Prepare for Impending OSHA Heat Standards

Heat is a sizable and growing threat to workers and their employers.
By Cheryl Lynn Palmer
March 14, 2022

You may be thinking: Adults know when they are hot, when to drink water and are capable of determining if they need a break from activity, such as work. So why does heat need to be regulated by OSHA? Research suggests assumptions regarding one’s ability to self-manage heat exposure may not be so simple.

Those experiencing heat stress may not feel symptoms immediately or symptoms may include impaired judgement. People willingly tolerate more extreme temperatures when under motivational conflict including physical effort or monetary reward, according to “Physiology and Behavior.“ A person experiencing impaired decision-making for either reason may mistakenly judge themselves able to safely continue an activity. If they keep working as their body temperature increases, additional symptoms arise, such as unsteadiness and cognitive impairment, which increase the likelihood of workplace injury. Additionally, employees may never have received adequate education regarding heat-related illness symptoms, which increases the likelihood of ignoring warning signs. Many employees do not report symptoms they experience, which increases their risk of serious complications or death from heat exposure.

If all that increased risk wasn’t enough, consider the rate the Earth’s temperature is rising: It has doubled each decade since 1981. If this rate continues, up to 137 million Americans will be exposed to temperatures above 90°F more than 100 days each year. Heat is known as “the silent killer,” taking more American lives than lightening, tornadoes, hurricanes and floods combined. Heat-related worker injuries and deaths go underreported for a variety of reasons, including delayed onset of heat stress and exacerbation of pre-existing conditions.

Workplace injuries increase in indoor and outdoor settings by 5% to 7% when temperatures are higher than 85°F and by 10% to 15% when temperatures are higher than 100°F, according to IZA Institute of Labor Economics. It is not a large leap to assume workplace injuries will increase as the number of hot days increases. Workplace injuries create financial burdens for companies. The average non-fatal workplace injury costs an employer $42,000 per occurrence and a death costs $1,220,000. If up to 35% of people exposed to hazardous heat experience some form of heat strain, and one common symptom impairs judgement (leading to accidents), ignoring heat risks is not financially sustainable.

The Atlantic Council predicts the United States stands to lose $100 billion due to extreme heat. The EPA cites high temperatures as causing a loss of 1.9 billion labor hours and $160 million in lost wages annually. It estimates lost labor hours of up to 6.5% per heat-exposed worker. If there are 100 days of heat above 90°F, each company will lose approximately 52 labor hours per worker per year.

Heat illness is a sneaky problem, creating economic impacts for employees, employers, and the U.S. economy. Prompt diagnosis, cooling, and supportive measures are the only way to manage heat illness. But, even with these things, long-term negative effects are still possible. Prevention of heat stress is the most effective approach to managing it. OHSA heat standards will help employers protect their human assets and reduce the economic burden of heat by preventing heat illnesses and casualties. Research shows that when workers take time to rest, hydrate and cool themselves, they are able to work for longer periods without reaching harmful core body temperatures.

Predicting How OSHA Heat Standards Will Help

There are still many things we don’t know about the upcoming OSHA heat standards, but several resources give clear insight to the situation including, the H.R.2193 Act, OSHA’s memorandum9 and ANPRM2, and the NIOSH Criteria for a Recommended Standard. H.R.2193 requires the new heat standard be no less protective than the most protective plan put in place by an individual state. Many people believe this will cause the policies to closely mimic California’s current heat regulations for workers. However, the three other states with heat standards today include details California does not. As a result, it’s likely the standards will mimic California’s structure while including a smattering of details from the other states’ heat policies. Some basic assumptions can be made regarding what will be included in upcoming federal heat standards.

1. Regulations for indoor and outdoor workplaces will likely have individualized expectations

Research indicates workplace injuries increase in all environments when outdoor temperatures soar. The ANPRM cites Tunisen et al., saying 61% of non-fatal heat illnesses occur during or after indoor work. Outdoor and indoor environments have different factors that affect workers’ heat stress, which will require some flexibility within the standards. Expect the standards to require employers to do some or all of the following:

  • Monitor current and predicted weather conditions;
  • Demonstrate awareness of necessary adjustments for microclimates (e.g., it’s hotter at urban worksites than the weather station location);
  • Consider metabolic heat production of work-related tasks; and
  • Consider effects of required personal protective equipment (PPE).

2. Training for employees and supervisors

Research indicates many individuals have not received heat training or they have misinformation regarding heat illness symptoms. The first line of defense will most likely be training for employees and supervisors that addresses some or all the following:

  • The causes of heat-related illness and risk factors;
  • Heat-related illness prevention (work/rest cycles, hydration, electrolyte consumption, diet, etc.);
  • Heat-related illness signs and symptoms;
  • Heat-related illness first aid and emergency procedures; and
  • Heat-related illness reporting.

3. Some form of mitigation requirements

Prevention is the most effective treatment for heat injury and illness. Each state with heat policies has some form of trigger that activates certain procedures. There will most likely be guidance for Recommended Work Limit (RAL) and Wet Bulb Globe Temperature (WBGT) that activates tactics in the following areas:

  • Work/rest schedules that include paid breaks;
  • Availability and amount of cool water;
  • Heat-specific first aid such as rapid-cooling methods; and
  • Medical and/or physiological monitoring program for workers.

4. Acclimatization program for new and returning workers

Acclimatization decreases the likelihood of heat-related injuries during work, although some individuals may be heat-intolerant. Anticipate being required to have an acclimatization plan that considers:

  • New workers;
  • Returning-to-work workers;
  • A trigger (RAL, WBGT, etc.); and
  • Multi-day, phased acclimatization approaches, including partial shifts and variable assignments based on metabolic heat production of work-related tasks.

5. Prioritizing individualized worker health over group monitoring

Thermoregulation is an individualized body function affected by age, sex, physical fitness and medical conditions. Adding high ambient temperatures and metabolic heat production further impacts thermoregulation. The NIOSH recommendations include individualized heat monitoring. Existing state policies attempt to prioritize individual worker health over group plans. The following individualized approaches have been suggested or currently exist:

  • Supervisors required to check in, talk to and observe individual workers regularly;
  • Mandatory buddy system, where workers watch out for each other;
  • Required medical evaluations;
  • Permission for employees to rest, seek shade and hydrate as necessary;
  • Treatment “beyond first aid” available for individuals who self identify symptoms; and
  • Documentation of symptoms.

It’s important to realize the sizable and growing threat to workers and their employers caused by rising heat and make plans now to understand and enact the impending OSHA heat standards. Your business, your employees and the nation’s economy will be healthier for it.

by Cheryl Lynn Palmer
Cheryl Lynn Palmer is customer success manager with Kenzen. She works with companies globally that use wearable technology to predict and prevent worker injuries and fatalities caused by heat.

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