California OSHA has implemented groundbreaking heat regulations to safeguard workers from indoor hazards.
Effective July 2024, these heat safety rules establish requirements to protect employees from extreme heat exposure in indoor workplaces.
Read on to understand what the Cal OSHA heat rules are and how to comply with the new indoor heat stress regulations.
What is in the New Cal/OSHA Indoor Heat Worker Mandate?
According to the U.S. Department of Health and Human Services, outdoor workers in the U.S. are up to 35 times more likely to die from heat exposure than the average American.
However, heat stress is not limited to outdoor workers—those in indoor environments like factories, restaurants, and warehouses with high heat-generating equipment are also at significant risk.
This is why the California Occupational Safety and Health (Cal/OSHA) Standards Board unanimously approved a new heat stress protection rule for indoor workplaces.
These new worker protections apply to indoor workplaces, including but not limited to, restaurants, warehouses, and factories in California. This effort to formalize heat standards at indoor workplaces is 7 years in the making, with the final approval by the Office of Administrative Law taking place in June 2024.
Cal/OSHA’s Chief Debra Lee emphasizes that these indoor heat illness regulations are designed to “prepare employers to deal with the challenges of rising temperatures in indoor environments.”
Under California Code of Regulations, Title 8 (T8CCR), sections 3395 (T8CCR3395) and 3396 (T8CCR 3396), employers are now required to protect workers from heat illness in both indoor and outdoor settings.
What is Mandated in the New Cal OSHA Indoor Heat Illness Regulations?
As of June 20, 2024, following the approval of Title 8, section 3396 , “Heat Illness Prevention in Indoor Places of Employment,” by the California OSHA board, these indoor heat safety regulations took immediate effect.
While industry-specific guidelines are still in the works, here are the key requirements of the indoor heat safety standard and the OSHA heat work/rest chart:
For workplaces where the temperature reaches 82°F (or 77°F with a heat index of 87°F):
- Monitor Indoor Temperature: Employers must closely monitor the indoor temperature conditions and identify any heat hazards.
- Recordkeeping: Employers must keep accurate temperature and heat index records and monitor environmental risk factors for heat illness.
- Heat Illness Prevention Plan: Employers must maintain a detailed Heat Illness Prevention Plan, and take steps to protect workers, including:
- – Providing access to potable drinking water that is fresh, pure, cool, and at no cost to employees.
- – Offering frequent breaks in cool-down areas.
- – Implementing training on heat illness prevention for employees and supervisors.
- – Implementing Emergency Response Procedures and have processes to respond to signs and symptoms of heat illness.
- – Providing access to potable drinking water that is fresh, pure, cool, and at no cost to employees.
- For workplaces where the temperature reaches 87°F (or 82°F with a heat index of 87°F) or higher AND employees wear restrictive clothing, additional requirements apply:
- – Employers must implement engineering control measures to cool down the work area, such as ventilation, air conditioning, or cooling fans.
- – If engineering controls are not feasible, employers must implement administrative controls like rotating employees, rescheduling work, and reducing work intensity.
- – Acclimatization: Supervisors must observe new employees within their first 14 days of employment and all employees during a heat wave.
- – Develop and implement a work-rest schedule to limit employee exposure to heat stress.
- – Provide personal protective equipment that helps with heat stress, if necessary.
- – Record-keeping: Employers must measure and maintain records of temperature and/or heat index measurements for 12 months.
- – Employers must implement engineering control measures to cool down the work area, such as ventilation, air conditioning, or cooling fans.
Employers must limit worker exposure to heat by adjusting work practices, procedures, and schedules. Additional training is required for supervisors on monitoring and responding to weather reports so they implement the employer’s plan.
Key Takeaways from the Cal OSHA Indoor Heat Illness Prevention Guidelines
- – Have a written heat illness prevention plan handy and easily accessible.
- – Train all employees thoroughly in accordance with the policies and prevention plan, with additional training for supervisors.
- – Monitor the indoor ambient temperature and heat index.
- – Maintain a record of all temperature and heat index measurements.
- – Provide cooling systems like air conditioning and fans where feasible.
Who does the new indoor heat stress standard apply to?
With exceptions, the new Cal OSHA heat stress law applies to all indoor work areas where the temperature equals or exceeds 82°F when workers are present.
It does not apply to outdoor working conditions that fall under the scope and application of California Code of Regulations title 8, section 3395.
What are the exceptions to the new indoor heat stress regulation?
The indoor heat safety standard does not apply to:
- – Workplaces where employees are teleworking and the location is not under the control of the employer.
- – Prisons, juvenile, and local detention facilities.
- – Emergency operations that are directly involved in the protection of life or property.
- – Incidental heat exposures above 82°F but less than 95°F for less than 15 minutes per hour.
These exceptions do not apply to:
- – Vehicles without effective and functioning air conditioning.
- – Shipping or intermodal containers during loading, unloading, or related work.
Why is the new Cal OSHA heat stress mandate necessary?
With soaring temperatures making 2024 one of the hottest years on record, California has expanded worker protections beyond outdoor environments. The new Cal/OSHA indoor heat stress mandate addresses the urgent need to safeguard employees in indoor workplaces from life-threatening heat hazards.
By mandating cool-down areas in workplaces exceeding 82°F, this regulation takes a crucial step towards preventing heat-related illnesses.
What is Cal/OSHA?
Cal/OSHA is the California state division of the Occupational Safety and Health Administration. It was established in 1973 and is part of the Department of Industrial Relations.
It is responsible for enforcing workplace safety and health regulations and providing workers and employers with the assistance they need to adhere to the occupational safety guidelines.
What are the differences between the indoor and outdoor heat stress regulations?
The Cal/OSHA indoor heat safety regulations share many similarities with the outdoor heat stress regulations. Many of the same precautions as outdoor environments apply to indoor settings, but there are subtle differences that set them apart:
Temperature Thresholds:
- Outdoor: Focuses primarily on air temperature, with specific thresholds for different levels of exertion.
- Indoor: Uses a combination of air temperature and heat index, with lower trigger points for indoor environments.
Work Environment:
- Outdoor: Emphasizes shade, hydration, and rest breaks in outdoor settings.
- Indoor: Focuses on ventilation, air conditioning, and engineering controls to cool down the work environment.
- NOTE: An indoor workplace’s internal temperature can also be impacted by factors such as levels of insulation and reflective shields.
Clothing and Equipment:
- Outdoor: Often requires specific heat-protective clothing and equipment for outdoor workers.
- Indoor: Addresses the impact of restrictive clothing on heat stress and requires employers to provide suitable attire.
Acclimatization:
- Both regulations include provisions for acclimatizing workers to hot conditions. However, specific requirements and timelines may vary.
Monitoring and Recordkeeping:
- Outdoor: Requires extensive monitoring of weather conditions and worker hydration.
Indoor: Emphasizes temperature monitoring and recordkeeping to identify and address heat hazards.
What is considered a cool-down area?
A cool-down area is a shaded indoor or outdoor space with good ventilation or air conditioning. It should be below 82°F when possible.
Employers must provide at least one cool-down area on site and encourage employees to take cool-down breaks as needed, with breaks lasting at least 5 minutes to prevent indoor heat stress.
What is considered an indoor place of employment?
Employers may be covered under both the indoor and outdoor regulations if they have both indoor and outdoor workplaces.
What is considered a sufficient amount of drinking water?
- – Potable drinking water must be made available at all times and at no cost to workers.
- – Workers should be encouraged throughout their work shifts to drink water.
- – Cal/OSHA recommends visually examining, tasting the water, and pouring some on the skin to ensure that the water is fresh, pure, and cool.
- – The water must also be located in a readily accessible place to all workers.
- – Water must be placed strategically to encourage workers to drink adequate amounts.
- For instance, in a large warehouse, water should be placed throughout the entire building and workspace area.
What is the hottest temperature you can legally work in?
Employees are required to provide employees with a cool place for rest breaks once the indoor temperature hits 82°F.
What is the recommended way to measure indoor temperature?
OSHA recommends the use of wet bulb globe temperature (WBGT) monitors to measure workplace environmental heat.
The WBGT can be adjusted to address indoor heat stress or outdoor conditions as required.
WBGT has continued to be widely used as it’s a convenient, efficient, and accurate measure of heat stress and real-world conditions.
How do I measure the wet bulb globe temperature (WBGT)?
The wet bulb globe temperature (WBGT) can be measured using on-site weather stations, handheld WBGT monitors, or online WBGT and weather monitoring apps.
These WBGT monitors can either be handheld or part of a weather station and measure temperature, humidity, sunlight, and other factors to calculate the WBGT index.
What is the Heat Index?
The heat index is a measurement that shows how hot the human body feels outside when relative humidity and air temperature are combined.
It is calculated for shaded areas and doesn’t account for direct sunlight, physical activity, or wind.
Different people may also perceive heat differently due to factors like hydration, body shape, and metabolism.
The scale spans from a low of 80°F and 40% humidity (Caution) to a high of 110°F and 100% humidity (Extreme Danger).
Learn more about the heat index here.
How do I recognize an occupational heat hazard?
Several elements contribute to occupational indoor heat stress, including:
- – Environmental conditions (temperature, humidity, sunlight, airflow)
- – Heat sources in the workplace
- – Intensity of physical exertion
- – Protective gear
- – Individual factors like overall health
Implementing Cal/OSHA’s Indoor Heat Stress Recommendations
As California businesses navigate the new California OSHA indoor temperature regulations, it is essential to prioritize employee well-being and compliance. By understanding and adhering to these guidelines, businesses can create safer and more productive work environments.
To effectively comply with CA OSHA guidelines and safeguard employee well-being, businesses must prioritize temperature monitoring, employee training, and the creation of a comprehensive heat illness prevention plan.
Weather stations like Perry Weather can provide essential data and insights to help organizations make informed decisions and ensure compliance.
By investing in heat safety measures, employers can create a healthier and more productive work environment for all employees.
Learn more about how Perry Weather can help here.
