How OSHA's NEP on Heat Hazards Affects Your Safety Program

I was recently considered for a role in a manufacturing outfit that applies a corrosion-resistant coating to lengths of pipe. During the interviews, the shop area was frequently referred to as Mordor - the fiery, lava-covered realm from The Lord of the Rings trilogy. It's a fitting nickname for a shop that typically operates at a sweltering ambient temperature 110°F, with flames and ignition sources that require flame resistant coveralls.

I didn’t wind up taking the job, but it got me thinking about the challenge of managing that level of heat in a work environment. At best, you might have near-constant turnover as people leave for nicer working conditions. At worst, the unmitigated risk will result in heat-related injuries and illnesses.

Without the right control measures in place, workers performing physically demanding jobs in excessive heat is a disaster waiting to happen. To address this problem, OSHA has launched its National Emphasis Program on Indoor and Outdoor Heat Hazards.

OSHA's National Emphasis Program on Indoor and Outdoor Heat Hazards

According to the US Department of Labor, heat-related injuries and illness resulted in an average of 35 fatalities per year and 2,700 cases with days away from work. The true number may be even higher, since many conditions brought on by heat exposure are misattributed to pre-existing conditions or assumed to be spontaneous, such as heart attacks and nausea.

As these numbers show, current protections need work. That's where OSHA comes in. Their National Emphasis Program (NEP) on Indoor and Outdoor Heat Hazards provides additional enforcement for heat risks.

Effective since April 8, 2022, The program puts the onus on the employer to make sure workers can carry out their jobs in a safe environment. And while employers sometimes wave off the heat as a hazard that can't be controlled, the government now provides guidelines for controlling heat exposure. The NEP on Heat Hazards provides a standard for conducting inspections for heat conditions in high-risk industries in order to audit employer performance.

(Learn more in Are Heat Edemas a Safety Issue?)

NEP Inspections

The National Emphasis Program on Indoor and Outdoor Heat Hazards names over 70 target industries subject to increased inspection activities based on the North American Industrial Classification System (NAICS). Inspections are programmed in a random order for each target industry, but the NEP also permits unprogrammed inspections as a result of complaints, reports, or fatalities that may be related to heat conditions.

Inspections are conducted by Compliance Safety and Health Officers (CSHO) who follow well-defined procedures and requirements. The CSHO will gauge the employer's ongoing performance by looking at their previous heat-related infractions, emergency situations, and incident reports. They may also assess current prevention measures by interviewing workers and recording on-site conditions, such as the heat index, wet bulb temperature, and the level of cloud cover. These environmental factors are weighed together with the vigorousness of the work and the type of clothing required.

A CHSO may also evaluate how well the organization's heat safety program has been implemented. This would include an assessment of the hazard and exposure, training, provision of drinking water, and structured respite using breaks and job rotation. The organization's records should corroborate that they have measured and monitored their workers' heat exposure.

NEP inspections for heat risks follow the NIOSH guidance document Criteria for a Recommended Standard: Occupational Exposure to Heat and Hot Environments. The Criteria lays out the required levels at which controls must be implemented for heat-related risks. Many of the controls consist of changes to administrative procedures, such as scheduling frequent breaks, ensuring access to drinking water, and job rotation.

(Learn more in A Primer on Administrative Controls)

Above 80°F, heat-related injury and illness become more frequent, particularly in workers who haven't acclimated to the temperature. Structured acclimatization to high-heat work environments is a feature of the NEP, specifying that workers need to be provided progressive time and load requirements to allow them to "get used" to the heat. Newer employees should be given more frequent breaks and an incremental, progressive workload.

In recognition of the increased risk, the American Conference of Governmental Industrial Hygienists (ACGIH) has introduced guidance for unacclimatized workers (the “Action Limit”, or AL), in addition to the Threshold Limit Value (TLV) that applies as a heat limit for all workers.

Meeting the Requirements of OSHA's NEP

OSHA's General Duty Clause already required employers to take heat risks seriously. Unfortunately, this often results in a casual approach to controlling this hazard - an approach that has proved insufficient time and time again.

Thankfully, OSHA has stepped in and formalized an enforcement program to ensure that more workers are protected from heat-related illness and injury. Where violations are observed, there is now a detailed process and criteria for evaluating performance and issuing citations.

Heat-related inspections are now formalized and more frequent, so take steps to be ready for them. Implement control measures for heat hazards, provide an adequate supply of drinking water for your employees, establish a procedure to acclimatize employees to hot working conditions, and document heat-related incidents.

The point of the National Emphasis Program on Indoor and Outdoor Heat Hazards is to reduce the rate of heat-related incidents. Don't wait for a visit from a Compliance Safety and Health Officer to address these hazards and provide your employees with the protection they need and deserve.