Update Applicable to:
All employers with employees working in heat hazardous workplaces in California.
What happened?
Cal/OSHA continues to push their proposed standard to cover Heat Illness Prevention in Indoor Places of Employment by stepping up enforcement of indoor heat hazards.
What are the details?
Employers know Cal/OSHA’s outdoor heat illness prevention standard with employees who commonly work outside. And while there is no official indoor heat illness standard, employers still need to consider heat hazards when evaluating workplace safety, especially in light of Fed/OSHA’s National Emphasis Program (“NEP”) for Outdoor and Indoor Heat-Related Hazards.
Although Cal/OSHA has been working on a proposed standard to cover Heat Illness Prevention in Indoor Places of Employment since 2017, the standard has not been approved. Despite no formal standard, Cal/OSHA is stepping up enforcement of indoor heat hazards, presumably due to the NEP, under California’s version of the General Duty Clause: Title 8 Cal. Code Regs., Section 3203.
Section 3203 requires employers to, among other things, identify and evaluate workplace hazards and correct unsafe or unhealthy conditions based on the severity of the hazards. Employers should document their assessment pursuant to Section 3203.
In assessing indoor heat hazards, employers should consider the following issues:
For more information, please see the links below:
Outdoor Heat Illness Prevention Standard
Fed/OSHA’s National Emphasis Program (“NEP”) for Outdoor and Indoor Heat-Related Hazards
Heat Illness Prevention in Indoor Places of Employment
What do employers need to do?
Employers should review the links provided above and may want to review their heat hazard policies and consider developing a written plan to protect employees. They should include training, personal protective clothing or equipment, engineering controls, administrative measures, and other measures to mitigate potential harm to employees.
