January 25, 2022 / Mark Ames

Help Us Translate Technical Expertise into Public Policy Recommendations

For more than a decade, people have been seeking action from OSHA on heat stress. In 2011, Public Citizen, a nonprofit advocacy group, filed a petition urging OSHA to issue and implement an emergency temporary standard (ETS) to help protect more workers from occupational exposure to heat illnesses and injuries. In denying the petition, OSHA stated that heat stress was not considered a “grave danger,” which is a requirement for issuing an ETS. Public Citizen tried twice more in 2018 and 2021 to get OSHA to issue a new standard. During that time, several members of Congress also sent messages to OSHA urging a new standard to be issued. Recently, the U.S. House Appropriations Committee included the following message to the U.S. Department of Labor in the report (PDF) accompanying the Fiscal Year 2022 Labor, Health and Human Services, Education, and Related Agencies Appropriations Bill, which funds OSHA:

The Committee recognizes the urgency of developing a workplace safety standard to protect workers from excessive heat, and is aware that a standard has already proven to be feasible to implement, and in light of rising temperatures urges OSHA to take all necessary steps to issue a proposed occupational heat stress protection standard by the end of fiscal year 2022. The Secretary is directed to submit a schedule to the Committee within 90 days of enactment of this Act on the action steps it will be taking to promulgate an occupational heat stress protection standard.

On Oct. 27, 2021, two months after that report language was published, OSHA took a step toward issuing a new heat stress standard, releasing an advance notice of proposed rulemaking (ANPRM) on heat injury and illness prevention in outdoor and indoor work settings. The ANPRM contained 114 questions on which the agency sought feedback.

Recently, AIHA submitted comments (PDF) on the ANPRM, stating, “AIHA believes that heat is a serious occupational hazard often not adequately controlled, and thus a standard to provide employers and employees with guidance on acceptable exposures and controls is warranted.” Our comments span 22 pages, addressing cold stress hazards, the interplay between public health and OEHS, acclimatization, under-reporting of heat-related injuries, illnesses, and fatalities, specific populations that may face disproportionate exposure to occupational heat stress, and more.

Going forward, OSHA has indicated that it intends to take action on the following issues:

  • infectious diseases
  • workplace violence prevention
  • respirable crystalline silica
  • safety in mine operations
  • heat injury and illness prevention

In addition to federal regulatory activity, while members of Congress continue debating federal funding, infrastructure, and other issues, state legislators are taking action.

Most state legislatures are now in session, and bills have already been introduced on heat stress, mold, safe patient handling, and more. AIHA is continuing to respond to these actions while encouraging policymakers to support our public policy priorities (PDF), which include hearing conservation, thermal stress, infectious diseases, professional title protection, indoor environmental quality, and the OEHS professional pipeline.

If you have an interest in public policy and would like to help shape the laws and regulations that directly impact OEHS on a large scale, we’d love to hear from you. Please take a moment to complete a short survey, which will let us know how you’d like to be involved. Currently, there are three levels of involvement:

  1. Join AIHA’s Government Relations Committee, where you’ll be among the first to hear about key OEHS government relations developments.
  2. Join AIHA’s informal Technical Advisory Group, which sits under the Government Relations Committee and whose purpose is to provide expert feedback on legislation, regulations, and other government actions in consultation with AIHA’s director of Government Relations, CIH staff lead, and Government Relations Committee officers.
  3. Join temporary teams that meet with, and help author AIHA’s comments to, government agencies and legislators.

Thanks so much to all the volunteers who’ve helped AIHA author content and meet with policymakers! We have many more opportunities to get involved; I hope you can join us. Together, we’re translating technical expertise into public policy recommendations and helping create, as described in our vision statement, “a world where all workers and their communities are healthy and safe​.”

Mark Ames

Mark Ames is AIHA’s director of Government Relations.


There are no submissions.

Add a Comment