As part of the program, OSHA said it will proactively initiate inspections in indoor and outdoor work settings when the National Weather Service issues a heat warning or advisory for a local area. Furthermore, on days when the heat index is 80 degrees or higher, OSHA inspectors and compliance specialists will engage in outreach and technical assistance to keep workers safe. Previously, when passing by a worksite, OSHA representatives needed to see a violation to stop -such as workers not utilizing proper fall protection measures when exposed to fall hazards. However, this new program allows an inspector to stop at any worksite, indoor or outdoor, whenever the temperature is above 80 degrees outside.
Stay ahead of unplanned inspections by becoming familiar with certain triggers for heat-related inspections:
● When conducting other, non-heat-related investigations, OSHA can open a heat-related inspection into any hazardous heat conditions observed or reported
● When the heat index is expected to be 80 degrees Fahrenheit or higher (“heat priority days”), OSHA will inquire about heat-related hazard prevention programs during inspections
● When the National Weather Service (NWS) has announced a heat warning or advisory for a local area, OSHA will use neutral, objective criteria to select employers for pre-planned inspections in high-risk industries in that area—including foundries, warehouses, farming, waste collection, and residential construction, among many others
● When the Wage & Hour Division of the Department of Labor (WHD) is investigating reported inadequate working or living conditions or wages, WHD is encouraged to refer information about potential heat-related hazards to OSHA
Companies will need to ensure they have current Heat Safety and Prevention policies. Should OSHA stop by, they will want to know what the employer is doing to be proactive about indoor and outdoor heat safety. It is important for employers to remain vigilant, particularly on hot days. OSHA may come knocking. Get ahead and stay prepared! Here are some steps OSHA could take in inspecting heat-related hazards:
● Review injury and illness logs and incident reports for entries indicating heat-related illness;
● Review records of heat-related emergency room visits and/or ambulance transport, even if hospitalization did not occur.
● Interview workers for heat illness symptoms like headache, dizziness, fainting, dehydration, etc.
● Determine if the employer maintains a heat illness and injury prevention program, and consider whether the program addresses hydration, breaks, shade, acclimatization, training, and other relevant policies.
● Interview workers to ensure there is an understanding of the company’s heat illness prevention program
● Review training records
● Document relevant conditions, such as the heat index, any NWS heat alerts, type of heat source (e.g., direct sunlight, proximity to furnace), any injured employee’s exertion level and duration of exposure to heat.
A Heath Illness Prevention Plan is a proactive process to help employers find and fix workplace hazards before workers are hurt. Eliminating workplace hazards enables employees to stay invested in their work and do their best. Safety is the most important aspect of your company’s plan for the future. If you would like Work Safety Review to compose a “Heat Illness Prevention Plan” for your organization, submit a request below.