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Key Takeaways:
- OSHA is poised to implement new heat illness standards for indoor workers.
- The standard may necessitate substantial changes for manufacturing worksites, particularly those lacking climate control.
- Measures could include required break times, monitoring of temperatures, humidity levels, and employee acclimatization.
- Employers are encouraged to ensure access to water, sufficient breaks, shade, and appropriate acclimatization for employees.
The Dawn of a New Heat Standard
In a bid to become “the most pro-union president you have ever seen”, President Joe Biden’s administration, through the Occupational Safety and Health Administration (OSHA), has indicated its intention to instate a new heat illness standard. This change specifically targets “indoor workers without climate-controlled environments”, with manufacturing facilities particularly in mind.
Despite the proposed standard still being in its nascent stages, with exact contents yet to be defined, we can get a sense of the potential implications by examining heat standards in various states. OSHA’s regulations may necessitate scheduled break times, temperature and humidity level tracking, and monitoring of employee acclimatization. These changes could impose significant costs on manufacturing sites that lack air conditioning or contain heat sources like furnaces or ovens.
Challenges and Implications for the Manufacturing Industry
Certain manufacturing operations generate significant heat, impacting the surrounding environment. For example, a factory melting metal or glass or running a furnace above 500 degrees could cause nearby employees to perspire heavily, potentially prompting the standard to require cooler temperatures.
Minnesota’s indoor heat standard uses a measure known as the “wet-bulb globe temperature” (WGBT) index, which considers factors such as air temperature, air speed, humidity, and radiation. Using this standard, permissible heat levels vary according to the level of exertion:
- Heavy work – Exerting 350 or more kcal/hr., with a maximum heat level of 77 degrees Fahrenheit.
- Moderate work – Exerting 200 to 350 kcal/hr., with a maximum heat level of 80 degrees Fahrenheit.
- Light work – Exerting 200 kcal/hr., with a maximum heat level of 86 degrees Fahrenheit.
This means facilities may need to constantly monitor and adjust conditions according to the highest level of exertion by any workers in the environment, a potentially unworkable demand for manufacturers due to fluctuating production schedules and external heat conditions.
Prevention Strategies and Adaptation
Manufacturers can take steps to prevent heat-related issues. This could include ensuring access to water for hydration, providing adequate rest times and regular breaks, and creating opportunities for shade where possible. Another key area is ensuring proper acclimatization for workers before they undertake strenuous activities.
Several states, including Oregon and Virginia, are already considering or implementing their heat standards. For example, Oregon recently adopted a 180-day emergency rule for indoor and outdoor worker heat protection. The rule includes regular cool-down breaks, training, communication, emergency planning, and other measures.
Historical Precedents and Current Recommendations
Traditionally, OSHA has used the General Duty Clause to protect workers from extreme heat. This clause necessitates that employers offer workplaces free of recognized hazards, which has previously encompassed heat exposure. However, recent rulings have set a high bar for its use in cases involving heat exposure and other environmental conditions.
Currently, OSHA suggests that employers maintain thermostats between 68 and 78 degrees Fahrenheit. OSHA also advises employers to provide workers with water and rest, acclimatize new or returning workers, plan for emergencies, and monitor workers for signs of illness.
OSHA’s Heat Standard: A Boiling Point for Change
The introduction of OSHA’s new heat standard could potentially usher in significant changes to manufacturing facilities and other workplaces without climate-controlled environments. As the details of these changes continue to be fleshed out, businesses should monitor developments closely and begin considering the potential impact on their operations and how to adapt. Though challenges may arise, with effective planning and proactive strategies, these changes could herald an era of safer and healthier working conditions in the manufacturing industry.
