In 2022, federal OSHA ramped up its heat illness efforts with a National Emphasis Program, but the agency’s future standard is likely still at least a year away. In the absence of a federal standard, what steps should construction contractors be taking to protect workers from heat illness?
“LIUNA signatory contractors and other employers should use existing state standards as a blueprint for how to protect workers from heat illness,” says LHSFNA Management Co-Chairman David F. Rampone. “These measures are straightforward, cost effective and may save a life or prevent a serious medical emergency.”
Three states – California, Oregon and Washington – now have state-specific heat illness standards for outdoor workers. Let’s take a look at some key elements from these standards that LIUNA signatory contractors can use to protect LIUNA members.
1. Water/Rest/Shade. This trio is the foundation of heat illness prevention. While the exact requirements differ slightly between the state standards, all three require employers to provide workers with adequate water, reasonable access to shade and periodic rest breaks to let them cool down.
Construction employers should ensure there’s enough water and shade for all workers throughout their entire shift. Workers should be instructed to take rest breaks anytime they experience the onset of heat illness.
2. Acclimatization. Cases of serious heat illness and death usually occur when workers are new to the job or during heat waves (often defined as temperatures spiking 10℉ higher than the previous week’s average). Employers can address this risk by increasing workloads gradually for new workers over the first two weeks on the job and by monitoring those workers for symptoms of heat illness.
3. High-Heat Procedures. During heat waves or periods of extreme temperatures, employers can protect workers by implementing mandatory rest breaks, using a buddy system and through monitoring by supervisors.
For example, the Washington State standard requires a cool-down rest of at least 10 minutes every two hours when temperatures reach 100℉. The Oregon standard requires cool-down rests starting at 90℉. The California standard requires supervisors to either directly observe workers, implement a mandatory buddy system or regularly communicate with individual workers by radio or phone.
4. Written Prevention Plan, Emergency Planning & Training. All three state standards require some combination of emergency planning and worker training as part of a written heat illness prevention program. Employers should ensure supervisors and workers know the signs of heat illness and what to do if they recognize it in themselves or a coworker.
Serious heat illness, which includes heat stroke, is a medical emergency and requires immediate action to protect workers’ health. Employers should create an emergency response plan for heat illness that includes what to do if emergency services can’t be reached directly (e.g., if cell service is unavailable).
An employer’s written heat illness prevention plan should also detail how water, rest and shade will be provided to workers as well as the employer’s procedures for acclimatization and high-heat conditions.
All LIUNA signatory contractors can order the Fund’s Preventing Heat-Related Illnesses in Construction pamphlet and Heat Illness Prevention Toolbox Talk for more information. LIUNA signatory contractors in California, Oregon and Washington State can also order the LHSFNA’s state-specific heat illness fact sheets to ensure they protect workers while also staying in compliance with state regulations.
Only three states have specific heat standards for outdoor workers, but there’s nothing stopping responsible and proactive employers from implementing these measures and others across the U.S. and Canada. Regardless of location, the LHSFNA recommends all employers with outdoor workers develop and implement a comprehensive heat illness prevention program. For assistance with creating such a program, contact the Fund’s OSH Division.