Introduction

On July 24, 2024 the California Division of Occupational Safety and Health (Cal/OSHA) obtained authorization to immediately implement and enforce new Indoor Heat Protection Regulations at places of employment state-wide. This summary provides Employers with an overview of these regulations, highlighting their objectives, key provisions, and implementation strategies.

I. Key Objectives of the Regulation

The Indoor Heat Protection Regulation, aims to safeguard workers from heat-related illnesses in indoor environments, which are becoming exacerbated due to the effects of climate change. Employers need to understand the comprehensive elements of this plan, assess their indoor workspaces for compliance with new standards, and take immediate action to conform where gaps or shortcomings exist.

II. Key Provisions of the Regulation

1. Scope and Application:
   • The regulation applies to all indoor workplaces where heat conditions could lead to heat illness. This includes manufacturing facilities, warehouses, kitchens, and other enclosed areas where heat is generated or accumulated.
   • It specifically targets environments where the temperature exceeds 82°F (27.8°C) and where heat is a recognized hazard, regardless of the source of heat.
2. Heat Illness Prevention Program (HIPP):
   • Employers are required to develop and implement a Heat Illness Prevention Program (HIPP) tailored to their specific work environments. This program must include procedures for:
     • Heat Stress Evaluation:Assessing the potential for heat stress by considering factors such as indoor temperature, humidity, and the type of work performed.
     • Training:Providing training for employees and supervisors on recognizing symptoms of heat-related illnesses, understanding the importance of hydration, and knowing the steps to take in case of heat stress.
     • Heat Controls:Implementing measures to control heat exposure, including adequate ventilation, cooling systems, and the use of personal protective equipment (PPE) when necessary.
     • Emergency Response:Establishing clear procedures for responding to heat-related emergencies, including access to first aid and medical care.

3. Hydration and Rest Breaks:
   • The regulation mandates that employers ensure workers have access to adequate amounts of drinking water and take regular rest breaks in a cool environment. Employers must:
     • Provide potable water that is readily accessible to all employees.
     • Allow employees to take breaks to cool down and recover from heat exposure.
     • Implement a system to monitor and manage employee hydration and rest needs, adjusting as necessary based on workload and environmental conditions.

4. Heat Monitoring and Adjustment:
   • Employers must monitor indoor temperatures and humidity levels regularly to ensure they do not exceed safe thresholds. They are required to:
     • Use appropriate tools and methods to measure indoor heat conditions.
     • Adjust work schedules and modify work practices to minimize heat exposure during extreme conditions.

5. Recordkeeping and Reporting:
   • Employers must maintain records related to heat exposure, training, and incidents of heat illness. This includes:
     • Documenting heat stress evaluations and mitigation measures.
     • Keeping records of employee training sessions and emergency responses.
     • Reporting serious incidents of heat illness to Cal/OSHA as required.

6. Employer Responsibilities:
   • Employers are responsible for ensuring compliance with all aspects of the regulation, including:
     • Regularly reviewing and updating the Heat Illness Prevention Program.
     • Providing adequate resources and support for heat protection measures.
     • Engaging employees in discussions about heat-related risks and prevention strategies.

III. Implementation Strategies

To effectively implement Cal/OSHA’s Indoor Heat Protection Regulation, employers should follow several strategic steps:

1. Assessment and Planning:
   • Conduct a comprehensive assessment of indoor heat risks and develop a detailed Heat Illness Prevention Program. This should involve evaluating current heat conditions, understanding the nature of work performed, and identifying potential areas for improvement.
2. Employee Training and Involvement:
   • Implement robust training programs that not only educate employees about heat illness but also involve them in developing and refining heat protection measures. Encourage feedback and participation to enhance program effectiveness.
3. Monitoring and Evaluation:
   • Regularly monitor indoor heat conditions and evaluate the effectiveness of implemented measures. Use data from temperature readings and incident reports to make informed adjustments to work practices and heat control strategies.
4. Communication and Collaboration:
   • Maintain open communication with employees about heat risks and protection measures. Collaborate with industry experts and other employers to share best practices and stay updated on new developments in heat protection strategies.

IV. Conclusion

Cal/OSHA’s Indoor Heat Protection Regulation is now a critical component of California’s occupational safety framework, designed to protect workers from the hazards of excessive indoor heat. By mandating comprehensive heat protection programs, hydration and rest breaks, and rigorous monitoring and reporting, the regulation seeks to prevent heat-related illnesses and ensure safe working conditions. Employers must proactively implement these provisions, continually assess their effectiveness, and engage with employees to foster a safe and healthy work environment. For more information, or to assist in assessing the compliance of your place of business, please call our offices at (818) 986-7561. We’ll be happy to work with you to ensure you aren’t exposed to Cal/OSHA enforcement actions.