Larry Rockefeller, CIH, CSP
Director, Health & Safety Services

Sydney Harris, MS
Industrial Hygienist

Even though it is a New Year and we are in the middle of winter, there is no time like the present to prepare for the inevitable hotter months to come, as well as potential heat-related illnesses that impact your workforce.  Many of you may be unaware that last April, OSHA added Outdoor and Indoor Heat-Related Hazards to its National Emphasis Program (NEP). This pioneering effort reinforces OSHA’s advanced notice of proposed rulemaking issued in October 2021 which marks the development of a standard that protects indoor and outdoor workers from hazardous heat. While most of us remain bundled up in our winter coats, employers can start acting now to ensure controls are in place for employees during the summer heat as well as remain prepared for OSHA heat-related inspections.

Employers reading this may be wondering “Am I a high-hazard industry affected by this?” Despite NEPs typically targeting high-risk and high-hazard industries, the NEP on Outdoor and Indoor Heat Hazards expands its reach and initiates inspections into not only heat-related fatalities/catastrophes, but also into complaints and referrals regardless of whether the worksite falls within a NEP-targeted industry. Pre-planned inspections can be expected in high-risk industries on any day a heat warning or advisory has been issued for the local area. Heat priority days, defined by the NEP as a heat index of 80 °F or higher, will also trigger OSHA inspection and initiation of compliance assistance.

At this point, you may be wondering what to expect during an inspection and how you can prepare for one. During OSHA inspections, a review of the employer’s OSHA 300 log and subsequent injury-related documentation will occur to identify prior heat-related illnesses, occurring over the most recent 3 years.  During the walkaround inspection, the OSHA inspector will evaluate the facility and operation characteristics, potential sources of heat, and control measures (engineering, administrative, and personal protection) that exist to reduce heat stress.  The inspector will also collect measurements and document per OSHA’s Technical Manual (OTM) for Heat Stress.  A review of the Heat Stress Prevention Program will also be conducted. 

How Can We Help?
With 18 of the last 19 summers being the hottest on record and the increase in extreme heat each year, employers should take heed and start preparing themselves for what lies ahead in the realm of heat-related injury prevention and enforcement. The EI Group is available to assist your site by drafting a heat stress prevention program, reviewing one that you already have in place, provide heat stress/strain monitoring, and more. If you have questions or concerns regarding heat stress, please contact Larry Rockefeller, CIH, CSP at (919) 459-5257 or [email protected] or Sydney Harris, MS at (919) 459-5259 or [email protected].