HEAT ILLNESS REGULATION CHANGES EFFECTIVE MAY 1, 2015
Cal OHSA recently approved changes to Heat Illness Prevention. These changes are effective May 1, 2015; in time for this year’s summer season. These regulations make substantial changes to the existing regulations and require your immediate review of and likely revisions to your policies, procedures and training programs.
Cal OSHA has updated the Heat Illness Prevention page of their website, located at http://www.dir.ca.gov/dosh/heatillnessinfo.html This page contains the full text of the amended regulations, a chart/guidance document created by Cal OSHA that provides additional direction regarding implementation of the new regulations, as well as training resources.
Golden State Risk Management Authority recommends you immediately review your existing policies, procedures, and trainings programs to incorporate the new requirements. We are in the process of revising our training programs and resources to incorporate the new requirements. If you have questions or need assistance with the new regulations, please feel free to contact us at firstname.lastname@example.org or via telephone at (530) 934-5633. We will continue to keep you updated regarding any additional changes or recommendations on these new regulations.
The information provided below is only a summary of the major changes. Please refer to the full text of changes to the regulations on Cal OSHA’s website at http://www.dir.ca.gov/dosh/heatillnessinfo.html.
Under the existing regulations, employers are required to provide water to their employees. Language has been added now requiring the water be “fresh, pure, suitably cool, and provided to the employees free of charge.” The water must also be located as close as practicable to the areas where employees are working. According to Cal OSHA’s guidance document, this language was added to encourage employees to drink water and so employees did not have to interrupt their work in order to drink water.
Shade shall now be present when the temperature exceeds 80°. Previously the trigger for the shade requirement was 85°. The amount of shade required has also changed. There must now be sufficient shade to accommodate all employees on the recovery or rest period and those onsite taking meal periods. Cal OSHA’s guidance document suggests that employers are expected to monitor weather forecasts and know if the temperature is exceeding 80° at the worksite.
Preventative Cool-Down Rest
Under the existing regulations employees were allowed to take cool-down rest breaks in the shade if needed to protect themselves from overheating. Under the changes, employers are now required to monitor employees that are taking a cool down rest period. Employers should:
- Ask if the employees is experiencing symptoms of heat illness.
- Encourage employee to stay in the shade during this period.
- Shall not order the employee back to work until the signs or symptoms of heat illness have stopped.
- If employee is experiencing signs or symptoms of heat illness, provide appropriate first aid or emergency response.
- Provide first aid or emergency response for employees exhibiting signs or symptoms of heat illness while taking a cool down rest or cool down rest period.
High Heat Procedures
The temperature trigger for implementing High Heat Procedures has remained at 95°. These requirements apply to employers in the agriculture, construction, landscaping, oil and gas extraction, and transportation and delivery industries. However, the following requirements have been added:
More stringent requirements regarding the observation/monitoring of employees for alertness and signs and symptoms of heat illness.
Designating employee as authorized to contact emergency services when necessary.
Pre-shift meetings are required before the start of work to review high heat procedures, remind employees to drink water and reminding employees to take cool down rests when necessary.
Employers in the agriculture industry must also provide one 10-minute preventative cool-down rest period for every two hours worked.
Emergency Response Procedures
A new requirement has been added requiring employers to develop and implement Emergency Response procedures. These procedures must include:
- Ensuring effective communication so employees at worksite can contact a supervisor or emergency services when necessary.
- Responding to signs and symptoms of possible heat illness, including first aid measures and how emergency services will be provided.
- Contacting emergency medical services and if necessary transporting employees to a place where they can be reached by an emergency medical provider.
- Ensuring clear and precise directions to the worksite can and will be provided as needed to emergency responders.
Acclimatization is a process by which the body adjusts to increased heat exposure. Bodies need time to adapt when working in hotter environments. Previously the acclimatization requirements only applied to specific industries under the high heat procedure requirements. Under the new regulations these requirements apply to all outdoor places of employment.
- All employees shall be closely observed during a heat wave. A heat wave means any day in which the high temperature for the day will be at least 80° and at least ten degrees higher than the average high daily temperature in the preceding five days.
- New employees shall be closely observed for the first 14 days of the employee’s employment.
New training requirements have been added. The new regulations contain specifics on the topics that must be covered in the training. Employers must ensure that employees and supervisors are familiar with the signs and symptoms of heat illness, the employer’s procedures for complying with the regulations including the employer’s responsibility for providing water, shade, cool-down rests, and access to first aid.
In their guidance document, Cal OSHA advises the training must be effective. They further note in order to be effective the training must be understood by employees and given in a language the employee’s understand.
Heat Illness Prevention Plan
Employers subject to the Heat Illness standard have always been required to have a written Heat Illness Prevention Plan. However, the new regulations establish additional requirements for the written plan. The plan must be written in both English and the language understood by the majority of the employees and shall be made available at the worksite. The new regulations also set minimum standards for content of the plan.