Courtney Hansen, Associate with NV5
On May 18th, 2023, the California Occupational Safety and Health Administration (Cal OSHA) Standards Board met to discuss the newly proposed Indoor Heat Illness standard. The drafting of this standard originally started in 2017 and has gone through several revisions, being delayed for finalization by the COVID-19 pandemic. This current standard is under review and anticipated to be voted on in the first quarter of 2024 with implementation before the summer of 2024. The Board’s goal is to create a program that is easy to understand and implement.
The proposed standard, 8 CCR 3396, mirrors the Outdoor Heat Illness Prevention standard including the following sections: provision of water, access to cool down areas, assessment and control measures, emergency response procedures, and close observation during acclimatization. This standard would go into effect for indoor workplaces where the temperature equals or exceeds 87 degrees Fahrenheit or where employees wear clothing that restricts heat removal or work in high radiant heat areas and the temperature equals or exceeds 82 degrees Fahrenheit. An indoor workplace would be considered a space that is under a ceiling or overhead covering that restricts airflow and is enclosed.
Regulations that would be unique to the proposed standard include cool down areas and recording of temperatures. Cool down areas would be required to be maintained at less than 82 degrees Fahrenheit and have water available. Similar to the outdoor heat standard, employers would be required to encourage employees to take preventative cool down rests and monitor for signs of heat stress. Also, employers would be required to measure the temperature and heat index when it is suspected the standard will apply, record whichever is greater, and maintain these records for a minimum of one year.
This proposed standard was met with criticism at the public hearing. Workers and union representatives expressed concerns about the temperature threshold still not being low enough, potentially leaving employees exposed to the dangers of heat illness. References were made to other state safety plans such as Minnesota where their indoor heat regulations trigger at 77 degrees Fahrenheit for heavy work and 80 degrees Fahrenheit for moderate work. Additional comments were made about how much water is to be provided, the importance of electrolyte replacement, frequency of training, and procedures for acclimatization. Cal OSHA is now tasked with reviewing the comments and modifying the proposed standard to take some of the concerns and comments into account.
NV5 recommends that employers take this current season as an opportunity to prepare themselves for the approval of this standard by taking temperatures over the summer of their indoor work areas and evaluating the work performed for applicability and implementation of this standard.