Despite a law requiring that Cal/OSHA create indoor heat illness regulations by 2019, no regulations are yet on the books, making for a difficult situation as many parts of California are experiencing some of the highest temperatures on record.
The workplace safety agency implemented heat illness prevention regulations for outdoor workers in 2013, but as the sustained heat wave leaves Northern California and the Central Valley sweltering, the problem of heat illness is affecting more and more indoor workers.
The Sacramento Bee recently reported on the issue, citing a few examples:
- Workers at a fast food establishment went on strike after the air conditioner went out, forcing them to toil in temperatures that peaked at 115 degrees.
- Many of the 400 employees working at a Southern California warehouse had to bring fans in to keep cool as temperatures in some parts of the facility reached 113 degrees, and 120 in shipping containers parked in the sun.
The problem of indoor heat illness can crop up in any indoor establishment — even an office — if the air conditioning breaks down. However, the problem is a more serious threat in:
- Warehouses
- Printing facilities
- Manufacturing operations
- Laundries
- Kitchens
- Boiler rooms
What you can do
There are a number of challenges in cooling large indoor work environments. The problem is that cool air from air conditioners will not reach all parts of a facility, particularly some nooks and corners or near machinery that kicks out heat.
There is also the cost of purchasing or upgrading air conditioning systems.
While Cal/OSHA has not yet implemented anything for indoor workers, it does have a working draft standard that includes the following highlights:
Have and maintain one or more cool-down areas at all times – A cool-down area must be large enough to accommodate the number of employees on recovery or rest periods so that they can sit in a normal posture fully in the area without having to be in physical contact with each other.
The cool-down area must be located as close as practicable to the areas where employees are working. The temperature in the indoor cool-down area must be less than 82 degrees at all times unless the employer demonstrates it is infeasible.
Employees should be allowed and encouraged to take a preventative cool-down rest in a cool-down area when they feel the need to do so to protect themselves from overheating. Such access to cool-down areas shall be permitted at all times.
Engineering controls – Employers must use engineering controls to maintain both the temperature and heat index to below 87 degrees when employees are present, and below 82 degrees where employees wear clothing that restricts heat removal or work in high radiant heat work areas.
Emergency response procedures – The employer must put in place plans for responding to a heat illness emergency, including:
- A system for effective communication by voice, observation or electronic means is maintained so that employees can contact a supervisor or emergency medical services when necessary.
- Steps to take when someone has signs or symptoms of heat illness. Depending on the symptoms, they can range from first aid measures to emergency response procedures for serious cases. That would include contacting emergency services.
Employee training – Employers must train their workers in the following:
- Environmental and personal risk factors for heat illness.
- The company’s heat illness prevention procedures and rules such as employee access to water, cool-down rests and access to first aid, as well as the employees’ right to exercise their rights without retaliation.
- The importance of frequent consumption of small quantities of water.
- How acclimatization works.
- Signs and symptoms of different stages of heat illness, and what are mild symptoms that require only rest to severe and life-threatening symptoms that require immediate emergency services.
- The importance to employees of immediately reporting to the employer signs of heat illness in themselves, or in co-workers.
- The employer’s procedures for responding to possible heat illness, including emergency medical services or transportation to a hospital, if necessary.
The takeaway
If you have workers in an indoor environment that can get hot during the summer months, in light of this summer’s intense heat in many parts of the state, take steps to protect them.
You can still be cited by Cal/OSHA for not protecting indoor workers if you have a health emergency or worker death on your hands due to heat illness.