Preventing Heat Injury and Illness

During the annual T&D PowerSkills Trainers Conference earlier this year, several of our clients asked about OSHA’s stance on heat illness prevention. Months later, we are still fielding questions about the topic, as are Incident Prevention’s subject matter experts.

The bottom line is that employers are legally required to have a plan in place to protect all heat-exposed workers. It’s as simple as that. Confusion usually stems from the difference between state OSHA plans and federal rules. After reviewing state plans that include detailed heat illness prevention protocols, some industry professionals question why federal OSHA is silent on the issue.

But the agency has not been silent. While it’s true that they haven’t yet been able to establish a workable standard, their expectations are clear. States generally have an easier time establishing heat illness prevention rules because their smaller relative size simplifies the development and implementation of rules that address region-specific risks. Federal OSHA, on the other hand, must consider the wide-ranging exposures that exist throughout the United States, including in overseas territories.

To help Incident Prevention readers prepare their organizations for compliance, we’re now going to review some relevant history followed by an exploration of OSHA’s more recent heat illness prevention work. Specific rules haven’t arrived just yet, but that doesn’t change your safety obligations to your employees.

OSHA’s General Duty Clause
It was 1972 when the National Institute for Occupational Safety and Health first recommended development of an OSHA heat standard. Their suggestion was based on a critical review of scientific and technical data. OSHA responded by appointing the Standards Advisory Committee on Heat Stress in 1973; in 1974, committee members presented their recommendations for an occupational heat stress standard.

Throughout the decades, OSHA has issued heat-related guidance to employers, ultimately relying on the core expectations of the General Duty Clause as incentive. Located at Section 5(a)(1) of the Occupational Safety and Health Act, the clause states that each employer “shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” Enforcement data reveals that federal OSHA used it as grounds to issue at least 348 heat-related citations between 1986 and 2023, but the agency cannot require employer abatement until they prove the hazardous nature of a specific workplace condition during an enforcement proceeding. In short, the General Duty Clause’s real teeth are reserved for post-incident enforcement.

Promulgating a written heat illness prevention standard would establish the hazard’s existence at the rulemaking stage, thus allowing OSHA to identify and require specific abatement measures. Currently, the General Duty Clause makes it difficult for the agency to ensure abatement before employees’ lives are unnecessarily endangered. The clause also largely forces OSHA to rely on expert witness testimony as proof that (1) a hazard exists and (2) feasible abatement measures will reduce or eliminate the hazard.

Per OSHA 29 CFR 1926.21, “Safety training and education,” employers must train employees in the recognition, avoidance and prevention of unsafe workplace conditions. The agency’s PPE standards require employers to conduct hazard assessments when determining the protective gear that exposed workers must wear. Yet heat is not specifically identified as a hazard in any OSHA standard, complicating the application of these rules.

Emphasis Program and Proposed Rulemaking
OSHA launched a national emphasis program on heat in April 2022, which was updated earlier this year (see www.osha.gov/sites/default/files/enforcement/directives/CPL_03-00-024_0.pdf). Intended to encourage early employer intervention, the program targets specific industries whose workers are exposed to high-heat hazards.

Around the same time, the agency also issued Temporary Worker Initiative Bulletin No. 12 (see www.osha.gov/sites/default/files/publications/OSHA4185.pdf), which addresses the rising number of heat illness and fatal heat exposures among temporary workers in the U.S.

Finally, on August 30, 2024, OSHA published a notice of proposed rulemaking for a standard titled “Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings” (see www.govinfo.gov/content/pkg/FR-2024-08-30/pdf/2024-14824.pdf), taking a significant step toward federal heat protection for workers. The proposed standard would require employers in general industry, construction, maritime and agriculture to create plans to evaluate and control heat hazards in their workplaces. Further, it would clarify employer obligations and the actions necessary to effectively protect employees.

The agency’s ultimate goal is to eliminate occupational injuries, illnesses and fatalities caused by heat exposure. Proactive employers should assume that most of OSHA’s proposal will eventually become standardized. In any case, the document contains solid guidance regarding the establishment of effective worker protection programs.

Preventive Activities
Heat illness prevention programs reflected in state OSHA plans often include the information and activities listed below. As you read, please note that anyone who uses this data is responsible for confirming its accuracy and ensuring the safety of any implementation efforts.

Watch Coworkers for These Symptoms

• Heat exhaustion: weakness, blurred vision, vomiting, dizziness, headache. Move the victim to a cool environment, loosen their clothing, provide fluids and call 911.
• Heat stroke: red face/skin; no perspiration when there should be; elevated body temperature; mental disorientation; convulsions; unconsciousness. Call 911; move the injured worker to a cool environment; elevate their feet; and apply cold packs to the back and sides of their neck, under their arms and between their thighs.
• Heat stress and heat cramps: thirst, stomachache, rash, soreness or weakness in the muscles, especially the arms and legs. Move the victim to a cool environment, encourage them to drink liquids and ensure they rest. Seek medical attention if their symptoms worsen or fail to subside.

Eat Well, Stay Hydrated

• Talk to your doctor(s) about dietary recommendations for heat stress prevention.
• Eat foods that contain omega-3 fatty acids to help your body regulate heat stress.
• Watermelon, cucumber, celery, kiwi and banana are just a few good sources of electrolytes, vitamins, fiber and water/hydration. Eat them to protect against and repair from heat stress.
• Avoid drinking excessive amounts of coffee. It is a diuretic, meaning it increases urine excretion.
• Drink at least one pint of water and one glass of fruit juice before beginning the workday.
• Sip water every 15 minutes throughout the day.
• Energy drink consumption is strongly discouraged (see the section below titled “Energy Drinks: What Employers Should Know” for more on this topic).
• Consume sports drinks like Gatorade to maintain healthy electrolyte levels. For optimal hydration, drink a ratio of three parts water to one part sports drink.
• Continue hydrating into the evening. Yes, technically beer is made with water, but as with coffee, alcohol also has diuretic effects.

Other Tips

• Maintain awareness of the jobsite’s heat conditions. Explore widely available weather apps that deliver timely heat risk warnings to your mobile device.
• Seek relevant reference materials from the American Red Cross, OSHA and NIOSH.
• Begin heat illness protocols when the jobsite temperature reaches over 80 degrees Fahrenheit.
• Adjust job scheduling or provide frequent breaks for exposed workers.
• Provide shade where practical. Make hard hat shades available; workers can use them to shield their head and neck from direct sunlight.
• During pre-job briefings, discuss the day’s potential for heat-related illnesses. Assess crew members for symptoms throughout your shift.
• Seek help as soon as you begin to feel heat stress effects.
• Consider contacting a local hospital to find out whether any of their doctors provide consulting services or deliver presentations on heat illness prevention.

Energy Drinks: What Employers Should Know
As I alluded to earlier, energy drinks can be dangerous, particularly when workers use them to cope with physical stress in hot environments. A 2015 report (see https://newsnetwork.mayoclinic.org/discussion/mayo-clinic-study-one-energy-drink-may-increase-heart-disease-risk-in-young-adults) confirmed what hospitals had already been reporting for several years: that energy drinks – especially when consumed throughout the day as a means of coping with high levels of physical stress – can have detrimental health effects, including heart stress that has led to the death of otherwise healthy young adults. Today, numerous other studies cite similar concerns. Safety and health professionals should be reading this literature.

Energy drinks are widely available, largely unregulated and typically marketed to consumers as a quick way to increase productivity, metabolism, stamina, physical endurance and/or mental acuity. Commonly available brands include Rockstar; Red Bull; 5-Hour Energy; Monster; NOS; Full Throttle; and AMP. These beverages can contain caffeine; sugar; niacinamide; carnitine; amino acids; herbal and natural extracts; taurine; guarana; ginseng; vitamin B3, B6, B9 and B12; sucrose; glucose; inositol; and various preservatives.

Sports drinks are usually advertised as an option for rehydration and electrolyte replacement during periods of strenuous exercise. They typically contain sodium, potassium, chloride, and glucose or sucrose. Common brands include Gatorade, Powerade, Sqwincher and All Sport.

Drink Policies
Industry employers should consider developing policies regarding energy and sports drinks. Do your research and roll out effective training so that employees understand the organization’s obligation to ensure their safety.

Given that energy drinks present a recognized health and safety risk, an employer may choose to fully prohibit their storage and consumption on company premises. Sports drinks, on the other hand, should be recommended and made readily available to employees for electrolyte replacement purposes during times of heat stress. While generally recognized as safe, be sure to note that sports drinks can be overused as hydration therapy, posing a health risk to some individuals. For this reason, it is wise to limit their consumption. Hydration is best achieved by drinking water, and eating a nutritious diet will successfully replace electrolytes.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 28 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at jim@ispconline.com.