How OSHA’s Emerging Investigations Guide New Safety Provisions & Standards for Heat Exposure

Heat-related illnesses and injuries are a very real concern when it comes to employee safety — but accurate accounts of them can be difficult to discern.

Knowing this, the Department of Labor’s Occupational Safety and Health Administration (OSHA) announced in October 2021 that it will increase monitoring and investigation of heat-related injuries, illnesses and deaths. In addition, OSHA also issued an Advance Notice of Proposed Rulemaking (ANPRM) for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. This notice is the first step toward establishing a federal heat standard. In conjunction with the announcements, OSHA invited employers and the public to comment and offer data and expertise on heat stress thresholds, heat acclimatization planning and exposure monitoring, among other heat-related workplace issues. OSHA received comments through January 2022 and will review them, along with other studies and data, as it establishes regulations to protect workers from excessive heat exposure.

In the absence of federal guidelines, many states have been establishing their own requirements for protecting workers from excessive heat. California, Minnesota, Oregon and Washington have provisions for the type of workplace, temperature thresholds and employee protections — hydration, shade, training, monitoring and more — employers must implement.

Increased Illness, Injury & Cost

Heat is the No. 1 cause of weather-related deaths in the workplace. In 2019, heat in the workplace caused 43 worker deaths and at least 2,410 serious illnesses or injuries, although these numbers are considered low due to underreporting.

In addition to causing illness and death from heat exhaustion and heat stroke, excessive heat can exacerbate existing health conditions like asthma, heart problems and kidney failure.

Excessive heat exposure can also impact worker efficiency and decision-making, leading to lower production and worker errors due to dehydration and heat-related mental impairment. Studies have determined that worker productivity declines 4% for every degree above 80 degrees Fahrenheit.

Errors also increase dramatically with rising temperatures.

80 F — Errors averaged five per hour, with 19 errors every three hours.

90 F — Errors averaged nine per hour, with 27 errors every three hours.

95 F — Errors averaged 60 per hour, with 138 errors every three hours.

In addition, studies show that hydration alone does not reduce core body temperatures. Climate control is necessary to restore full mental functioning. These errors, plus the decline in productivity and the increase in heat-related illnesses and injuries, increase the cost of doing business. Excessive workplace heat exposure has also been linked to reduced work hours, increased medical leave and higher employee turnover, all of which may require employers to hire and train new employees. In today’s tight workforce, this further adds to costs.

Estimates of economic loss due to heat, compiled by the Atlantic Council’s Adrienne Arsht-Rockefeller Foundation Resilience Center, total at least $100 billion annually. This impact may double by 2030 and quintuple by 2050 based on projections of continued heat intensification.

Proactive Climate Control

By monitoring heat exposure in the workplace, employers can proactively initiate heat mitigation options before OSHA imposes regulations for those exposures. Portable cooling products, such as evaporative cooling fans, are a good option to implement. They can be placed in large spaces where the air is hot and dry. Contractors may also want to consider establishing cooling stations that incorporate access to hydration in conjunction with an evaporative cooling fan. Air-cooled air conditioners are also available for indoor and outdoor use in 12- and 25-ton models. The air-cooled air conditioners exhaust the heat outside of the space into a designated area.

When deciding on a cooling solution, employers need to determine whether to invest in owning the equipment or renting it. Questions to ask when making the decision include:

Is it necessary to maintain financial flexibility and free up capital?

Is the business in need of constant cooling year-round?

If the risk of heat exposure is seasonal, is there ample storage to house and maintain the equipment in the offseason?

Renting cooling equipment may be the most cost-effective solution if the business only needs it periodically. Whichever the case, it’s critical for employers to take steps to protect workers from heat exposure and related illnesses and injuries — and they can start today.