HR Alert

California Proposes Rule on Heat Illness Prevention in Indoor Places of Employment

Certain Employers Must Comply with Existing Heat Illness Prevention Mandates

The California Division of Occupational Safety and Health (Cal/OSHA) has released a proposed rule that would generally affect all indoor places of employment where the "dry bulb" temperature equals or exceeds 85 deg. F.

Proposed Rule
Under the proposal, such employers would be required to establish, implement, and maintain an effective heat illness prevention plan. The plan must be in writing in both English and the language understood by the majority of the employees and must be made available in the workplace to employees and to Cal/OSHA representatives upon request.

Note: The plan may be included as part of the employer's Injury and Illness Prevention Program required by state regulations or the employer's outdoor Heat Illness Prevention Plan required under state regulations (section 3395), discussed below in the "Current Requirements" section.

The heat illness prevention plan required under the proposal also must, at a minimum, contain certain elements (section: c), including control measures and training. Employers would also have certain responsibilities to assess and reassess the heat illness risk (using certain specified procedures) and would have to establish certain first-aid and emergency response procedures. Employers would also be required to keep certain records of training and the most recent heat illness risk assessment and the control measures used. Additional requirements are outlined in the text of the certain elements.

Current Requirements
Currently, many employers in California are required to have an effective written '''Injury and Illness Prevention Program''' (IIPP). The IIPP is a basic written workplace safety program, which also must contain certain elements, including training and hazard assessment. According to Cal/OSHA, employers must regularly review and update their IIPPs in order for them to remain effective. Cal/OSHA offers employers an '''Injury and Illness Prevention Program''', which contains guidance on (among other things) how to create a written IIPP.

Additionally, California's outdoor Heat Illness Prevention Standard generally applies to all outdoor places of employment. (Also, certain industries are subject to additional requirements in high heat--95 deg. F or above). Covered employers must (among other things) provide sufficient access to shade and water, training, high-heat procedures, and must develop a heat illness prevention plan that meets certain requirements (section: i). Cal/OSHA offers certain employer resources, including Q&As, training materials, guidance, and sample procedures.

Click here to read the proposed rule. Stay tuned for updates regarding the status of Cal/OSHA's proposed heat illness prevention requirements.


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