Creating a Heat Illness Prevention Program

In 2024, workplace temperatures are a hot topic (pardon the pun). 

Last year, the Occupational Safety and Health Administration (OSHA) launched a wide-reaching heat illness prevention campaign, which sought to educate employers and workers on heat hazards. Those efforts have increased over the past several months as the administration has increased enforcement under the General Duty clause (section 5(a)(1) of the Occupational Safety and Health Act of 1970).

But for employers, compliance is a secondary incentive. Heat illnesses mean lost productivity and higher turnover — and a well-constructed heat illness prevention program has benefits for both employees and employers. 

In this article, we’ll discuss OSHA’s heat regulations and non-binding guidance. We’ll also provide a basic strategy for creating a sustainable strategy for heat illness prevention. 

What Are OSHA’s Requirements for Heat Illness Prevention Programs? 

OSHA does not define specific temperature/humidity thresholds for workplaces, nor does the administration have regulations for maintaining temperatures in given environments.

Instead, the administration enforces heat prevention under the General Duty clause, which simply requires that employers provide a safe workplace that is “free from recognized hazards that are causing or are likely to cause death or serious physical harm" to employees.

Of course, dozens of factors can influence whether a worker is “safe" from the heat. Some of those factors are within an employer’s control, while others are not directly manageable:

• The level of physical activity (the workload).
• The worker’s clothing and/or protective gear.
• The worker’s diet and general health, along with other individual risk factors.
• Environmental conditions, including the humidity, temperature, air speed, and degree of exposure.
• Environmental heat generated by equipment and other surroundings. 

For compliance with the General Duty clause, employers must make a reasonable effort to manage heat stress. It’s a good idea to start that process with a heat hazard assessment for workplaces 70° Fahrenheit (21° Celsius) or warmer.

(We should note here that several states do have established requirements for indoor workplaces that exceed certain heat thresholds. To learn more, read: OSHA Indoor Temperature Regulations: What Warehouse Operators Should Know).

Heat Hazard Assessments and the OSHA Heat Index

Humidity has a major impact on environmental heat. Higher humidity levels mean less evaporation — which means that sweat is less effective at cooling down the body. 

For that reason, OSHA recommends using a wet bulb globe temperature (WBGT) monitor when performing a heat hazard assessment. WBGT monitors provide three separate readings:

• Ambient air temperatures.
• Evaporative cooling potential.
• Radiant heat. 

A WBGT device can measure wind, humidity, temperature, and radiant heat. These can be weighed and combined into a single average, which can be used to assess the potential heat stress hazard of a worksite. OSHA’s Technical Manual (OTM) includes a section on heat hazard assessment, which includes guidance for using the WBGT equation.

If your worksite does not have a WBGT monitor, consider using the OSHA-NIOSH Heat Safety Tool. The Heat-Safety Tool is an app that provides a visual indicator of the heat index and risk levels specific to the workplace’s geographical location. It also includes recommendations to limit heat stress. 

However, it’s important to remember that there’s no “magic number" that can tell you whether a worker can safely handle a given workload. As with many aspects of workplace safety, you need to combine general OSHA/NIOSH guidelines with training, environmental controls, and common sense.

Building a Workplace Heat Illness Prevention Strategy

Once you’ve assessed heat as a workplace hazard, you can build out the rest of your heat illness prevention strategy. 

1. Start with Training for Workers and Supervisors

All employees and supervisors should receive heat illness prevention training. You should also document each training session. Documentation prevents employees from falling through the gaps, and it’s essential when a workplace injury occurs.

OSHA outlines a Model Heat Illness Prevention Plan, which includes training in the following areas:

• An outline of the company’s heat-illness prevention plan.
• Risk factors for heat stress (temperature, humidity, air movement, work-related risk factors, and so on). 
• How the body handles heat (including a discussion of the risks of dehydration and heat stress). Include information about proper hydration.
• The importance of acclimation (gradually introducing the worker to heat, discussed in detail below).
• First-aid treatment for heat-related illnesses.
• Heat illness reduction strategies, including engineering controls (using powered equipment and reducing radiant heat) and administrative controls (adjusting work schedules to enforce acclimation). 

The full Model Heat Illness Prevention Plan is available for download; note that employers are not required to use this plan for OSHA compliance, and certain elements of the plan might not be applicable to all workplaces.

2. Focus on Acclimating Workers to Heat

Acclimation is the process of introducing workers to heat gradually. This is an absolutely crucial practice: Almost half of heat-related deaths occur on a worker’s first day on the job, according to OSHA. Over 70 percent of heat-related deaths occur during a worker’s first week.

A work schedule that gradually builds heat tolerance will help workers manage the heat (and can be beneficial for productivity). OSHA and NIOSH recommend using the Rule of 20% when building schedules:

• New and temporary workers should only work in heat for 20% of the normal duration of the workday on their first day.
• Work duration can be increased by 20% on subsequent days.

If you’re scheduling employees for full days, they can spend the other 80% of their first workday on other tasks — such as training and light-duty work. They can and should perform intense activities on day one, but reducing the duration of the work will help them build tolerance. 

3. Implement Controls to Limit Hazards

You can’t control the weather, but you can control your worksite. Engineering and administrative controls can reduce heat hazards (and keep employees happy, which generally means less turnover). 

Many of those controls are common sense, but you should still include them in writing within your heat illness prevention program. For example: 

• Provide an adequate supply of cool, clean water, along with disposable cups. Do not rely on water from garden hoses, irrigation systems, or other potentially non-potable sources. This also improves compliance with various OSHA sanitation standards (29 CFR 1910.141, 29 CFR 1915.88, 29 CFR 1917.127, 29 CFR 1918.95, and others).
• Provide a cool space for water breaks and rest. Ensure that the rest area is shaded or air-conditioned.
• Use appropriate material handling equipment (MHE) to minimize physical effort. As we’ve discussed in other articles, MHE such as scissor lift tables and bin dumpers can reduce strain (and improve productivity) through better ergonomics.
• When possible, suspend activities during the hottest part of the day.
• Medically screen employees who will need to perform high-intensity work in hot environments.
• Instruct workers to drink water regularly and avoid caffeine and alcohol.
• Use the “buddy system:” Have employees work in pairs and monitor each other for signs of heat stress.

4. Plan for Heat-Related Emergencies

Even in well-run workplaces, heat illnesses can occur — and they should be treated as emergency medical events. On-site personnel must have adequate first aid training.

All workers and supervisors should know the early warning signs of heat stress:

• Muscle pain or spasms.
• Heavy sweating.
• Cold, pale, and/or clammy skin.
• A fast, weak pulse.
• Nausea or weakness.
• Dizziness or headache.

Severe heat exhaustion can lead to fainting, vomiting, a fast pulse, confusion, or high body temperatures. Consider posting the CDC’s “Heat-Related Illnesses” poster to keep workers informed. 

Workplace Safety and Productivity Go Hand-in-Hand

BHS can help your business reduce work intensity by investing in ergonomic material handling equipment. 

With an ergonomic approach, you can meet OSHA standards (and stay ahead of upcoming regulations) while streamlining workflows and boosting productivity. Contact BHS today at 1.800.247.9500 to learn more.