Heating and Cooling, Safety

Are You Familiar with Cal/OSHA’s Indoor Heat Proposal?

If you’re a facilities manager in California, you should be staying up to date on the developments! California’s Division of Occupational Safety and Health (Cal/OSHA) recently revised its draft indoor heat illness prevention standard to address stakeholders’ concerns. Employers would have to maintain the indoor temperature and heat index below 87 degrees Fahrenheit when workers are present under the standard—and facilities managers will play a role in compliance.

Indoor Heat

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Cal/OSHA doesn’t anticipate making any additional changes before it begins the rulemaking process, and a proposal is overdue. The California law authorizing the standard set a January 1, 2019, deadline for the agency to send a proposed rule to the California Occupational Safety and Health Standards Board.

Indoor Heat Limits

Employers also would be required to maintain the temperature and heat index below 82 degrees where workers work in high radiant heat work areas or must wear clothing that restricts heat removal. If you are a facilities manager for a company that has workers subject to these conditions (or you manage a property where your tenants work in these conditions), the time to start planning any necessary adjustments to your HVAC system is now.

Other requirements of the draft standard may or may not directly affect you as facilities manager, including:

  • Establishing, implementing, and maintaining a heat illness prevention plan;
  • Implementing emergency response procedures for signs and symptoms of heat illness and contacting emergency medical services, if necessary;
  • Providing water and access to cool-down areas maintained below 82 degrees;
  • Taking temperature or heat index measurements during work shifts and maintaining records of measurements to assess the effectiveness of the employer’s control measures;
  • Closely monitoring new or newly assigned employees while they acclimate to hot conditions;
  • Training workers and supervisors in the risks and signs of heat illness; and
  • Using administrative controls or providing heat-protective equipment if engineering controls cannot reduce the temperature and heat index below the standard’s limits.

Evolving Draft

Cal/OSHA has repeatedly revised the draft standard since its initial February 22, 2017, discussion draft. The agency made the latest round of revisions in response to comments from employers, labor unions, and other stakeholders in a January 29 draft.

What About Outside of California?

What if you are located outside of California? Well, federal OSHA has no indoor or outdoor heat illness prevention standard. OSHA cites employers under the Occupational Safety and Health Act’s General Duty Clause, usually after an employee succumbs to heat illness. A coalition led by Public Citizen has called OSHA’s practice reactive and repeatedly petitioned the agency for a heat illness standard.

Minnesota has temperature limits for both cold and hot conditions in indoor workplaces. Employers must maintain a minimum of 65 degrees Fahrenheit during cold conditions where light or moderate work is performed and 60 degrees for heavy work. Minnesota’s heat limits are 77 degrees for heavy work, 80 degrees for moderate work, and 86 degrees for light work.

Next Steps

There are several steps to complete before California’s indoor heat standard becomes final. Cal/OSHA must complete a prerulemaking package with proposed rulemaking text it would submit to the standards board. The standards board staff reviews Cal/OSHA’s submission before publishing a proposed rulemaking for public comment and public hearings. So there is still likely plenty of time before the standard goes into effect—stay tuned for more developments!

Cal/OSHA 2019

If you’re a facilities manager in California, you may want to know all you can about state-specific safety regulations such as the indoor heat proposal. To learn more about Cal/OSHA regulations, enforcement trends, and strategies to stay in compliance, attend BLR’s upcoming Cal/OSHA Summit 2019.

The Cal/OSHA Summit, which will be held from October 7–9 in Los Angeles, is a leading state-specific event for California employers and safety professionals to get cutting-edge developments on new safety regulations, compliance strategies, and management tactics. Register now!