We employ a number of workers in outdoor jobs during the summer. With summer heat coming on, are there Cal/OSHA requirements we need to comply with in this regard? —Sarah G., HR Manager in Marina del Rey
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Yes, there is a Cal/OSHA requirement in the state Code of Regulations covering heat illness prevention that applies to all outdoor places of employment. The standard, found in General Industry Safety Orders Section 3395, defines heat illness as a serious medical condition resulting from the body’s inability to cope with a “particular heat load,” and it includes heat cramps, heat exhaustion, heat syncope, and heat stroke.
Providing Water
The safety standard requires employers to provide potable drinking water. Where it is not plumbed or otherwise continuously supplied, a sufficient amount of water must be available at the beginning of the work shift to provide one quart of drinking water per employee per hour for the entire shift. Employers may begin the shift with smaller quantities of water if they have effective procedures for replenishing the water supply during the shift as needed to allow employees to drink one quart or more per hour. Further, employers must encourage employees to drink water frequently.
Access to Shade
When employees suffer from heat illness or believe that they need a preventive recovery period, the heat illness prevention standard requires employers to provide access to an area with shade that is either open to the air or provided with ventilation or cooling for no less than five minutes. Except for employers in the agricultural industry, cooling measures other than shade (e.g., use of misting machines) may be provided if the employer can demonstrate that these measures are at least as effective as shade in allowing employees to cool off.
Training
Employers must train all supervisory and nonsupervisory employees on the following topics:
- the environmental and personal risk factors for heat illness
- the employer’s procedures for complying with the requirements of the heat illness prevention standard
- the importance of frequently consuming small quantities of water, up to four cups per hour, when the work environment is hot and employees are likely to sweat more than usual in performing their duties
- the importance of having procedures for adjusting to the first two weeks of work in hot weather
- the different types of heat illness and the common signs and symptoms of heat illness
- the importance of having employees immediately report to the employer, directly or through the employee’s supervisor, symptoms or signs of heat illness in themselves or in co-workers
- the employer’s procedures for responding to symptoms of possible heat illness, including how emergency medical services will be provided should they become necessary
- the employer’s procedures for contacting emergency medical services, and if necessary, for transporting employees to a point where they can be reached by an emergency medical service provider
- the employer’s procedures for ensuring that, in an emergency, clear and precise directions to the worksite can and will be provided as needed to emergency responders
Supervisor Training
Before assigning supervisors to positions where they oversee employees working in the heat, Section 3395 requires supervisors to be trained on the following topics:
- the information required to be provided as detailed above
- the procedures to follow to implement the applicable Section 3395 provisions
- the procedures to follow when an employee exhibits symptoms of possible heat illness, including emergency response procedures
Written Program
The employer’s plan for complying with the heat illness prevention standard must be in writing and made available to employees on request. Note that the procedures may be integrated into the employer’s overall Injury and Illness Prevention Program.
For More Information
Cal/OSHA has several publications dealing with heat illness. Employers may access the following documents online:
- Heat Advisory
- Heat Illness Prevention: What You Need to Know
- Protect Yourself from Heat Illness (English and Spanish)
—CELA Editors