Over the last month, OSHA has been reviewing comments about its Advance Notice of Proposed Rulemaking (ANPRM) for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. OSHA reviews these public comments to help determine if and how it should proceed with rulemaking for a heat-specific workplace standard.

A standard specific to heat-related injury and illness prevention would more clearly set forth employer obligations and the measures necessary to more effectively protect employees from hazardous heat. The goal is to prevent and reduce the number of occupational injuries, illnesses, and fatalities caused by exposure to hazardous heat.

ISEA Comments

ISEA has been meeting regularly with members who manufacture heat stress safety equipment and products. Under the ISEA letterhead, leaders in safety equipment filed comments to OSHA urging them to indeed develop a heat stress standard.

ISEA offered examples of current best practices of using heat stress solutions across a variety of workplaces:

  • Administrative Controls, such as changes to tasks or work schedules, can aid as a heat illness prevention step, reducing heat exposure.
  • Access to Water, with hydration packs or water stations.
  • Cooling PPE, worn on the neck, arms, and core; including cooling towels and jackets/vests.
  • Light-Weight High-Visibility Clothing can serve as a lighter alternative to heavier vests.

ISEA and its members advised OSHA to consider all relevant PPE in its efforts to protect workers from hazardous heat in indoor and outdoor work settings:

“Cooling PPE, when worn correctly and when use instructions are followed, can reduce the surface of the skin temperature and aid in maintaining core body temperature. Cooling PPE should be worn on areas where there are large blood vessels located near the surface of the skin (neck, arms, and core).

Studies indicate cooling PPE coverage on the body is directly correlated to its effectiveness. An example being a vest that covers the core is more effective at cooling the body than a towel or bandana on the neck.

For high heat indoor settings with limited airflow, or if an impermeable suit is worn, evaporative products are not ideal. In these work environments, a phase-change product should be worn. While there is weight with a phase change vest and it adds an additional layer, it is can also help reduce or maintain the core body temperature, allowing for a safer work environment and increased productivity.”

ISEA also asked that record-keeping requirements be updated to include heat stress. Even if non-mandatory, any type of data that OSHA can gather will help to inform the agency’s decisions and will supplement data from the Bureau of Labor Statistics.

Next ISEA Heat Stress Meeting

ISEA’s Heat Stress working group will convene virtually on March 3 at 11:00 am ET to discuss potential reporting on the number of US workers at risk of heat stress, an update on BSR/ASSP A10.50, and ISEA efforts around OSHA’s Water-Rest-Shade campaign.

Please contact Dan Glucksman at dglucksman@safetyequipment.org if you’d like to join the meeting.