- Safety and Health Topics
- Occupational Heat Exposure
Occupational Heat Exposure
Under the General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act (OSHA) of 1970, employers are required to provide their employees with a place of employment that "is free from recognizable hazards that are causing or likely to cause death or serious harm to employees." The courts have interpreted OSHA's general duty clause to mean that an employer has a legal obligation to provide a workplace free of conditions or activities that either the employer or industry recognizes as hazardous and that cause, or are likely to cause, death or serious physical harm to employees when there is a feasible method to abate the hazard. This includes heat-related hazards that are likely to cause death or serious bodily harm.
Criteria for a Recommended Standard – Occupational Exposure to Heat and Hot Environments. U.S. Department of Health and Human Services (DHHS), National Institute for Occupational Safety and Health (NIOSH) Publication No. 2016-106, (February 2016).
- The Personal Protective Equipment (PPE) standard at 29 CFR 1910.132(d) requires every employer in general industry to conduct a hazard assessment to determine the appropriate PPE to be used to protect employees from the hazards identified in the assessment. See also 29 CFR 1915.152 (shipyard), 29 CFR 1917.95 (maritime) and 29 CFR 1926.28 (construction).
- The Recordkeeping regulation at 29 CFR 1904.7(b)(5) requires that employers record certain work-related injuries and illnesses. If a worker requires medical treatment beyond first aid, the worker's illness or injury must be recorded. However, if a worker merely requires first aid for the worker's condition, the employer is not required to record the condition. For example, if a worker requires intravenous fluids, the worker's condition must be recorded. But if a worker is only instructed to drink fluids for relief of heat stress, the worker's condition is not recordable. Refer to 29 CFR 1904.7(b)(5) for an explanation of the difference between medical treatment and first aid.
- The Sanitation standards at 29 CFR 1910.141, 29 CFR 1915.88, 29 CFR 1917.127, 29 CFR 1918.95, 29 CFR 1926.51 and 29 CFR 1928.110 require employers to provide potable water.
- The Medical Services and First Aid standards at 29 CFR 1910.151, 29 CFR 1915.87, 29 CFR 1917.26, 29 CFR 1918.97, and 29 CFR 1926.50, require that persons onsite be adequately trained to render first aid, in the absence of medical facilities within close proximity.
- The Safety Training and Education standard for construction at 29 CFR 1926.21.
Letters of Interpretation
- The use of hard hats while working on roofs in hot weather. (August 1, 2014). Addresses concerns related to the use of hard hats and roofers' risk of heat-related illnesses from exposure to excessive heat.
- Whether the use of personal protective equipment is mandatory when working under heat stress conditions. (May 18, 2010). OSHA guidance for choosing appropriate PPE to protect workers from electrical hazards when heat stress is a factor.
- Clarification of preexisting injury/illness and recordkeeping. (October 6, 2009). Clarifies recordkeeping requirements for heat-related illnesses.
- Wearing short-sleeved shirts while performing a thermal spray operation with exposure to hexavalent chromium fumes. (January 25, 2007).
- Requirements for "nature breaks" and weather-related "comfort breaks" for U.S. Postal Service employee. (May 12, 2006)
- Acceptable methods to reduce heat stress hazards in the workplace. (October 17,2001). Identifies feasible and acceptable methods that can be used to reduce heat stress in workplaces.
- Fire retardant PPE requirements and PPE hazard assessment. (March 27, 1998). Identifies heat and cold stress as a factors considered under PPE hazard assessment.
- Interpretation of OSHA requirements for personal protective equipment to be used during marine oil spill emergency response operations. (September 11, 1995). 29 CFR 1910.132(d) mandates the employer to perform a hazard assessment of the workplace to determine if the use of PPE is necessitated; select and mandate employee use of the necessary PPE; communicate selection of PPE decisions to employees; and select PPE that properly fits the employees.
- Landscaping employees working in extreme temperatures. (July 14, 1992).