After many months of deliberating and some unforeseen drama with the Cal/OSHA Standards Board, the Indoor Heat Illness Prevention Regulation is finally in effect! Employers who may be affected may include warehouses, distribution centers, restaurants, manufacturing plants, or similar indoor work environments where temperatures cannot be lowered to specific temperatures. These employers will be required to implement new controls to protect their employees from this new regulated hazard.
Title 8 Section 3396 Requirements
Cal/OSHA’s new Indoor Heat Illness Prevention regulation does have similar requirements to the Outdoor Heat Illness regulation but with some important differences. Trigger temperatures will include at least one of the following conditions:
- The temperature equals or exceeds 82 degrees Fahrenheit when employees are present;
- Temperature equals or exceeds 82 degrees Fahrenheit while employees are wearing clothing that restricts heat removal;
- Temperature equals or exceeds 82 degrees Fahrenheit while employees work in a high radiant heat area;
- The temperature equals or exceeds 87 degrees Fahrenheit when employees are present;
- The heat index equals or exceeds 87 degrees Fahrenheit when employees are present;
If any one of these trigger temperatures are met for an indoor work environment, employers will need to protect their employees from heat illness through engineering controls, administrative controls, access to water, temperature monitoring, implementing a cool-down rest area, employee training, and a written Indoor Heat Illness Prevention Plan.
Monitoring, Assessments, and Cool-Down Rest Areas
If one or more of the temperature triggers have been met, employers are required to measure the temperature and heat index and record whichever is greater. Records of these temperatures must be established and maintain accurate records of the temperature or heat index measurements, including the date, time, and specific location of all measurements.
If an employee is observing heat illness symptoms, employers are now required to implement a cool-down rest area that is cooler than 82 degrees for employees to sit down and recover. Examples of cool-down rest areas could include break rooms, conference rooms, or anywhere else indoors where the temperature is less than the immediate work area and can provide relief to enough employees.
It is also important to implement monitoring procedures for employees who may be affected by heat illness and emergency response procedures if medical assistance is necessary. This requirement is similar to the Outdoor Heat Illness regulation.
Access to Water
Potable water that is fresh, suitably cool, and free of charge should also be available to employees within a reasonable distance from their work area. Examples of accessible water sources could include water bottles, plumbed faucets, or water dispensers that can be replenished to provide at least 1 quart per hour per employee. This is another similar requirement from the Outdoor Heat Illness regulation.
Controls
One of the most crucial elements in this new regulation is controlling the hazard for employees. Companies can achieve this through engineering controls and/or administrative controls. The following are some examples of these two controls that employers may consider:
Engineering Controls:
- Fans
- Swamp coolers
- Misters
- Improve HVAC system
- Isolation of heat exposure to employees
Administrative Controls:
- Acclimatizing employees
- Rotating employees
- Scheduling work earlier or later in the day
- Increased rest/break periods in cool-down rest areas
- Reducing work intensity/speed
Written Plan & Training
These new requirements for the Indoor Heat Illness Prevention regulation will need to be in a written plan where it is accessible to employees. Elements to consider including in the written plan are:
- Responsibility
- Access to Water
- Cool-Down Rest Area
- Acclimatization
- Controls – Engineering & Administrative
- Emergency Response Procedures
- Signs & Symptoms of Heat Illnesses
- Employee & Supervisory Training
Any affected employees are required to be trained on this written plan before being exposed to any indoor heat hazard. Supervisors/Management level training on what their specific responsibilities when it comes to this plan should be covered as well.
