Safeguarding the health and well-being of employees is among the critical functions of management. In hot workplaces, monitoring environmental conditions and providing adequate protection comprise a significant share of these responsibilities. The details of these efforts are often documented and formalized in a heat illness prevention program.
An effective heat illness prevention program consists of several components, including the measure(s) used for environmental assessment, exposure limits or threshold values, policies defining the response to a limit or threshold being reached, content and schedule of required training for workers and managers, and the processes used to collect and review data and modify the program. Other information may be added, particularly as the program matures. Though it is nominally a prevention program, response procedures, such as the administration of first aid, should also be included; the program should not be assumed to be infallible.
In this installment of the “Thermal Work Environments” series, the components of heat stress hygiene and various control mechanisms are introduced. Combined with the types of information mentioned above, an outline of a heat illness prevention program emerges. This outline can be referenced or customized to create a program meeting the needs of a specific organization or work site.
The content of a heat illness prevention program is presented in five (5) sections:
Every person that works in or has responsibility for a hot workplace should be trained on the ramifications of excess heat. Information relevant to the following four sections is included in an effective training program. Examples of important topics for all team members include:
A complete training plan includes the content of the training and a schedule for delivery. It may be best to distribute a large amount of information among multiple modules rather than share it in a single, long presentation. Refresher courses of reduced duration and intensity should also be planned to combat complacency and to update information as needed. Refreshers are particularly helpful when dangerous conditions exist intermittently or are seasonal.
An initial hazard assessment consists of identifying the elements of job design (see Part 1) that are heat-related. These include environmental factors, such as:
Using the information collected in the hazard assessment, a risk profile can be created for each job. The risk profile is then used to prioritize the development of controls and modifications to the job design.
Similar to that for quality [see “The War on Error – Vol. II: Poka Yoke (What Is and Is Not)” (15Jul2020)], there is an implied hierarchy of controls used to manage heat-related effects on workers. Engineering controls modify the tasks performed or the surrounding conditions, while administrative controls guide workers’ behavior to reduce heat stress. Finally, personal protective equipment (PPE) is used to manage heat stress that could not otherwise be reduced. PPE is often the first protection implemented and is used until more-effective controls are developed.
A comprehensive heat stress control plan is developed by considering each term in the heat balance equation (see Part 2). Examples of engineering controls include:
Monitoring is a multifaceted activity and responsibility. In addition to measuring environmental variables, the effectiveness of controls and the well-being of workers must be continually assessed. A monitoring plan includes descriptions of the methods used to accomplish each.
Measurement of environmental variables is the subject of Part 4 of this series. As discussed in that installment, multiple indices may be used to inform decisions regarding work cycle modifications or stoppages. Those used in popular meteorology, such as Heat Index (HI), are often insufficient to properly characterize workplace conditions; however, they can be useful as early warnings that additional precautions may be needed to protect workers during particularly dangerous periods. See “Heat Watch vs. Warning” for descriptions of alerts that the National Weather Service (NWS) issues when dangerous temperatures are forecast.
After controls are implemented, they must be monitored for proper use and continued effectiveness. This should be done on an ongoing basis, though a formal report may be issued only at specified intervals (e.g. quarterly) or during specific events (e.g. modification of a control). Verification test procedures should be included in the monitoring plan to maintain consistency of tests and efficacy of controls.
Monitoring the well-being of workers is a responsibility shared by a worker’s team and medical professionals. Prior to working in a hot environment, each worker should be evaluated on his/her overall health and underlying risk factors for heat illness. An established baseline facilitates monitoring a worker’s condition over time, including the effectiveness of acclimatization procedures and behavioral changes.
Suggestions for behavioral changes, or “lifestyle choices,” can be made to reduce a worker’s risk; these include diet, exercise, consumption of alcohol or other substances, and other activities. Recommendations to an employer regarding one’s fitness for certain duties, for example, must be made in such a way that protects both safety and privacy. Heat-related issues may be best addressed as one component of a holistic wellness program such as those established by partnerships between employers, insurers, and healthcare providers.
There are three (3) response plans that should be included in a heat illness prevention program. Somewhat ironically, two of them are concerned with heat illness that was not prevented.
The first response plan details the provisioning of first aid and subsequent medical care when needed. Refer to Part 3 for an introduction to heat illnesses and first aid.
The second outlines the investigation required when a serious heat illness or heat-related injury or accident occurs. The questions it must answer include:
The final response plan needed defines the review process for the heat illness prevention program. This includes the review frequency, events that trigger additional scrutiny and revision, and required approvals.
Currently, management of hot work environments is governed by the “General Duty Clause” of the Occupational Safety and Health Act of 1970. The General Duty Clause provides umbrella protections for hazards that are not explicitly detailed elsewhere in the regulations. It is a generic statement of intent that provides no specific guidance for assessment of hazards or management of risks.
In 2021, OSHA issued an “advance notice of proposed rulemaking” (ANPRM) to address this gap in workplace safety regulations. A finalized standard, added to the Code of Federal Regulations (CFR), will add specific enforcement responsibilities to OSHA’s current role of education and “soft” guidance on heat-related issues.
That an OSHA standard will reduce heat-related illness and injury is a reasonable expectation. However, it must be recognized that it, too, is imperfect. No standard or guideline can account for every person’s unique experience of his/her environment; therefore, an individual’s perceptions and expressions of his/her condition (i.e. comfort and well-being) should not be ignored. A culture of autonomy, or “self-determination,” where workers are self-paced, or retain other responsibility for heat stress hygiene, is one of the most powerful tools for safety and health management imaginable.
For additional guidance or assistance with complying with OSHA regulations, developing a heat illness prevention program, or other Operations challenges, feel free to leave a comment, contact JayWink Solutions, or schedule an appointment.
For a directory of “Thermal Work Environments” entries on “The Third Degree,” see Part 1: An Introduction to Biometeorology and Job Design (17May2023).
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Jody W. Phelps, MSc, PMP®, MBA
JayWink Solutions, LLC
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