Celly Services Inc.

Heat Stress

Both Cal-OSHA and Fed-OSHA are requiring that employers take affirmative steps to reduce heat stress. This law was enacted in California a few years ago when employers were required to train employees & supervisors for the prevention of heat stress. https://www.dir.ca.gov/title8/3395.html This memo provides you with guidance on the statute and other steps you may take to be in compliance and to protect employee health. Please note that if Cal-OSHA were to inspect you facility, they would require you to show proof of training on heat stress along with other safety documentation!
Background: Workers who are exposed to extreme heat or work in hot environments may be at risk of heat stress. Exposure to extreme heat can result in occupational illness and injuries. Heat stress can result in heat stroke, heat exhaustion, heat cramps, or heat rashes. Heat can also increase the risk of injuries in workers as it may result in sweaty palms, fogged-up glasses, and dizziness. Burns may also occur as a result of contact with hot surfaces.
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 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.
  • Parts Truck Drivers: A parts truck driver works outside the dealership driving around town. The place of work is considered outdoors.
  •  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.
Employees Working Indoors: Training on Heat Stress for employees working indoors is being worked out by the regulators in Sacramento.
Other States: In other states where a specific heat illness standard may not exist, the employer’s responsibility for addressing heat related illness’ does not cease. The general duty clause of OSHA requires that an employer provide a safe workplace and abate hazardous conditions. Training employees on Heat Stress should be completed.
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. Last but not least, water fountains or coolers should be readily available at the job site.
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
Start A Conversation At 80˚ F: The dealership management should start a conversation with the employees regarding the impact of hot ambient temperatures and the means to alleviate the effects of heat. Some ideas are as follows:
  • Install a Thermometer: An 18 inch or bigger thermometer in the shop area. May even install one in the break room indicating the temperature outside. This will send a reminder to employees regarding being vigilant to the increase in temperature. Taylor Precision sells patio thermometers for $25.
  • Drink Water: Remind employees to drink water and stay hydrated. You may even blend Gatorade type drinks for employees with ice in the cooler, preferably during the hotter times of the day.
  • Get the OSHA App For Your Cell Phone: OSHA has developed an app “OSHA-NIOSH HEAT SAFETY TOOL”. Employee can download the app on their phone and get the local Heat Index, Hourly Heat Index, Symptoms of Heat Stroke, First Aid for Heat Stroke and other safety tips.
  • Defog Your Glasses: The high heat will induce sweat that will fog up the safety glasses. Keep your safety glasses clean and spray defogger solution on the lenses. Lenses with high performance anti-fog coating are also available.
  • High Blood Pressure and Diabetics: The heat impacts persons with diabetes or high blood pressure in a severe manner. Employee with those ailments should take extra precaution in the hot summer months.
Training Guidance
Employee training is required for employees as follows:
  1. The environmental and personal risk factors for heat illness.
  2. The employer’s procedure for complying with the requirements of this standard.
  3. The importance of frequent consumption of small quantities of water
  4. The importance of acclimatization.
  5. The different types or 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 symptoms of heat illness in themselves, or in coworkers.
  7. The employer’s procedures for responding to symptoms of possible heat illness, including how emergency medical services will be provided should they become necessary.
  8. 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.
  9. How to provide clear and precise directions to the work site.
Training should be completed ASAP and employee acknowledgment should be retained in files.
DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.  Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Our newsletters can be accessed at www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com.

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