June 14, 2023
As summer approaches, and temperatures in Maryland and across the country begin to skyrocket, are you considering additional precautions for your employees to protect them from heat-related injuries and illnesses?
The Occupational Safety and Health Administration (OSHA) covers most private sector employers and their workers in all 50 states, the District of Columbia, and other U.S. jurisdictions. OSHA, which oversees the enforcement of the OSH Act of 1970, requires employers to comply with hazard-specific safety and health standards. Although the Biden Administration, upon assuming power, stated that one of its goals was to develop a regulation specifically concerning heat-related hazards, experts speculate that the implementation of such a rule is still many years away.
However, the OSH Act also contains a “general duty” clause, whereby employers must provide employees with a workplace free from recognized hazards likely to cause death or serious physical harm. This would include protecting workers from heat-related hazards.
There are three types of controls that OSHA requires employers to consider in mitigating a hazard – in this case, extreme heat.
- Engineering controls, or those that engineer a hazard out by design specifications or applying substitute methods, are to be considered first. Engineering controls that can be utilized to combat heat-related hazards include air treatment, air cooling, or heat conduction blocking.
- Administrative controls, which reduce employee exposure to the hazard through methods such as education, training, etc., are to be considered second, as they depend on constant human implementation. Still, administrative controls can be extremely effective in combating the dangers of overheating, including acclimatizing workers to work in a hot environment for progressively longer periods (3/4 of all heat-related workplace deaths occur in an individual’s first week of employment), reducing physical demands, providing recovery areas, ensuring workers take routine water breaks, and rescheduling hot jobs for a cooler part of the day.
- Personal Protective Equipment is the final control, worn by employees to protect themselves from the hazard. Heat-related PPE includes reflective clothing, wetted clothing, water-cooled garments, and auxiliary body cooling vests.
Any employer with workers exposed to high temperatures should develop a heat illness prevention program. The summer heat affects workers in many industries – both outdoors (agriculture, construction, landscaping, delivery, oil rigs) and indoors (restaurants, electrical utilities, mills and foundries, manufacturing, warehousing). The language of your heat illness prevention program, including which engineering, administrative, or PPE controls are to be utilized, will depend on your industry.
Of course, beyond your requirements under the OSH Act, ensuring your employees’ safety is simply the right thing to do. We hope the simple steps outlined above lead to a productive, happy, and safe summer season for you, your company, and your employees.