Final Draft of Cal/OSHA Indoor Heat Illness Standard Released
By: Faith L. Driscoll
The
Division of Occupational Safety and Health has issued its latest – and final – draft
of proposed new standards for heat illness prevention in indoor workplaces. This standard would apply to workplaces when
the indoor temperature reaches 82 degrees in work areas. Additionally, assessment and control measures
must be taken in the following situations: when the temperature reaches 87 degrees,
the heat index reaches 87 degrees, employees wear clothing that restricts heat
removal, or employees work in high-radiant-heat areas. Employers will be required to provide water
on the same basis as outdoor workplaces.
This
draft revises the definition of a “cool-down area” as an indoor or outdoor area
that is blocked from sunlight and shielded from high-radiant-heat sources, that
is either open to the air or ventilated or cooled. It adds that blockage will be considered
sufficient when “objects do not cast a shadow in the area of blocked sunlight.”
In
the assessment and control section, DOSH added an exception to a requirement
that employers measure and record the temperature or heat index, whichever is
greater, and identify/evaluate all environmental risk factors for heat
illness. The exception gives employers
the option of assuming a work area is subject to the need for controlling the
temperature, thus forgoing the requirement to assess and record specific
heat-related information.
Employers
will also be required to use control measures to minimize the risk of heat
illness, including isolation of thermal processes, isolating employees from
heat sources, using air conditioning, cooling fans, cooling mist fans, and
natural ventilation if the outdoor temperature is lower than inside. Finally,
the draft standards will require supervisors to closely observe workers during
heat waves, which are defined as any day when the predicted high outdoor
temperature will be at least 80 degrees and at least 10 degrees warmer than the
daily temperature during the preceding five days.
To view the draft standard in its entirety, please visit:
https://www.cal-osha.com/wp-content/uploads/2019/05/Indoor-Heat-Draft-revisions-Apr-22-2019.pdf
DOSH does not anticipate making any further changes before the draft is assessed for economic impact and then sent to the Standards Board for the formal rulemaking process.
What This Means for Employers
Now is the time to begin evaluating the workplace to determine how these proposed standards will impact the workplace. Preparing in advance is critical to ensure proper compliance with these detailed requirements. As soon as the regulations are implemented, Cal/OSHA inspections will likely target agricultural employers, as well as construction, manufacturing and industrial kitchens and laundries. Contact Barsamian & Moody for help in drafting compliant policies and procedures to prevent violations and expensive penalties.
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The goal of this article is to provide employers with current labor and employment law information. The contents should neither be interpreted as, nor construed as legal advice or opinion. The reader should consult with Barsamian & Moody at (559) 248-2360, for individual responses to questions or concerns regarding any given situation.