As temperatures continue to rise, the impact of heat on indoor workspaces has prompted California regulators to take action. The Cal/OSHA Standards Board proposal to introduce a comprehensive heat illness standard for indoor work areas triggered at 82 degrees Fahrenheit has sparked discussions and debates among employers, especially those operating in warehouses, distribution centers, and manufacturing plants. While the proposal presents significant challenges, a recent revision released on August 4th, 2023, brings some relief for employers by addressing concerns and providing more practical solutions. Continue reading to explore the intricacies of the proposed standard, the challenges it poses, and the positive changes introduced in the latest revision.
Understanding The Proposed Standard
The Cal/OSHA Standards Board proposed indoor heat illness standard aims to ensure the safety and well-being of employees working indoors when temperatures reach 82 degrees Fahrenheit. If adopted, this standard will necessitate a range of measures employers must take to prevent heat-related illnesses among their workforce.
Key Requirements Of The Proposed Standard
- Written prevention program: Employers must establish and maintain a written indoor heat illness prevention program detailing procedures for water access, cool-down areas, and emergency response measures.
- Training: Effective training on heat illness prevention will be mandatory for employees and supervisors.
- Cool-down areas: Access to cool-down areas maintained below 82 degrees, protected from direct sunlight and radiant heat, will be required.
- Additional rest periods: Encouraging and monitoring employees to take preventive cool-down rest periods during high-temperature periods will be essential.
- Observation obligation: Close observation of new employees during a 14-day acclimation period and monitoring employees during heat waves without effective engineering controls will be necessary.
Challenges Presented By The Proposed Standard
- Temperature monitoring and control: One of the major hurdles for employers will be measuring the temperature and heat index at specific thresholds. Temperature readings must be taken when the threshold is suspected to be met and when it's expected to be 10 degrees higher than previous measurements.
- Hierarchy of control measures: The strict hierarchy of control measures presents a complex challenge. Employers must prioritize engineering controls, then administrative controls, and if neither is feasible, provide personal heat-protective equipment.
Recent Revisions: A Breath Of Relief For Employers
Recognizing the concerns raised by stakeholders, the August 4th, 2023 revision of the proposed standard offers several improvements that alleviate some of the compliance burdens.
- Short-duration exception: The revision includes an exception for indoor work areas where employees spend less than 15 minutes in any one-hour period, as long as the location isn’t usually occupied. This addresses the worry of applying the rule to brief indoor activities such as equipment retrieval.
- Compliance for outdoor-indoor transition: Employers no longer have to comply with two separate heat illness rules when employees transition between indoor and outdoor work, simplifying compliance efforts.
- Clothing-specific control triggers: For employees wearing heat-restrictive clothing, the trigger temperature for control measures is lowered to 82 degrees. Exceptions are provided for clothing materials that are air and water-vapor permeable.
- Feasibility exception for cool-down areas: The revision acknowledges feasibility challenges, making it more practical for employers to provide shaded and radiant-heat-shielded cool-down areas.
- Training integration: Employers can integrate indoor heat illness training with existing outdoor heat illness training, streamlining the education process.
Simplifying Compliance Through Expertise
Amidst the changing landscape of workplace regulations, small businesses in California are confronted with the dual challenge of ensuring compliance with the proposed indoor heat illness standard while maintaining operational efficiency. This is where a professional employer organization (PEO) emerges as a strategic partner. A PEO like GMS provides comprehensive HR solutions that encompass the complexities of the new heat illness regulations and a range of employment-related tasks.
From drafting and implementing the required written prevention programs to conducting employee training, a PEO can alleviate the administrative burden on small businesses. By partnering with GMS, businesses can confidently navigate the evolving regulatory landscape, allowing them to focus on what truly matters: fostering a safe and productive work environment for their employees. As the indoor heat illness standard journey continues, the role of a PEO becomes increasingly vital, ensuring that small businesses remain compliant, competitive, and caring employers. Contact us today to learn more.