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Understanding OSHA Regulations for Heat: A Comprehensive Guide for Indoor Manufacturing Facilities

Keeping Employees Safe and Compliant in a Changing Climate

Key Takeaways:

  1. The Occupational Safety and Health Administration (OSHA) is considering a new heat illness standard for indoor environments without climate-controlled settings, significantly affecting manufacturing facilities.
  2. The proposed standard is still in preliminary stages, but it may mandate break times, monitor employee acclimatization, and require temperature and humidity level checks.
  3. State standards, such as Minnesota’s, which rely on the Wet-Bulb Globe Temperature (WBGT) index, may hint at the future federal standards.
  4. The potential changes may impose significant costs on manufacturing facilities, particularly those with sources of heat such as furnaces or ovens, or those where workers perform physically exerting tasks.
  5. Employers can preemptively act to prevent heat-related issues by ensuring access to water, promoting regular breaks, providing access to shade, and acclimatizing employees to strenuous activities.

An Urgent Need for New Heat Standards

With 18 out of the past 19 years being the hottest on record and an increasing intensity of heatwaves, OSHA has recognized the need to safeguard employees against the risk of heat illnesses or injuries. As a top priority under the Biden administration, OSHA is pursuing a new heat illness standard that will particularly apply to indoor work environments without climate-controlled settings.

The specifics of this proposed standard are still in their formative stages, but there are indications that it may require employers to provide break times, monitor employee acclimatization, and measure temperatures and humidity levels.

Understanding the Potential Implications

A regulation of this kind could impose significant costs on manufacturing worksites, particularly those that do not have air conditioning or possess sources of heat like furnaces or ovens. It’s not just machinery that contributes to heat levels. Even a large number of workers at a site, especially those engaged in physically demanding tasks, can raise the overall temperature.

Take, for instance, a factory where employees are melting materials like metal or glass. The machinery in use can become extremely hot, affecting the surrounding environment, regardless of outdoor temperatures. Similarly, a furnace operating at high temperatures can cause nearby employees to sweat profusely, especially if they are wearing heavy personal protective equipment (PPE).

Insights from State Regulations

Existing state standards may provide clues as to what the OSHA regulations might look like. For example, Minnesota’s indoor heat standard uses the Wet-Bulb Globe Temperature (WBGT) index, which is calculated by considering air temperature, air speed, humidity, and radiation. Under this standard, permissible heat levels vary according to the levels of exertion, defined as follows:

  • “Heavy work,” which includes heavy lifting and pushing or shovel work, and cannot exceed 77 degrees Fahrenheit.
  • “Moderate work,” which encompasses moderate lifting and pushing, has a permissible heat level of 80 degrees Fahrenheit.
  • “Light work,” which includes sitting or standing performing light hand or arm work, has a permissible heat level of 86 degrees Fahrenheit.

Under such a standard, facilities would need to calculate the WBGT and continually monitor and adjust conditions according to the highest level of exertion by any workers in the working environment. This kind of regulation may prove challenging for manufacturers because of changing production schedules and varying outdoor heat conditions.

Proactive Measures for Manufacturing Employers

Even as we wait for the final form of the OSHA heat regulation, manufacturing employers can take certain steps to prevent heat-related issues. These include:

Ensuring Access to Water and Hydration

Staying hydrated is crucial when working in a warm environment. Employers should ensure that employees have easy access to water throughout their shifts.

Providing Adequate Rest Time and Regular Breaks

Regular breaks allow employees to rest, hydrate, and cool down, reducing the risk of heat-related illnesses.

Offering Access to Shade

Where possible, employers should make provisions for shaded areas for employees to take their breaks, especially in facilities where the heat levels can get high.

Acclimatizing Employees

It is also essential that employees are acclimatized before they engage in strenuous activities. This can be achieved by gradually increasing workloads and allowing more frequent breaks until they build a tolerance for working in the heat.

State-Level Developments

Some states are not waiting for OSHA to roll out the new regulations. On July 8, Oregon adopted a 180-day emergency rule that protects workers from indoor and outdoor heat, which may become a permanent rule in the fall. Virginia is drafting a similar standard with the goal of reducing or eliminating injuries, illnesses, and fatalities due to exposure to excessive heat at workplaces.

Existing OSHA Regulations and Recommendations

Traditionally, OSHA has protected workers against extreme heat by invoking the General Duty Clause, a provision in the Occupational Safety and Health Act that requires employers to provide workplaces free of recognized hazards, including heat exposure.

Currently, OSHA recommends that employers set thermostats between 68 and 78 degrees Fahrenheit. It also provides guidelines for “Working In Outdoor and Indoor Heat Environments,” suggesting that employers should plan for emergencies, train workers on prevention, and monitor workers for signs of illness.


The Occupational Safety and Health Administration’s proposed heat illness standard for indoor environments signifies an important step towards enhancing the safety of workers in manufacturing facilities. Although the precise details are yet to be determined, proactive employers can prepare by adopting strategies that minimize heat-related hazards and foster a safer working environment.

It’s evident that the climate is changing, and

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