Is A Heat Stress Program Required By OSHA?

OSHA frequently utilizes the General Duty Clause of the Occupational Safety and Health (OSHA) Act to cite employers who should have a written heat stress program in place.

By Robert Box

Is a written heat stress program required by OSHA? The answer depends on where workers are working. Heat stress is usually associated with construction work and other work outdoors during summer months (particularly in the southern and southwestern United States), but heat stress can be an issue while working inside as well.

Working in or near kitchens, industrial ovens, heat processing, foundries and other hot areas subject workers to the risks of heat stress, which can include death if not handled properly.

Although there is no specific Occupational Safety and Health Administration (OSHA) standard that addresses heat stress, OSHA frequently utilizes the General Duty Clause of the Occupational Safety and Health (OSHA) Act to cite employers who should have a written heat stress program in place.

The General Duty Clause says employers are required to “…provide a place of employment free from recognized hazards that are causing or are likely to cause death or serious physical harm to its employees.” Employers know if the workplace or work area is hot or not, so employers are expected to have hazard controls in place to protect workers exposed to hot work environments.

The Body’s Coping Mechanisms for Heat

The body can maintain a constant internal temperature by varying the rate and volume of blood circulation to the outermost layers of skin and releasing fluid onto the skin through sweat glands. When the moisture evaporates, it cools the skin and the body.

However, when ambient temperatures approach the skin’s temperature, it becomes more difficult for the body to cool itself. If the ambient temperature reaches or exceeds the skin’s temperature, the blood that is brought to the body’s surface cannot lose its heat, and as a result, sweating becomes the primary method of maintaining constant body temperature.

Evaporating moisture (sweat) from the skin is a very effective method to cool the body. When weather conditions include high humidity, sweat has a more difficult time evaporating from the skin, which can greatly disrupt the body’s ability to cool itself.

Thankfully, human beings are generally able to adjust to the heat. Employers can utilize acclimatization as a method of gradually exposing workers to a hot work environment for increasingly longer periods of time. Full acclimatization typically takes from five to seven days. If done properly, acclimatization will prepare the human body to adapt to hotter temperatures.

Heat Stress Illnesses and Symptoms

There are five basic types of heat-related health issues and illnesses that can develop from working in hot environments, including:

• Heat cramps
• Fainting
• Heat Rash
• Heat exhaustion, and
• Heat Stroke

Heat Cramps can manifest independently, or they can develop with another heat-related illness. Heat cramps are actually muscle spasms caused by sweating while working muscles hard in hot environments. Heat cramps are very painful and they may be caused by improper salt levels in the body (too much or too little), and muscles tend to be more susceptible to heat cramps when they are overworked.

Fainting usually occurs when an acclimatized worker stands in one position for a long time, but recovery is usually adequate after a brief break to lie down or sit. Keeping the blood circulating can reduce the risk of fainting, so workers should be encouraged to move around rather than standing still.

Heat Rash typically develops on the skin in hot, humid conditions where sweat does not easily evaporate from the skin. When sweat ducts become clogged with dried sweat or dirt, heat rash usually develops. If the rash becomes infected, it makes an already uncomfortable condition almost intolerable. Bathing and drying the skin on a daily basis, particularly after working in hot environments, can help reduce the likelihood of developing a heat rash.

Heat Exhaustion is associated with losing an abundance of salt by excreting a large volume of sweat. A worker who is experiencing heat exhaustion will still sweat, but may have some of the following symptoms:

• Headache
• Dizziness
• Weakness
• Mood changes
• Confusion
• Irritability
• Nausea
• Vomiting
• Urine of darker color and smaller quantity
• Pale or clammy skin

Heat Stroke is the most dangerous form of the heat stress illnesses and could result in death of the victim. Heat stroke is the result of the body’s temperature-regulating system failing. Heat stroke victims typically have the following symptoms:

• No sweating
• Dry, pale skin
• Mood changes
• Irritability
• Confusion
• Seizures
• Unconsciousness

Call For Emergency Care

While victims of heat cramps, fainting and heat rash can be treated with rest, cool water and shade, and possibly a shower, victims of heat exhaustion or heat stroke must be taken more seriously as they are potential life-threatening situations.

Heat Exhaustion

Assist victims of heat exhaustion by:

• Moving the person out of the sun or away from the heat source and into a cooler/shaded area
• Provide sips of cool water to drink
• Cool the victim by fanning and providing a wet cloth
• If the victim is dizzy, lay them down and raise the feet 6 to 8 inches
• If the victim is nauseous, lay the victim on his or her side
• Loosen or remove clothing, but most importantly…
• Stay with the victim

The victim’s condition can rapidly change the illness from heat exhaustion to heat stroke, and the victim’s life could depend on having someone available to call for help. If the victim doesn’t feel better in a few minutes, call for emergency help immediately.

Heat Stroke

If the victim is diagnosed as having heat stroke, call for emergency help right away (911).

Perform the same first aid actions list above for heat exhaustion, plus:

• If the victim is unconscious, lay the victim on his or her side
• If the victim has a seizure, remove any objects on the victim or nearby that could cause harm
• Provide cool water if the victim is conscious, but provide the water in small sips
• Place ice packs underneath the armpits, behind the knees, and in the groin area.

Who Is At Greater Risk?

Anyone working in hot environments is susceptible to heat stress illnesses, but workers have an elevated risk of developing a heat stress illness when they:

• Are dehydrated
• Are tired or fatigued
• Have non-regular exposure to hot and humid environments
• Are over the age of 40
• Are overweight or otherwise in poor physical condition
• Are on some medications (diuretics, some tranquilizers, and antihistamines)
• Have a history of heat stress illnesses
• Have consumed alcohol or drugs within the past 24 hours
• Have a heat rash or a sunburn, and/or
• Wear too much clothing

Preventing Heat Stress Illnesses

Workers can be protected from dangers associated with working in hot environments by doing the following:

• Train all workers how to recognize symptoms of heat-related illnesses and how to appropriately respond to them
• If possible, schedule the hardest work during the coolest part of the day
• Promote workers using the buddy system (working in pairs) to keep an eye on one another
• Provide plenty of clean, cool water and remind workers to sip water (at least one cup) every 15 to 20 minutes
• Encourage workers to wear light-colored, loose-fitting clothing that is breathable (as permitted by working conditions)
• Provide cool shaded areas and promote workers to take frequent micro-breaks there
• Encourage workers not to consume large, heavy meals or consuming caffeine or alcoholic beverages within 24 hours of working in hot environments
• Attempt to contain radiant heat by placing shields around hot machines or furnaces where it is safe to do so
• Increase insulation around heat-producing machines and furnaces
• Open windows and doors where appropriate
• Use exhaust ventilation, fans and/or air conditioning where possible
• Provide tools and equipment to reduce worker exertion

Heat Related Illness Resources

• OSHA’s “Planning Ahead for Hot Weather:  Employer Checklist” (https://www.osha.gov/SLTC/heatillness/heat_index/employer_checklist.html)
•  OSHA’s “Heat Related Illness Prevention Training Guide” (https://www.osha.gov/SLTC/heatillness/osha_heattraining_guide_0411.pdf)

Safety First Consulting is a contributor of SM Corridor News and helps businesses identify OSHA compliance issues in their workplaces, manage their safety programs, and we become accountable for the results. In addition to offering custom written safety programs for companies, Safety First Consulting provides required safety training, industrial hygiene sampling, noise sampling, and workplace inspections. You can read more from Robert Box under Business.