts are announced by the National Weather Service, or when Heat Waves are predicted by the local weatherman? Your written program outlining these practices must include (in this order):

• Engineering Controls – minimizing/insulating equipment heat sources, providing shade (umbrellas, canopies or temporary tents), cooling structures, providing shaded rest areas with cool water stations.
• Administrative Controls – as the heat index rises, the work/rest ratio must also be adjusted; train on how to recognize signs of heat stress in yourself or your co-worked (consider the “buddy system”) and when/where /how to take rest breaks and stay hydrated.
• Heat-reducing PPE – consider cooling vests, lighter work attire options, and/or absorptive cooling PPE.

Written Plans should also include:

• Risk Assessment
• How did you assess temperatures and work exertion?
• How do you measure and record the heat data?
• Action items for various levels of heat, i.e.  Caution (less than 80), Warning (80-94), Danger (95+)
• Specifics on the heat related hazards in your environment.
• For indoors, Maps and Signs of high heat zone areas.
• Scific task(s) that are known to cause heat stress.
• Need to be periodically updated or when a change in processes can increase risk.

As a final checklist, don’t forget the five specific things the EPA Auditor is looking for:

• Are adequate water sources readily available?
• Are sufficient rest periods provided?
• Is an adequate shade or cooler rest area available?
• Have acclimatization procedure been used for new or returning employees?
• Has appropriate heat stress avoidance training been conducted?

So, once you get that impressive Written Heat Stress Program, remember to train…train…train!