b'YOUR TOOLKIT FOR BUILDING EXCELLENCEHEAT ILLNESS PREVENTIONWe are well into the summer high heat season. It appears that, in many parts of the United States, temperatures are again setting record highs and for longer durations. Last year, in 2021, reminded everyone about the unusually high temperatures in the Pacific Northwest and the high number of fatalities associated with those high temperatures.BY Gary AumanNFBA Legal CounselA s we learned last year, high temperaturesnow have a heat illness prevention are not limited to just one area of theNEP,OSHAcanstillconduct country.So,whatdoesthismeancompliance inspections in the for you as an employer? Whether you are incaseofanOSHAreportable construction or general industry, unusuallyillness, injury, or employee complaint. high temperatures will impact you, unless youOSHAbeganitsenforcementeffortsin operate an air-conditioned manufacturing, or2012. On July 19, 2012 OSHA published a warehouse, facility. My goal for all of my tradememorandum with a directive to expedite associationclientsistokeepourmembersheat related inspections. It identified its goal apprised about significant hazards that maythe swift abatement and reduction of heat confront their employees, and to remind themrelated illnesses and death. This was ten years of their obligations to those employees. Everybefore OSHA declared the NEP for heat illness employer should have as its number one goal,prevention. At that time, compliance officers the safety of its workforce.were directed to consider whether the employer This year, in 2022, OSHA has taken two bigwas employing feasible and useful methods to steps directed at heat illness prevention. Thecorrect the hazard. These were identified as first step was to announce that OSHA willproviding immediate access to water, rest and be proposing a new specific standard in bothshade (something OSHA still emphasizes now generalindustryandconstructiontosetin 2022), have an acclimatization program, specific standards for employers in both ofimplement a work/rest schedule, and provide those industrial sectors. It is too early in theclimate-controlled cool down areas. rule making process to predict how OSHANow that we have the NEP, OSHA has added will actually move on these standards. But thesome additional points for compliance officers second action by OSHA is well underway, andto look for when inspecting an employer under that is to declare a National Emphasis Programthe NEP. They are:(NEP) for heat illness prevention. In doing this, OSHA has created probable cause to conduct1. the employer have administrative Does inspections in high hazard industries for heatcontrols in place?illness. Just about every type of construction is2. Is the employer using a buddy system?on that list and OSHA will provide guidelines 3. Do workers have access to cool water?for compliance officers conducting the NEP inspections. Remember that, even though we4. Does the employer require hydration breakscontinued on page: 26 FRAME BUILDER - AUG2022 / 25'