Responding to Occupational Heat Stress
It’s sweltering outside, which makes this the perfect time to talk about occupational exposure to heat stress. The numbers are staggering: each year, thousands of workers suffer from occupational exposure to heat stress, in some cases leading to death. This is a preventable workplace risk, but OSHA does not have a standard that specifically addresses heat stress. In the absence of federal leadership, some states have taken action.
Recently, the Virginia Department of Labor and Industry released a proposal to craft a standard on occupational exposure to excessive heat at indoor and outdoor workplaces. According to the Department’s background document (PDF), a new standard is needed because
[e]xcessive heat exposure poses a direct threat to Virginia’s employees, employers, and its economy. Working in excessive heat can result in employees suffering diminished mental acuity and physical ability, which increases the risk of accidents and even death. Heat-related injuries and illnesses increase workers’ compensation costs and medical expenses, and decrease productivity.
AIHA recently submitted comments (PDF) to the Department strongly supporting the proposal. In our comments, we recommend that the following components be detailed in the standard:
- references to established and recognized alert/exposure limits
- provisions for personal protective equipment, rest, water, and shade
- references to surveillance and medical testing
- administrative controls such as training and the posting of heat stress warning notices
- provisions for whistleblower protections
Virginia’s Department of Labor and Industry explains that in crafting such a standard, it will look to other states that have already adopted standards on occupational heat exposure, such as California, Minnesota, and Washington. The Department will also take into consideration NIOSH’s “Criteria for a Recommended Standard: Occupational Exposure to Heat and Hot Environments” (PDF), a 192-page document published in 2016.
While consensus is rarely universal, at this point in the rulemaking process, the vast majority of comments submitted (including AIHA’s) support Virginia’s proposal to draft a heat stress standard. The next step is for the Department to review the comments and appoint a Regulatory Advisory Panel (RAP), which will comprise approximately 20 public and private sector representatives and assist in drafting the standard. AIHA, which is headquartered in Virginia and represents more than 200 occupational and environmental health and safety professionals in the Commonwealth, has requested a seat on the RAP. When the standard has been drafted, there will be a 60-day comment period, an economic analysis, and likely a public hearing. Additional information, including a summary of issues that led to and may be addressed by a new standard, can be found in the background document (PDF).
While we wait for Virginia to take further action, some are calling for a new drive to petition OSHA to issue a heat stress standard. The argument is that the Biden Administration may be more favorable to issuing such a standard, in part because of President Biden’s focus on infrastructure and the connections between infrastructure, construction, and heat stress (for additional information, see AIHA’s "Focus Four for Health" guidance document). OSHA was petitioned in 2011 and 2018 to issue a standard on heat stress, but chose instead to emphasize its educational outreach activities to businesses and workers. Advocates of a new heat stress standard are hoping that soaring temperatures, connections to high profile priorities such as infrastructure, and a patchwork of state regulations may mean that a new OSHA standard could soon be on the horizon.
Heat Stress and the Selection and Use of Personal Protective Clothing and Equipment
One critical factor is the selection and use of personal protective clothing and equipment when considering a model for heat stress. Firefighters wear bunker gear and SCBAs when fighting structural fires. Baseball officials wear protective equipment while officiating multiple summertime games. Other construction and agricultural workers wear other types of protective gear while performing their jobs. Depending on the layers and the material type of personal protective clothing, these extra layers and thickness can increase the thermal load and the core body temperature over time. Some heat stress calculations estimate the core body temperature can rise up to 11 degrees above ambient WBGT environmental levels. This consideration should be evaluated by qualified OEHS professionals to ensure the ACGIH and other guidance levels are not exceeded. In short, a moderate risk based solely on WBGT indicators can make the risk unacceptable when wearing these layers of protective clothing and equipment.By Bernard Fontaine, Jr., CIH, CSP, FAIHA on June 28, 2021 5:05pm