(Source: Jackson Lewis California Workplace Law Blog by Joshua M. Henderson & Sean Paisan – June 28, 2023)
As Summer starts to heat up, employers with outdoor worksites should review their Heat Illness Prevention Plan (HIPP) compliance under Cal/OSHA’s outdoor heat illness prevention standard.
Which Employers Are Covered?
The standard applies to any employee working outside and this may include positions that are not solely outside.
Obligations for Covered Employers
Covered employers must take the following steps to prevent heat illness in the workplace:
- Train employees and supervisors in heat illness prevention.
- Provide enough “fresh, pure, and suitably cool” water so that each employee can drink at least one quart per hour and encourage them to do so.
- Ensure timely access to shade when the temperature exceeds 85 degrees Fahrenheit and otherwise upon an employee’s request.
- Encourage employees to take a preventative cool-down rest in the shade when they feel the need, in order to protect themselves from overheating at all times.
- Implement effective emergency response procedures related to heat illness.
- Closely observe employees who have been newly assigned to a high-heat area for the first 14 days of employment, and all employees during heat waves.
- Develop and implement a written Heat Illness Prevention Plan.
Additional High Heat Procedures
Certain industries must comply with additional high-heat illness prevention procedures when the temperature equals or exceeds 95 degrees Fahrenheit. These industries include:
- Agriculture
- Construction
- Landscaping
- Oil and gas extraction
- Transportation and delivery of agricultural products, construction, or other heavy materials, except for employment that consists of operating an air-conditioned vehicle and does not include loading or unloading.
High heat procedures include ensuring employees are observed regularly for signs of heat illness, and establishing effective communication methods so workers can contact a supervisor when needed.
Written HIPP
All covered employers must have a written HIPP, which is generally recommended to be a stand-alone document. Cal/OSHA has an e-tool to assist with developing a HIPP on its website.
Inside Heat
Summertime can also mean hotter temperatures inside, and while the official Indoor Heat Standard is still in the works, employers should still evaluate and address heat hazards indoors. Cal/OSHA has begun citing employers for indoor heat under Section 3203. For details on indoor heat illness and related regulations, read Cal-OSHA Reporter’s “Indoor Heat Regulations, Explained”.
Our workplace safety, labor law, and human resource experts here at CalWorkSafety & HR can help your organization with heat injury prevention to ensure compliance – contact us today.