On July 23, 2024, Cal/OSHA’s new Indoor Heat Illness Prevention Plan went into effect. Title 8, Section 3396 “Heat Illness Prevention in Indoor Places of Employment”. This new regulation creates a mandatory heat illness prevention standard for indoor places of employment that exceed 82 degrees Fahrenheit.
Who Does the Indoor Heat Illness Standard Apply To?
The standard covers all indoor work areas where the temperature equals or exceeds 82 degrees Fahrenheit when employees are present. The regulation is aimed at places like warehouses, restaurant kitchens, and manufacturing plants. Indoor places with functioning air conditioning, for example, many corporate offices, would not be covered if the temperature never exceeds 82 degrees when employees are present.
There is an exception for teleworking employees that are at a location not under the control of the employer (e.g., a remote employee working from home). Additionally, requirements do not apply to emergency operations directly involved in the protection of life or property.
What Are the New Requirements?
Essential requirements include:
- Water: Providing access to portable drinking water that is fresh, pure, suitably cool, and free of charge.
- Cool-Down Areas: Providing at least one cool-down area on site and allowing and encouraging employees to take cool-down breaks as needed, which must be at least 5 minutes in duration.
- Emergency Response Procedures: Ensuring effective communication methods for emergencies and processes to respond to signs/symptoms of heat illness.
- Acclimatization: Supervisors observing new employees within their first 14 days of employment, and all employees during a heat wave.
- High Heat Requirements: When the temperature or heat index exceeds 87 degrees Fahrenheit OR when the temperature exceeds 82 degrees and employees wear restrictive clothing that prevents heat removal or when working in high radiant heat areas, employers have additional requirements, such as keeping accurate temperature and heat index records, and monitoring environmental risk factors for heat illness.
Note: Heat index takes into account other factors, such as humidity. Employers would need to purchase tools that measure heat index (not just temperature) to comply.
Covered employers are required to create a written Heat Illness Prevention Plan (HIPP). The HIPP must contain procedures to comply with the requirements above, as well as procedures for taking heat measurements and recordkeeping when temperatures exceed 87 degrees.
Covered employers must also train their staff on heat illness prevention and treatment, and the employer’s HIPP. For supervisors, employers must provide additional training on monitoring and responding to weather reports indicating excessive heat.
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