In the Dog Days of Summer – Guard Against Heat Stress
Recently, OSHA announced a new proposed rule to address heat stress at work. It is important for employers to recognize that the current lack of an OSHA standard directly addressing heat stress does not mean there is no duty of care to protect employees and prevent heat related injuries and illnesses. The General Duty Clause currently is applied to enforcement efforts relating to work related heat illness and injury hazards. Further, if an employee is hospitalized due to heat stress, it is reportable to OSHA, as is any other workplace related hospitalization, and will likely result in a visit by your local OSHA enforcement agency. (See 29 CFR 1904.39(a)(3))
So, what should employers be doing to protect employees form heat related injuries and illnesses?
1) Identify and Evaluate the Risks
NIOSH has published “Criteria for a Recommended Standard: Occupation Exposure to Heat and Hot Work Environments”, from which the proposed OSHA standard borrows heavily. OSHA states:
“Occupational risk factors include both the work environment and the work you are doing. The temperature, humidity, length of time close to heat sources, and direct sunlight are all factors to pay attention to in the work environment. In addition, the physical exertion or workload required for your job, being unaccustomed to or not used to working in the heat, and the clothing or protective equipment you wear can contribute to your risk for heat illness.”
When evaluating your workplace for heat stress risks, consider exposure to the sun (outdoor work) or other radiant heat sources, level of exertion, air temperature, and humidity. Equipment such as ovens and furnaces, or exothermic chemical processes expose employees to higher heat stress risk as well, so the temperature of the activity location should be monitored closely. Further, activities taking place at heights, such as overhead crane work activities and those taking place in confined spaces are likely to be an increased risk. Finally, consider the effect PPE may have on the body’s ability to cool off, such as respirators, hot work protective clothing, arc flash or fire rated clothing, or chemical protective clothing.
2) Take Steps to Mitigate the Risks
Employers should take steps to mitigate the risks of heat stress to their employees including implementing one or more of the following:
· Provide hydration stations that are readily accessible throughout the workplace and encourage employees to take frequent hydration breaks
· Provide additional air movement in the work area and consider if cooling or misting fans will be beneficial
· Modify work-rest periods based on risk (i.e., more frequent and/or extended break periods and shorter intermediate work periods)
· Provide a cool and/or shaded area for breaks
· Modify work schedule to perform high risk activities during cooler periods of the day
· Monitor temperature and humidity in the workplace and adjust work schedules and break periods accordingly
· Establish a “Buddy System” to help recognize heat stress symptoms early and take action
· Encourage employees to take breaks when needed and report concerns without fear of reprisal
3) Know How to Respond
Heat stress can manifest itself in several ways:
Reat Rash exhibits itself as red clusters of small blisters that look like pimples on the skin. Constrictive clothing, dampness, and some fabrics can exacerbate the condition. Treatment involves staying cool and dry, using powder to alleviate the rash, and wearing loose, breathable clothing.
Heat Cramps tend to occur due to an electrolyte imbalance and is characterized by heavy sweating during exertion and muscle spasms or cramps. Treatment involves stopping the activity and resting in a cool location while rehydrating. Wait until cramps go away before continuing activity. If cramps last more than an hour, the employee suffers from a heart condition or is on a low sodium diet, seek medical assistance.
Heat Exhaustion is characterized by weakness, dizziness, cramps, pale, clammy, sweaty skin, disorientation, headache and faintness. Care for heat exhausting includes removing the individual from the hot environment, loosening restrictive clothing and PPE, and sipping cool water. If the individual become nauseous, vomits, loses consciousness or otherwise deteriorates, obtain medical assistance.
Heat Stroke is a life-threatening condition that requires immediate medical attention. Victims of heat stroke will exhibit high body temperature (over 105 degrees F), hot, red, dry or damp skin, fast, strong pulse, headache, dizziness, nausea, confusion, or may lose consciousness. Call 911 immediately and move the person to a cool area. Try to reduce their body temperature with the use of cool cloths or a cool bath. Do not give anything to eat or drink to a person who is losing or has lost consciousness. Prepare to give CPR if needed.
The CDC has a great resource here that can be posted in your workplace.
4) Train Employees and Supervisors
Now that you know what the hazards and risks of heat stress are, and what steps can be taken to mitigate those risks, it is important to train both employees and supervisors on the workplace plan. It is important for supervisors and employees to follow the plan and not bypass it because they think they are OK to work a little longer or because of a push to “Get-R-Done”. All employees and supervisors also need to be trained how to respond to a heat stress incident and it should be part of the workplace emergency action plan.
If an individual exhibits symptoms of heat stress, first, stop and move them out of the hot environment into a cooler area. Remove constricting PPE and loosen clothing. Provide cool water to drink, if they are fully conscious. Placing cold packs on the individual’s armpits and groin area can help reduce body temperature, as can a cool, damp washcloth placed on the individuals’ head. If the individual does not improve within a few minutes, vomits, loses consciousness, or becomes more disoriented, call 9-11 immediately.
It is important to recognize that some employees are more sensitive to heat stress illnesses, such as those wearing certain PPE, performing hot work, working at heights or near heat producing equipment and processes. Further, employees who have certain pre-existing health conditions, those taking certain medications, and those who have suffered a heat related illness in the past, are more susceptible to heat stress related injuries and illnesses. Not every employee will respond the same to a high-heat work environment due to individual differences such as health and fitness levels, hydration levels, and other personal characteristics and health habits. Further, some employees may be engaging in activities outside of work that could affect their sensitivity to heat related illnesses, such as exercise and outside work activities. Training employees how to recognize and prevent heat stress, to report symptoms immediately, and to follow safe work practices in addition to application of the above steps will help reduce the risk of a heat stress related injury or illness.