Oh yes, it is that time of year again, it is heating up quickly. The last couple of weeks have reminded us that the Summer is upon is. The gap between 80 degrees and 90+ has such an impact on all outdoor activities, fire risk and human factors.
Most likely everyone reading this article has navigated through many, many Heat Stress safety training courses. Both employer and employee have responsibilities related to heat related training and best practices. Below is a summary of the latest OSHA NEP on Heat Stress and Heat Related injuries, as well as links to OSHA, NIOSH and other sites to provide further knowledge on Heat related illnesses. In short, the latest NEP will be effective until April 8, 2025.
PART 1: NEW OSHA NEP RELATED TO HEAT RELATED ILLNESS
Federal workplace safety officials just unveiled a program designed to scrutinize both indoor and outdoor workplaces for dangers related to extreme heat, putting employers on notice that they need to take steps to address the situation before withering summer temperatures kick in across the country. The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) announced on April 12, 2022 that it has implemented a new National Emphasis Program (NEP) related to heat illness and injuries for both outdoor and indoor workers. As predicted, this NEP comes after OSHA previously issued inspection guidance to its compliance safety and health officers (CSHOs) focusing on heat-related hazards and comes on the heels of OSHA’s proposal to create a permanent safety standard for hazards stemming from heat-related injuries and illnesses. What do employers need to know about OSHA’s new NEP?
What is a National Emphasis Program (NEP)?
Before we examine this specific situation, it’s important to understand what we’re dealing with. NEPs are temporary programs that focus OSHA’s resources on particular hazards and high-hazard industries. The agency uses inspection data, injury and illness data, NIOSH reports, and other information to create new emphasis programs or to evaluate existing NEPs.
Employers are selected for planned inspections under an NEP, and OSHA generally conducts planned inspections fourth on its list of priorities after Imminent Danger, Fatality/Catastrophe, and Complaint/Referral inspections. OSHA currently has 11 other NEPs in effect, ranging from combustible dust to COVID-19 to trenching and excavation.
What Does This New NEP Entail?
OSHA’s goal in implementing this new NEP is to prevent heat-related illnesses such as heat stroke, heat exhaustion, heat cramps, heat syncope, heat rash, rhabdomyolysis (muscle breakdown), and acute kidney injury. The NEP will also focus on heat-related injuries, defined as an injury linked to heat exposure that is not considered one of the typical symptoms of heat-related illnesses (with the exception of kidney injury), such as a fall or cut that occurs after or during heat exposure.
To that end, OSHA will target workplaces where the above illnesses or heat-related injuries are prevalent during high heat conditions. This includes outdoor workspaces in a local area experiencing a heat wave, as announced by the National Weather Service, or working indoors near radiant heat sources, such as iron and steel mills and foundries.
Here are the highlights of the NEP and how employers will be selected for inspections under the NEP:
- List of Employers for Programmed Inspections:
- OSHA will utilize several NAICS codes of non-construction employers, listed in Table 1 of Appendix A of the NEP, to fill its list of employers that can then be inspected under the NEP. Each area office will inspect establishments in random number order. Other employers in non-construction settings may also be added to the list for random inspection through a list of NAICS codes in Table 3 to Appendix A that includes restaurants and an assortment of employers. OSHA can analyze data from employer OSHA injury and illness forms or other information gleaned from other governmental agencies to add additional employers to the list.
- Expansion of Open Inspections Based on OSHA Logs and Observations:
- OSHA now also instructs its CSHOs to open a separate, heat-related inspection of a workplace where, during another inspection by OSHA, the CSHO observes any hazardous heat conditions, notes any relevant illnesses or injuries recorded in the OSHA 300 logs or 301 Incident Reports, or where an employee brings a heat-related hazard(s) to the attention of the CSHO.
- Expansion of Open Inspections Based on Weather:
- During any open inspection where the heat index during the inspection is 80°F or higher, CSHOs will ask employers whether the employer has developed any heat-related hazard prevention programs. OSHA CSHOS will now document conditions relevant to heat-related hazards during open inspections.
- Programmed Inspections Based on Weather:
- Coordination with DOL WHD:
- OSHA will also use information from the Wage and Hour Division (WHD) of the Department of Labor to conduct inspections per the Memorandum of Understanding between the OSHA and the WHD.
- Follow-up from Prior OSHA Inspection:
- Employers may be subject to a follow-up inspection if they have received an other-than-serious recordkeeping violation related for failure to record a heat-related illness or injury.
This new NEP will be effective until April 8, 2025, unless canceled or extended by another OSHA directive.
There is no heat-related or heat stress standard in place. Instead, federal OSHA has traditionally enforced heat-related hazards through its General Duty Clause. This standard requires employers to provide a work environment that is free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees. The NEP recognizes this and notes that: “Heat cases proposing a 5(a)(1) [general duty clause citation] are novel cases and must be submitted to the National Office following novel case procedures, until otherwise instructed.” Therefore, employers should continue to consider whether any such citations issued under the general duty clause for injury and illnesses that are heat related should be contested.
Why is OSHA Focusing on Heat-Related Illnesses and Injuries?
In the NEP, OSHA notes that when the heat index (how hot the air feels when humidity is taken into account) is 80°F or higher, “serious occupational heat-related illnesses and injuries become more frequent, especially in workplaces where unacclimatized workers are performing strenuous work” such as intense arm and back/lifting work, carrying, shoveling, manual sawing, pushing and pulling heavy loads, and walking at a fast pace. OSHA notes that without easy access to cool water, or cool/shaded areas, when working in direct sunlight or areas where other radiant heat sources are present, such injuries are more likely.
Between 2015 and 2020, OSHA conducted nearly 200 heat-related hazard inspections per year (nearly half a percent of all inspections), which included approximately 15 heat-related fatality inspections annually. And in 2021, OSHA published an Advance Notice of Proposed Rulemaking to initiate the rulemaking process towards a federal heat standard. This NEP is one step along that process and allows OSHA to focus its resources during the rulemaking process.
OSHA held a meeting on May 3, 2022 to discuss its ongoing activities regarding heat-related hazards, including its Heat Illness Prevention Campaign, compliance assistance activities and enforcement efforts.
What About States Not Covered by Federal OSHA?
If you do business in a state where a state agency rather than federal OSHA enforces the OSH Act (such as California, Kentucky, or elsewhere), emphasis programs in those states may differ. OSHA’s NEP states that within 60 days of the effective date of its new NEP, State Plans must submit a notice of intent indicating whether they already have a similar policy in place, intend to adopt new policies and procedures, or do not intend to adopt OSHA’s NEP for heat-related injuries and illnesses. And, within 60 days of adoption, the State Plans must provide an electronic copy of the policy or a link to where their policies are posted on the State Plans’ websites. The State Plans must also provide the date of adoption and identify differences, if any, between their policies and OSHA’s. OSHA will provide summary information on the State Plan responses on its website.
What Employers Can Do?
As you prepare for the summer months ahead, there are some steps you can take in order to avoid scrutiny under this NEP and protect employee from heat-related concerns.
- Draft a prevention program to mitigate heat-related injuries and illnesses;
- Designate someone at each worksite to monitor worker health and conditions on days of extreme heat;
- Conduct a hazard analysis of job duties or positions that could involve exposure to extreme heat, including an analysis of outdoor and indoor workspaces; and
- Review your OSHA 300 logs from the past few years to quantify what injuries or illnesses, if any, are or could have been heat-related and implement plans to address those situations moving forward.
What Employees Can Do?
- Arrive at work “Fit For Duty”
- Participate in assigned Heat related annual training (Click for LMS Heat Stress Course)
- Complete First Aid/CPR training. Be knowledgeable and trained to assist if needed.
- “Be your brother’s keeper”, monitor those around you during work activities for heat related symptoms.
- Hydrate! Stay hydrated daily. Drink water and or electrolyte drinks to help maintain hydration. (Ex. Liquid IV, Drip Drops, or Gatorade as an example).
PART 2: HEAT STRESS – HEAT RELATED ILLNESS
Now we will focus on how we can prevent heat related injury by noticing the signs. Click here for the PDF Poster shown below.
Heat stroke is the most serious heat-related illness. It occurs when the body can no longer control its temperature: the body’s temperature rises rapidly, the sweating mechanism fails, and the body is unable to cool down. When heat stroke occurs, the body temperature can rise to 106°F or higher within 10 to 15 minutes. Heat stroke can cause permanent disability or death if the person does not receive emergency treatment.
Symptoms of heat stroke include:
- Confusion, altered mental status, slurred speech
- Loss of consciousness (coma)
- Hot, dry skin or profuse sweating
- Very high body temperature
- Fatal if treatment delayed
Take the following steps to treat a worker with heat stroke:
- Call 911 for emergency medical care.
- Stay with the worker until emergency medical services arrive.
- Move the worker to a shaded, cool area and remove outer clothing.
- Cool the worker quickly, using the following methods:
- With a cold water or ice bath, if possible
Wet the skin
- Place cold wet cloths on the skin
- Soak clothing with cool water
- With a cold water or ice bath, if possible
- Circulate the air around the worker to speed cooling.
- Place cold wet cloths or ice on the head, neck, armpits, and groin; or soak the clothing with cool water.
Heat exhaustion is the body’s response to an excessive loss of water and salt, usually through excessive sweating. Heat exhaustion is most likely to affect:
- The elderly
- People with high blood pressure
- Those working in a hot environment
Symptoms of heat exhaustion include:
- Heavy sweating
- Elevated body temperature
- Decreased urine output
Treat a worker who has heat exhaustion by doing the following:
- Take worker to a clinic or emergency room for medical evaluation and treatment.
- Call 911 if medical care is unavailable.
- Have someone stay with the worker until help arrives.
- Remove the worker from the hot area and give liquids to drink.
- Remove unnecessary clothing, including shoes and socks.
- Cool the worker with cold compresses or have the worker wash their head, face, and neck with cold water.
- Encourage frequent sips of cool water.
Rhabdomyolysis (rhabdo) is a medical condition associated with heat stress and prolonged physical exertion. Rhabdo causes the rapid breakdown, rupture, and death of muscle. When muscle tissue dies, electrolytes and large proteins are released into the bloodstream. This can cause irregular heart rhythms, seizures, and damage to the kidneys.
Symptoms of rhabdo include:
- Muscle cramps/pain
- Abnormally dark (tea or cola-colored) urine
- Exercise intolerance
Workers with symptoms of rhabdo should:
- Stop activity
- Drink more liquids (water preferred)
- Seek immediate care at the nearest medical facility.
- Ask to be checked for rhabdomyolysis (i.e., blood sample analyzed for creatine kinase).
- To learn more, visit NIOSH Rhabdomyolysis.
Heat syncope is a fainting (syncope) episode or dizziness that usually occurs when standing for too long or suddenly standing up after sitting or lying. Factors that may contribute to heat syncope include dehydration and lack of acclimatization.
Symptoms of heat syncope include:
- Fainting (short duration)
- Light-headedness from standing too long or suddenly rising from a sitting or lying position
Workers with heat syncope should:
- Sit or lie down in a cool place.
- Slowly drink water, clear juice, or a sports drink.
Heat cramps usually affect workers who sweat a lot during strenuous activity. This sweating depletes the body’s salt and moisture levels. Low salt levels in muscles cause painful cramps. Heat cramps may also be a symptom of heat exhaustion.
Muscle cramps, pain, or spasms in the abdomen, arms, or legs
Workers with heat cramps should do the following:
- Drink water and have a snack or a drink that replaces carbohydrates and electrolytes (such as sports drinks) every 15 to 20 minutes.
- Avoid salt tablets.
- Get medical help if the worker:
- Has heart problems.
- Is on a low sodium diet.
- Has cramps that do not subside within 1 hour.
Heat rash is a skin irritation caused by excessive sweating during hot, humid weather.
Symptoms of heat rash include:
- Red clusters of pimples or small blisters
- Usually appears on the neck, upper chest, groin, under the breasts, and in elbow creases
- Workers who have heat rash should:
- Work in a cooler, less humid environment, if possible.
- Keep the rash area dry..
- Apply powder to increase comfort.
- Don’t use ointments and creams
5 Signs of Dehydration—Besides the Color of Your Pee
How do you know if you're not drinking enough water? From brain drain to gnarly breath, see the most common signs of dehydration.
Forgetting to drink sounds almost as silly as forgetting to breathe, yet there's a dehydration epidemic, according to a 2015 Harvard study. Researchers found that over half of 4,000 kids studied weren't drinking enough, with 25 percent saying they didn't drink any water during the day. And this isn't just a kid problem: A separate study found that adults may be doing an even worse job of hydrating. (This is Your Brain on Dehydration.) Up to 75 percent of us could be chronically dehydrated!
Being a little low on water won't kill you, says Corrine Dobbas, M.D., R.D, but it can decrease muscle strength and aerobic and anaerobic ability. (And of course, if you're training for a distance race, hydration becomes even more crucial.) In your day-to-day life, dehydration can cause poor mental performance, headaches, and make you feel sluggish, she says.
So how do you know if you're drinking enough H2O? Your urine should be pale yellow or very clear, says Dr. Dobbas. But there are several other less-obvious signs your water tank needs a refuel. Here are five of the biggest signs of dehydration to watch out for.
Dehydration Sign #1: You're Hungry
When your body wants a drink, it's not picky about where that water comes from and will happily accept food sources as well as a glass of plain water. That's why many people assume they're hungry when they start to feel weak and tired, Dr. Dobbas says. But it's harder to get hydrated through food (not to mention more caloric!), which is why she advises drinking a cup of water before eating to see if that takes care of your "hunger."
Dehydration Sign #2:Your Breath Reeks
One of the first things to get cut when you're dehydrated is your saliva production. Less spit means more bacteria in your mouth and more bacteria means stinky breath, according to research published in the Orthodontic Journal. In fact, the study authors write that if you go see your dentist about chronic halitosis, usually the first thing they suggest is drinking more water—that often takes care of the problem.
Dehydration Sign #3: You're Grouchy
A bad mood may start with your water levels, according to a study published in the Journal of Nutrition. Scientists found that young women who were just one percent dehydrated reported feeling more anger, depression, annoyance, and frustration than women who drank enough water during a lab test.
Dehydration Sign #4: You're a Little Fuzzy
That afternoon brain drain may be your body crying for water, according to a study in the British Journal of Nutrition. Researchers found that people who were mildly dehydrated during the experiment performed worse on cognitive tasks and reported feelings of wanting to give up and an inability to make decisions.
Dehydration Sign #5:Your Head Is Pounding
That same study that found that dehydration increased moodiness in women also found an increase in headaches in the dried-out ladies. The researchers added that dropping water levels could decrease the amount of fluid surrounding the brain in the skull, giving it less padding and protection against even mild bumps and movement.
- Heat index (HI) values were created for shady, light wind conditions, so exposure to full sunshine can increase heat index values by up to 15°F.
- The simplicity of the HI makes it a good option for many outdoor work environments (as long as there are no additional radiant heat sources, such as, fires or hot machinery). However, if you have the ability, NIOSH recommends using wet bulb globe temperature (WBGT)-based Recommended Exposure Limits (RELs) and Recommended Alert Limits (RALs) in hot environments.
- Use of the HI or WBGT is important, but other factors such as strenuous physical activity also cause heat stress among workers. Employers should have a robust heat stress prevention program that ensures workers are protected.
- NIOSH and OSHA are currently considering new scientific data related to the HI levels, and considering how to best incorporate the evolving science. It is important to regularly download updates to ensure you are using the latest version of the app.
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