b'OSHA Heat Illness Prevention Standardpurposes of the standard. Each time you have a heat-related illness or injury that results in death, days away from work, medical treatment beyond OSHA is ahead of schedule, for a change. Whilefirst aid, or loss of consciousness, you must review and evaluate acting Secretary of Labor Su stated about forty-five days agothe effectiveness of your HIIPP. If none of these occur, you must that OSHA would be issuing a proposed rule for heat illnessevaluate it annually. prevention in October 2024, OSHA released the new standard on July 2, 2024. The indication is that this proposedWhen engaged in outdoor work, the employer must rule will become a final rule and that it will be enforceablemonitor the heat index with sufficient frequency to determine with sixty days after it is published in the Federal Register. Thatreasonable accuracy your employees exposure to heat. In publication has not yet been made. As soon as the proposedconnection with this, you must monitor heat conditions at outdoor rule is published, we will advise our members. As indicated,work areas by tracking the local heat index forecasts. I found it the standard will become enforceable within sixty days ofinteresting that the new standard does not suggest using the OSHA that publication date however, that time may be extended ifHeat Tool App to perform this task. challenges to the new standard are filed.For indoor work, the employer must identify each work The new proposed standard will be numberedarea where there is a reasonable expectation that employees are or 1910.148. While this is a general industry standard, it willmay be exposed to heat at or above the initial heat trigger (80F). also impact the construction industry as stated in proposedThe standard also indicates that for indoor work, this information standard 1926.67. Standard 1926.67 states that thewill need to be updated anytime there is a change in production, requirements for heat illness prevention applicable toprocesses, equipment, or a substantial increase in outdoor construction under that section are identical to thetemperature which has the potential to increase the heat exposure requirements of 29 CFR 1910.148. The proposed rule appearsindoors. to follow the five steps in the NIOSH Criteria Document. As with outdoor workers, employers must seek input and The Proposed Rule (PR) addresses two triggerinvolvement of non-managerial employees and their points. An initial heat trigger is identified as a heat index ofrepresentatives, if any, when evaluating the work site to identify 80F while a high heat trigger means a heat index of 90F.work areas with a reasonable expectation of exposures at or above The standard also defines heat index as combining thethe initial heat trigger. While the standard does not specifically ambient temperature and humidity. As I have already stated,require documentation, I strongly suggest that you do document (1) the standard for the construction industry is the same as thewhen you sought input and involvement from non-managerial standard for general industry.employees; (2) who you sought for that input and their response; and (3) if you did not use the input you received, why you did not All employers with more than ten (10) employeesimplement that input. are required to have a Heat Injury and Illness Prevention Plan (HIIPP) in writing. 29 CFR 1919.148 requires that the planNext the standard discusses the requirements the must contain a comprehensive list of the types of workemployer has under the standard to its employees for both the covered by the plan. For construction this includes all fieldinitial and high heat triggers. When working outdoors, employers employees, unless they work in an air-conditioned office. Inare required to monitor the heat conditions at the work site. This addition, the plan for an employer must include the heatcan be accomplished by tracking the National Weather Service index or the wet bulb temperature it will monitor to comply(NWS) or other reputable sources. From here, you need to with the standard.determine the heat index at the site. And, you are expected to monitor the heat index with sufficient frequency to determine with In addition to the preceding, all employers will havereasonable accuracy employees exposure to heat. to designate one or more heat safety coordinators to implement and monitor the HIIPP. These individuals willIndoor work areas have much the same requirements. The have to be documented in any HIIPP. They must have theemployer for employees working indoors must identify each work authority to ensure compliance with all aspects of the HIIPP.area where there is a reasonable expectation that employees will In addition to the preceding, the employer must seek thebe exposed to heat at or above the initial heat trigger. This section input and involvement of non-managerial employees andalso requires the employer to reassess whenever there is a change their representatives, if any, in the development andin production, equipment, controls, or a substantial increase in implementation of the HIIPP. Both of these requirementsoutdoor temperature, which has the potential to increase heat have not appeared before now in the enforcement of heatexposure indoors. illness protections under the General Duty Clause. You mustIn this standard there is a section which removes the make the HIIPP readily available at the work site to allobligation for heat testing under certain conditions. This section employees working at the site and the plan must be availablestates that you, the employer, can assume that the temperature at in a language each employee, supervisor, and heat safetythe work area is at or above both the initial heat and high heat coordinator understands.As I reviewed these requirements ittriggers and implement the steps for the high heat trigger without became apparent that each HIIPP must be site specific.repeating steps to determine the necessary protection for your At least twice in the PR, OSHA states that theemployees. Basically, it appears that if you assume that your employer must identify the heat metric that it will monitor toemployees are exposed to high heat and you protect them comply with the identification of heat hazards. The heataccordingly, you can be excused from all monitoring requirements metric may be either the heat index or the wet bulb globein the standard. This gives you relief you do not get in other temperature. When addressing this in outdoor work, it statesstandards, such as working with air contaminants, etc.that this will be used to determine the appropriate heatThe standard sets out several requirements for employers trigger. But when the heat metric is discussed with regard towhen the measurements are above the initial heat trigger. First, the indoor work, the implication is that the heat metric chosenemployer must provide access to potable water for drinking. This is will determine the applicable initial and high heat triggers for (continued to page20) 8'