Question: I read about new regulations for indoor heat illness prevention. What do I need to do to comply with these regulations?
Answer: On July 23, 2024, Cal/OSHA’s regulations for “Heat Illness Prevention in Indoor Places of Employment” took effect. These regulations require safety measures for most indoor workplaces where the temperature reaches 82 degrees Fahrenheit, such as restaurants, warehouses, and manufacturing facilities. If a company has a covered workplace, the company must abide by safety requirements such as providing water, cool-down rest periods, and training to employees.
Employers must also develop and implement a written indoor heat prevention plan. The plan must be made available at the worksite to employees, in the language understood by the majority of the employees. It must also be provided to Cal/OSHA upon request. The plan may appear as a standalone section in the employer’s Injury and Illness Prevention Program or as a separate document. The plan must include information such as:
- Provision for Drinking Water: Covered employers must give employees access to clean, cool drinking water as close as practicable to their work area. If a continuous water supply is not possible, employers must provide enough water (i.e., one quart of drinking water per hour) for each employee.
- Provision of Cool-Down Rest Periods: Covered employers must allow and encourage employees to take a “preventative cool-down rest” in a cool-down area when employees feel the need to do so to protect themselves from overheating. Access to cool-down areas must be permitted at all times and employers must ensure that the cool-down areas are maintained at a temperature below 82 degrees Fahrenheit, are blocked from direct sunlight, and are shielded from other high radiant heat sources (to the extent feasible). The standard instructs that employees must not be ordered back to work until any signs or symptoms of heat illness have abated, and in no event less than five minutes.
- Acclimatization: Acclimatization is the process of allowing workers to adjust to hot environments over time, reducing their risk of heat-related illnesses. Covered employers must closely observe employees who are newly assigned to high heat conditions for signs of heat stress during their first 14 days of work in these conditions. Additionally, during a heatwave, if employers cannot reduce indoor heat using methods like air conditioning or fans, they must have a supervisor closely observe employees for any heat-related issues.
- Emergency Response Procedures: Covered employers must have a plan for responding to symptoms and/or signs of heat illness and heat illness related emergencies.
Cal/OSHA has a model prevention plan, which employers can access on the Department of Industrial Relations (“DIR”) website: https://www.dir.ca.gov/dosh/heatillnessinfo.html.
Employers with covered workplaces must comply with additional requirements when the workplace temperature or heat index is 87 degrees Fahrenheit or higher, or where the temperature or heat index is 82 degrees Fahrenheit but feels hotter because employees are (1) wearing clothing that restricts heat removal or (2) working in high radiant heat areas. The additional requirements include measuring and recording the temperature and heat index and implementing control measures in the workplace where feasible. Moreover, employers with outdoor workplaces may also need to comply with separate regulations covering outdoor workplace.
The DIR website includes high level factual summaries and FAQs on the Cal/OSHA regulations. While the information on this website may be used as a starting point, employers may want to connect with their employment counsel on specific questions.