Is It Hot in Here?

By Eliseo Nú?ez , HR Director

Does anyone remember that classic I Love Lucy episode where Lucy drinks Vitameatavegamin for a television commercial, and after many takes with the alcoholic elixer, says in a slurred voice, “It’s awful hot in here!”? If you need a good laugh today, it’s worth a watch.?

What’s not so funny is the new Indoor Heat Illness Prevention regulation which Cal/OSHA’s standard board adopted in June. The Office of Administrative Law (OAL) issued a final approval on the Indoor Heat Illness Standard on July 20, 2024, which took effect on July 23, 2024. Since then, California employers have been waiting for some guidance on when Cal/OSHA says it’s too hot for workers inside of a workplace.

Join CEA and Cal/OSHA for a free webinar/Q&A presentation on August 20, where Cal/OSHA Consultation will provide key insights into this new standard, as well as the new Workplace Violence Prevention requirements! Register here now!

Who Does the Indoor Heat Illness Standard Apply to?

To recap, the standard applies to all indoor work areas where the temperature equals or exceeds 82 degrees Fahrenheit when employees are present. This regulation is aimed at workplaces like warehouses, restaurant kitchens, and manufacturing plants. Indoor work spaces where the temperature never exceeds 82 degrees, like offices environments with functioning air conditioning, will not need to worry about this if the temperature never exceeds 82 degrees when employees are present. (Unless your air conditioner stops working, in which case this rule would then apply to your workplace!)?

Are There Any Exceptions?

Very few.? The new standard does not apply to outdoor working conditions since these are already regulated by their own Heat Illness Prevention Standard. Other exceptions include:

• Prisons, local detention facilities, and juvenile facilities
• Teleworking employees where the location is not under the control of the employer
• Emergency operations directly involved in the protection of life or property
• Incidental heat exposure where a worker is exposed to temperatures between 82 and 95 degrees Fahrenheit for less than 15 minutes in any 60-minute period. This exception does not apply to vehicle without working air conditions or shipping or intermodal containers during loading, unloading, or related work.

New Employer Requirements

Employers impacted by this new standard must now develop, document (put in writing), and implement procedures for complying with the requirements of this standard. A Heat Illness Prevention Plan (HIPP) must include information on:

• Water: Procedures for providing sufficient drinking water.
• Cool-Down Areas & Breaks: Procedures for providing access to cool-down areas and breaks.
• Emergency Response Procedures: Including effective communication and first aid response.
• Acclimatization Methods: Including closely observing new employees and newly assigned employees working in hot areas during a 14-day acclimatization period.

And, when additional risk factors are present, such as when the temperature reaches or exceeds 82 degrees when employees are wearing restrictive clothing or working in high radiant areas (ovens, fire, etc.), or anytime the temperature reaches or exceeds 87 degrees, employers must also include information on:

• Monitoring & Controls: Procedures for measuring the temperature and heat index and recording whichever is greater, identifying and evaluating environmental risk factors for heat illness, and implementing control measures.

Communication and Training

Covered employers must train their staff on how to prevent and treat heat illness, and on the employer’s written heat illness prevention plan. Additional training on monitoring and responding to weather reports indicating excessive heat must be provided for all supervisors in the workplace.

Resources

More information is available on Cal/OSHA’s Heat Illness Prevention and Guidance Resources page including educational materials and a model Written Heat Illness Prevention Plan employers can use to craft their own plan. Cal/OSHA also has an updated Frequently Asked Questions page regarding this new ruling.

CEA members, please give us a call today with your questions at 800.399.5331 or email us at [email protected].