Compliance with 2014 OSHA Heat Illness Prevention, April 2014

Download Available: COMPLIANCE WITH 2014 OSHA HEAT ILLNESS PREVENTION 

Background:  Cal/OSHA released the 2014 Heat Illness Prevention Campaign on March 25, 2014. Workers who are exposed to extreme heat or who work in hot environments are at a risk of heat stress that can result in occupational illnesses and injuries. Heat stress can result in heat stroke, heat exhaustion, heat cramps, or heat rashes. Heat can also increase the risk of other physical injuries in workers as it may result in sweaty palms, fogged-up safety glasses, and dizziness.

 

95 Degree Action Stations:  When temperatures reach 95 degrees, Cal/OSHA regulations require that special “High Heat” procedures be implemented (We at CSI note that this time they are specifying temperature rather than just saying hot temperatures!). Supervisors must take extra precautions to mitigate risks to workers:

  • Observe workers for signs and symptoms of heat illness.
  • Remind workers to drink water frequently.
  • Provide close supervision of workers in the first 14 days of employment (to ensure safe acclimatization).
  • Test communication systems to guarantee that emergency assistance can be reached if necessary.

Source:  http://www.dir.ca.gov/DIRNews/2014/2014-24.pdf

Law on Heat Stress:  In the state of California, regulations require employers to take affirmative steps for controlling heat stress.  Generally, for an automobile dealership, high risk of heat stress exists in locations and persons as follows:

  • Sales Staff: When a sales employee walks through the lot with a potential customer, the walk-through the lot would be considered outdoors and hence, the standard would apply.  Encourage sales staff to wear hats when out in the sun.
  • Parts Truck Drivers: As the parts truck driver works outside the dealership, driving around town, the place of work would be considered outdoors as well.
  • Shop Areas: Shops with marginal ventilation, metal roofs and/or hot engines idling may increase the ambient temperatures and heat stress can become an issue.

Other States:  In other states where a specific heat illness standard may not exist, the employer’s responsibility for addressing heat related illnesses does not cease.  General duty clause of Fed-OSHA requires that an employer provide a safe workplace and abate hazardous conditions.  The Assistant Secretary of Labor (OSHA) has clearly articulated that employers in states with Fed-OSHA jurisdiction must protect their employees from heat stress; else, employers would be subject to citations.  In summary, following the California blueprint for employers in other states, even though not statutorily required, makes sense.

 

 

 

 

 

AFFIRMATIVE STEPS FOR MANAGEMENT

Provide Water:  One salient requirement of the California Code is that the employer provide one quart of water per hour per employee during the work shift.  For parts truck drivers, provide a water cooler with ice at the start of the shift.  And last but not least, water fountains or coolers are readily available at place of work.

Monthly Mailer:  In the monthly mailer to your dealership, a training memo on heat stress is enclosed.  Please review it with all the employees and seek acknowledgement.

Poster: “Stopping for Water Keeps You Going” poster from the OSHA website can be downloaded and posted on your employee notice board.  http://www.osha.gov/SLTC/heatillness/osha_heat_poster_en.pdf

TRAINING REQUIREMENTS IN CALIFORNIA

Training requirement under the standards is also listed in the memo and supervisors should pay special attention.

Employee Training is as follows:

  1. The environmental and personal risk factors for heat illness.
  2. The employer’s procedures for complying with the requirements of this standard.
  3. The importance of frequent consumption of small quantities of water or up to 4 cups per hour under extreme conditions of work and heat.
  4. The importance of acclimatization.
  5. The different types of heat illness and the common signs and symptoms of heat illness.
  6. The importance of immediately reporting to the employer, directly or through the employee’s supervisor,

about symptoms or signs of heat illness in themselves, or in co-workers.

  1. The employer’s procedures for responding to symptoms of possible heat illness, including how emergency medical services will be provided should they become necessary.
  2. Procedures for contacting emergency medical services, and if necessary, for transporting employees to a point where they can be reached by an emergency medical service provider.
  3. How to provide clear and precise directions to the work site.

Supervisor Training is as follows:

  1. The information required to be provided by section above.
  2. The procedures the supervisor is to follow to implement the applicable provisions in this section.
  3. The procedures the supervisor is to follow when an employee exhibits symptoms consistent with possible heat illness, including emergency response procedures.
  4. How to monitor weather reports and how to respond to hot weather advisories.

Authority Cited:  Title 8 CCR Section 3395 and Info from CDC & CAL/OSHA website

 

Sam has been helping automobile dealers comply with EPA & OSHA regulations in California, Nevada, Arizona, Hawaii & New York since 1987. Sam received his MS (1986) in Chemical Engineering from School of Mines & Technology followed by a JD (1997) from Southwestern University. Sam is a Certified Safety Professional. Send your comments/questions to sam@cellyservices.com.

 

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