Heat Stress Prevention
On July 2, 2024, the Occupational Safety and Health Administration (“OSHA”) proposed a rule for Heat Injury and Illness Prevention. The proposal is not yet finalized but OSHA remains active in regulating heat hazards via the general duty clause. The summer months are always a good time to review your policies regarding heat-related risks.
Employers should prioritize heat stress prevention training and implement a heat-related illness prevention program. Prevention of heat-related illness and fatality is most effectively done through reduction of heat stress in the workplace. Remember this applies to employees working both indoors and outdoors in the heat. OSHA recommends employers utilize wet bulb globe temperature (WBGT) monitors to measure each heat factor in a workspace: temperature, humidity, sunlight, and wind. Heat index may not be a sufficient method of determining heat stress risk since it cannot consider these other factors, nor the conditions of an indoor workspace. Specifically, relying on heat index alone will likely result in an underestimation of risk, and limit an employer’s ability to adequately prevent and address heat stress risk.
Other factors to be considered in calculating heat stress risk include level of physical activity, clothing and PPE, and individual risk factors. Employees tasked with more intense labor, which require greater exertion, are at a higher risk for heat stress and related conditions. In determining what methods of prevention to employ, PPE must be considered since it has a likelihood of trapping heat and contributing to an employee’s risk. OSHA recommends that those with higher workloads be afforded frequent breaks, or scheduled work throughout the cooler parts of the day. When in doubt, consult with a qualified occupational safety and health professional to determine the safest course of action.
Employers should implement policies to prevent heat stress, such as acclimatization over a 1-2 week period for “workers who are new to working in warm environments.” This includes new employees, employees returning to work after a weeklong absence, employees working through seasonal changes, and employees who work during a heat wave. Employers should ensure that procedures are in place to provide employees with fluids and rest breaks, preferably in shade, when heat stress risk is high.
Employers should enforce training procedures to ensure supervisors are aware of the signs and symptoms of heat stress and its related conditions. A supervisor on-site with the employees should be trained in recognizing early signs and symptoms of heat stress and administering the appropriate first aid for related illnesses.
OSHA Hazard Communication Requirements
The Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HazCom), 29 C.F.R. § 1910.1200, is one of the most frequently cited OSHA standards. To comply with the standard, employers must ensure proper labeling on chemical containers, provide Safety Data Sheets (SDSs) and provision information to employees, ensure proper training on chemical hazards in the workplace, and develop and maintain a written Hazard Communication Program. Because cleaning chemicals are considered a hazardous chemical, most workplaces are subject to this standard.
The Hazard Communication Program should describe procedures for labeling hazardous chemicals, maintaining and accessing SDSs, training and informing employees, addressing non-routine tasks involving hazardous chemicals, and notifying outside contractors of such hazard if applicable. The written program should be reviewed periodically and updated whenever new chemicals or processes are introduced.
SDSs provide detailed information about chemical hazards, safe handling procedures, personal protective equipment (PPE), first aid measures, spill response procedures, storage requirements, and fire-fighting information. Employees must have immediate access to SDSs during every work shift. Electronic systems are acceptable if employees can access them without delay during emergencies.
Regular inspections can identify chemicals that are no longer in use or products that have been introduced without being added to the inventory.
Every container of a hazardous chemical must be properly labeled. Manufacturer labels generally include a product identifier, a signal word (“Danger” or “Warning”), hazard statements, precautionary statements, pictograms, and supplier identification. If chemicals are transferred to secondary containers, employers must ensure those containers are also appropriately labeled unless the chemical will be used immediately by the employee who performed the transfer. Missing or damaged labels should be replaced promptly.
Employees should receive training at the time of initial assignment and whenever a new chemical hazard is introduced into their work area. Training should include education on the requirements of the Hazard Communication Standard, location of the written program, how to read labels and pictograms, how to interpret SDSs, physical and health hazards of workplace chemicals, protective measures employees should take, emergency procedures and spill response, and proper use of personal protective equipment.
Hazard communication is an ongoing process, not a one-time compliance exercise.
OSHA Training Seminar
The OSHA Training Institute (“OTI”) will be offering a virtual training event available to federal agencies and their employees from August 4-6, 2026. The training will educate on topics such as fall protection, heat stress prevention, respiratory protection programs, OSHA inspection procedures, and ergonomics, among others. OTI regularly offers courses at various training centers. Stay up to date with upcoming training events here.