b'YOUR TOOLKIT FOR BUILDING EXCELLENCEfor the construction industry is the same as theapplicable initial and high heat triggers for standard for general industry. purposes of the standard.All employers with more than ten (10)Each time you have a heat-related illness employees are required to have a Heat Injury andor injury that results in death, days away from Illness Prevention Plan (HIIPP) in writing. 29work, medical treatment beyond first aid, or loss CFR 1919.148 requires that the plan must containof consciousness, you must review and evaluate a comprehensive list of the types of work coveredthe effectiveness of your HIIPP. If none of these by the plan. For construction this includes all fieldoccur, you must evaluate it annually.employees, unless they work in an air-conditionedWhen engaged in outdoor work, the office. In addition, the plan for an employer mustemployer must monitor the heat index with include the heat index or the wet bulb temperaturesufficient frequency to determine with reasonable it will monitor to comply with the standard. accuracy your employees exposure to heat. In In addition to the preceding, all employersconnection with this, you must monitor heat will have to designate one or more heat safetyconditions at outdoor work areas by tracking the coordinators to implement and monitor the HIIPP.local heat index forecasts. I found it interesting These individuals will have to be documentedthat the new standard does not suggest using the in any HIIPP. They must have the authority toOSHA Heat Tool App to perform this task.ensure compliance with all aspects of the HIIPP.For indoor work, the employer must In addition to the preceding, the employer mustidentify each work area where there is a reasonable seek the input and involvement of non-managerialexpectation that employees are or may be exposed employees and their representatives, if any, in theto heat at or above the initial heat trigger (80F). development and implementation of the HIIPP.The standard also indicates that for indoor Both of these requirements have not appearedwork, this information will need to be updated before now in the enforcement of heat illnessanytime there is a change in production, processes, protections under the General Duty Clause.equipment, or a substantial increase in outdoor You must make the HIIPP readily available attemperature which has the potential to increase the work site to all employees working at the sitethe heat exposure indoors.and the plan must be available in a language each employee, supervisor, and heat safety coordinatorAs with outdoor workers, employers must understands.As I reviewed these requirementsseek input and involvement of non-managerial it became apparent that each HIIPP must be siteemployees and their representatives, if any, when specific. evaluating the work site to identify work areas At least twice in the PR, OSHA states thatwith a reasonable expectation of exposures at or the employer must identify the heat metric that itabove the initial heat trigger. While the standard will monitor to comply with the identification ofdoes not specifically require documentation, I heat hazards. The heat metric may be either thestrongly suggest that you do document (1) when heat index or the wet bulb globe temperature.you sought input and involvement from non-When addressing this in outdoor work, it statesmanagerial employees; (2) who you sought for that this will be used to determine the appropriatethat input and their response; and (3) if you did heat trigger. But when the heat metric is discussednot use the input you received, why you did not with regard to indoor work, the implication isimplement that input.that the heat metric chosen will determine theNextthestandarddiscussesthe continued on page: 30 FRAME BUILDER - VOL5 3 / 29'