Regional Policy for Heat Illness Prevention

OSHA
U.S.DEPARTMENT OF LABOR
Occupational Safety and Health Administration
DIRECTIVE NUMBER: SFO-CPL-04-00-16
SUBJECT: Regional Emphasis Program for Heat Illness Prevention
REGION: San Francisco
SIGNATURE DATE: September 30, 2022 EFFECTIVE DATE: November 4, 2022
ABSTRACT
Purpose: This instruction establishes a Regional Emphasis Program (REP)
for heat related health hazards.
Scope: This instruction applies to areas of federal enforcement in the San
Francisco Region.
References: See Paragraph III
Cancellations: This instruction cancels all previous San Francisco Regional
Instructions and memorandum on this subject.
State Impact: No Impact
Action Offices: All San Francisco Regional and Area Offices
Originating Office: San Francisco Region Enforcement Programs
Contact: Paul Leary, Assistant Regional Administrator Enforcement
Programs
By and Under the Authority of
James D. Wulff
Regional Administrator
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TABLE OF CONTENTS
I. PURPOSE..................................................................................................3
II. SCOPE...........................................................................................................3
III. REFERENCES.............................................................................................3
IV. CANCELLATIONS..........................................................................................4
V. EXPIRATION..................................................................................................4
VI. STATE PLAN IMPACT.....................................................................................4
VII. BACKGROUND.................................................................................................4
VIII. OBJECTIVE..................................................................................................6
IX. SCOPE OF REP.............................................................................................7
X. DEFINITIONS..............................................................................................8
XI. ROLES AND RESPONSIBILITIES...................................................................9
XII. POLICY......................................................................................................10
XIII. INSPECTION PROCESS......................................................................................11
XIV. RECORDING IN OIS....................................................................................16
XV. OUTREACH...............................................................................................17
XVI. PARTNERSHIP AND ALLIANCES.................................................................18
XVII. EVALUATIONS...........................................................................................18
XVIII. WHISTLEBLOWER PROTECTIONS...............................................................18
APPENDIX A: FIRST AID FOR HEAT STRESS...........................................................19
APPENDIX B: TARGETED INDUSTRIES...................................................................22
APPENDIX C: SAMPLE AVD FOR HEAT-RELATED 5(A)(1) VIOLATION........................28
APPENDIX D: SAMPLE HAZARD ALERT LETTER (HAL)............................................30
APPENDIX E: CSHO PRE-INSPECTION CHECKLIST..................................................31
APPENDIX F: ADDITIONAL RESOURCES................................................................34
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I. Purpose
This Instruction establishes a regional emphasis program (REP) for conducting
heat illness inspections of indoor and outdoor hazardous work activities. It
expands on the agency's ongoing heat-related illness prevention campaign by
setting forth the enforcement component regardless of the temperature at the
time of the enforcement activity and reiterating its compliance assistance and
outreach efforts. Employers will be encouraged to implement proactive
interventions, such as water, rest, and shade, and other important prevention
measures such as acclimatization of new or returning workers.
II. Scope
This Instruction applies to Federal enforcement activities in the San Francisco
Region.
III. References
A. OSHA Instruction CPL 04-00-002, Procedures for Approval of Local
Emphasis Programs (“LEPs”), November 13, 2018, or current update.
B. OSHA Instruction CPL 02-00-164, Field Operations Manual (FOM), April
14, 2020, or current update.
C. OSHA Instruction CPL 02-00-025, Scheduling System for Programmed
Inspections, January 4, 1995, or current update.
D. OSHA Instruction CPL 02-00-051, Enforcement Exemptions and
Limitations under the Appropriations Act, May 28, 2005, or current update.
E. Criteria for a Recommended Standard: Occupational Exposure to Heat
and Hot Environments, DHHS (NIOSH) Publication Number 2016-106,
February 2016.
F. OSHA Directive TED 01-00-015, OSHA Technical Manual – Section III,
Chapter 4 – Heat Stress, (September 15, 2017).
G. OSHA Safety and Health Topic Page Occupational Heat Exposure
H. OSHA’s Heat Illness Prevention Campaign
I. OSHA-NIOSH Heat Safety Tool – Smartphone Application
J. OSHA Technical Manual (OTM), Section III: Chapter 4
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K. Fact Sheet: Biden Administration Mobilizes to Protect Workers and
Communities from Extreme Heat
L. Executive Order (EO) 14008, January 27, 2021, Tackling the Climate
Crisis at Home and Abroad
M. U.S. Department of Labor Climate Action Plan, September 2021, pgs. 6-7
N. OSHA Instruction CPL 03-00-024, National Emphasis Program – Outdoor
and Indoor Heat-Related Hazards Information, April 8, 2022, or current
update
IV. Cancellations
This instruction cancels all previous San Francisco Regional Instructions and
memoranda on this subject.
V. Expiration
This Instruction will expire on September 30, 2027, but may be renewed as
necessary.
VI. State Plan Impact
None.
VII. Background
The U.S. Department of Labor’s Bureau of Labor Statistics (BLS) reports that
from 2011 to 2019, environmental heat cases resulted in an average of 38
fatalities per year and an average of 2,700 cases with days away from work.
Heat related illnesses range from heat cramps to heat stroke, which can lead to
death. Between 2015 and 2020, federal OSHA conducted approximately 200
heat-related inspections each year, with about 15 heat-related fatality inspections
annually. Many of these inspections resulted in OSHA citations under the general
duty clause, Section 5(a)(1) of the OSH Act, for exposing workers to heat-related
hazards. However, the total number of heat-related fatalities may be
underreported. The cause of death is often listed as a heart attack when the
actual cause may have been exposure to a heat-related hazard. Since 2013,
former Region IX (now known as part of the San Francisco Region) has
conducted four heat-related fatality investigations. Between October 1, 2015, and
May 1, 2022, approximately 5% of the complaints received by the former Region
IX and X Area Offices within the San Francisco Region included alleged heat
related hazards. Considering that outdoor heat is not a year-round concern, this
number is significant.
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This REP is part of a broader Department of Labor response to President Biden’s
Executive Order (EO) 14008, “Tackling the Climate Crisis at Home and Abroad.”
EO 14008 established an interagency effort and commitment to workplace
safety, climate resilience, and environmental justice. In response, the US
Department of Labor has developed the Climate Action Plan, where the
Secretary of Labor has established a goal of reducing heat-related illnesses.
OSHA’s initial enforcement response to the President’s order was to issue a heat
initiative memorandum on September 1, 2021, instructing the Regional Offices to
increase their efforts to prioritize heat complaints and referrals and to intervene
when they become aware of heat hazard conditions. On April 8, 2022, OSHA
initiated a National Emphasis Program to ensure that employees in high-hazard
industries are protected from heat-related hazards, both indoors and outdoors,
that may lead to serious illnesses, injuries, or death. This REP expands on the
NEP to include additional industries outside the NEP with a documented history
of heat stress hazard exposures within the San Francisco Region, regardless of
the temperature. This REP further specifies additional industries in the San
Francisco Region where heat hazards exist and provides a mechanism for
identifying hazards and compelling abatement in those industries using targeted
outreach and compliance assistance.
Serious heat-related illnesses can occur when an unacclimated person has a
body temperature that exceeds 100.4 degrees Fahrenheit (100.4°F). Fatal heat-
related incidences are usually the result of exertional heat stroke, where physical
activity in hot environments causes the body temperature to reach 104°F or
higher (normal body temperature is around 98.6°F). Appendix A provides a list of
serious heat-related illnesses, along with common signs and symptoms, and
appropriate first aid procedures. Heat-related illnesses occur when body heat
generated by physical work is performed in conditions of high ambient heat,
especially when combined with humidity and inadequate cooling. Combinations
of heat and humidity are used to determine the commonly used "feels like" (i.e.,
or heat index, or HI) temperature. The National Weather Service (NWS) uses
heat index to classify environmental heat into four categories: Caution (80°F -
90°F HI), Extreme Caution (91°F - 103°F HI), Danger (103°F - 124°F HI), and
Extreme Danger (126°F or higher HI). (Heat Index and other relevant terms are
defined in paragraph X. Definitions.)
The National Institute for Occupational Safety and Health (NIOSH) has published
recommended occupational exposure limits and controls for heat stress. A
NIOSH publication, Criteria for a Recommended Standard: Occupational
Exposure to Heat and Hot Environments, outlines recommended
environmental limits for physical work at which point engineering controls,
preventative work, hygienic practices, and administrative or other control
procedures should be implemented to reduce the risk of heat-related illnesses.
NIOSH has a Recommended Alert Limit (RAL) and a Recommended Exposure
Limit (REL) based on the Wet Bulb Globe Temperature (WBGT).
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While all alerts and advisories can serve to signify 'heat priority days' (i.e., days
in which a maximum heat temperature can result in increased risks of heat-
related illnesses), these criteria vary across the country. In areas of the United
States that are not usually subject to elevated dangerous heat conditions,
unacclimatized workers may suffer serious heat- related illnesses even when the
heat index is not high enough to trigger NWS heat advisories or warnings.
When the heat index exceeds 80°F, serious occupational heat-related illnesses
and injuries become more frequent, especially when unacclimatized workers are
performing heavy strenuous work (e.g., intense arm and back/lifting work,
carrying, shoveling, manual sawing, pushing and pulling heavy loads and walking
at a fast pace), without easy access to water or shade, or working in direct
sunlight. Heat-related fatalities have occurred with a heat index below 80°F,
particularly when these aggravating factors are present.
This initiative identifies heat priority days as those days when the National
Weather Service forecasts that the heat index will be 80° F or above on its
website. A heat index at this level indicates a need to increase enforcement
efforts to identify potential heat-related hazards present in working conditions
before the occurrence of an illness or death.
Section 5(a)(1) of the OSH Act states that employers shall provide to their
employees “employment and a place of employment which are free from
recognized hazards that are causing or are likely to cause death or serious
physical harm”. This includes a duty to prevent heat-related illnesses, injuries,
and deaths in workplaces. Hot temperatures create excessive heat working
conditions that are especially dangerous to workers who have not been
acclimatized. Acclimatization is a process by which a person gradually increases
their exposure time in hot environmental conditions, causing beneficial
physiological changes to prevent heat-related illnesses by properly regulating
body temperature. It is essential for employers of new or returning workers to
gradually increase their workloads and ensure more frequent breaks as they
acclimatize to ambient conditions. However, the most successful efforts to
prevent heat-related illnesses and deaths include more than just worker
acclimatization programs. A resource for best practices on worker acclimatization
is the American Conference of Governmental Industrial Hygienists (ACGIH®)
Action Limit (AL) for unacclimatized workers and a Threshold Limit Value (TLV®)
for acclimatized workers, see Heat Stress and Strain: TLV® Physical Agents
2021 or current edition. Employers should use a combination of intervention
methods, including encouraging or mandating that employees regularly take
breaks for rest, shade, and supply water. Employers should train employees on
heat-related illnesses, how to spot common symptoms, and what to do when a
worker suspects a heat-related illness is occurring. Employers should also take
periodic temperature measurements to determine employees' heat exposure and
provide protection to employees from heat, as necessary.
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VIII. Objective
The purpose of this REP is to prevent occupational exposure to conditions
creating heat stress. This REP is targeted at keeping employees from developing
heat cramps, heat exhaustion, and heat stroke. Evidence from the Department of
Labor, Centers for Disease Control, and NIOSH, shows that elevated
environmental temperatures cause hundreds of employees working both indoors
and outdoors to experience heat-related illnesses and deaths annually.
Excessive heat occurs from a combination of elevated temperatures, moderate
or higher workloads, and high humidity. At certain levels of work, heat, and
humidity, the human body cannot maintain a normal internal temperature and
may experience a heat illness, including a fatal heat stroke.
To prevent these illnesses and injuries, OSHA will utilize weather forecasts to
determine days with hazardous heat conditions. OSHA will endeavor to ensure
employers take appropriate precautions to address heat hazards. These heat
illness precautions include: (1) training employees on the hazards of hot
environmental temperatures, and procedures for responding to and reporting
heat illness or injury (2) making appropriate first aid available, (3) having
drinking water available, (4) having shade or a climate-controlled (i.e. air
conditioning) area for rest breaks, (5) having a protocol to protect and
acclimatize new workers and those who have just returned from an extended
absence, because these workers are particularly vulnerable, and (6) having
made provisions for prompt medical attention if a heat-related illness occurs.
This instruction is provided to address the unsafe working conditions created by
heat hazards and inappropriate safety procedures.
IX. Scope of REP
This instruction applies to indoor and outdoor worksites in the San Francisco
Region where potential heat-related hazards exist. Working conditions that have
resulted in serious heat-related illnesses occur in all major industry sectors of
employers, including general industry, construction, agriculture, and maritime.
Typical indoor worksites where heat-related illnesses may occur include electrical
utilities (particularly boiler rooms), bakeries, confectioneries, commercial
kitchens, laundries, food canneries, warehouses without adequate climate
control, chemical plants, and smelters.
The outdoor work activities impacted by heat under the jurisdiction of federal
OSHA in the San Francisco Region include National Security; Water Supply and
Irrigation Systems; Landscape Architectural Services; Nonferrous Metal (except
Aluminum) Smelting and Refining; Secondary Smelting, Refining, and Alloying of
Nonferrous Metal (except Copper and Aluminum); Administration of Conservation
Programs; National Parks and Other Similar Institutions; Support Activities for
Forestry; the Postal Service; Couriers and Express Delivery Services; and any
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other activities that require moderate to high physical exertions or the wearing of
heavy and/or bulky clothing or equipment on a hot day. See Appendix B for all
covered industries.
X. Definitions
A. Heat Index - A measure indicating the level of discomfort the average
person is thought to experience because of the combined effects of the
temperature and humidity of the air.
B. Wet Bulb Globe Temperatures - a measure of heat stress which considers
temperature, humidity, wind speed, sun angle and cloud cover (solar
radiation). This differs from the heat index, which takes into consideration
temperature and humidity and is calculated for shady areas. For work or
exercise in direct sunlight, this is a good element to monitor. Military
agencies, OSHA, and many nations use the WBGT as a guide to manage
workload in direct sunlight.
C. OSHA-NIOSH Heat Safety Tool - a useful resource for planning outdoor
work activities based on how hot it feels throughout the day. Features
include real-time heat index and hourly forecasts, by specific locations,
and occupational safety and health recommendations from OSHA and
NIOSH.
D. Heat Advisory - A Heat Advisory is issued within 12 hours of the onset of
extremely dangerous heat conditions. The general rule of thumb for this
Advisory is that the maximum heat index temperature is expected to be
100°F or higher for at least 2 days, and nighttime air temperatures will not
drop below 75°F.
E. Heat Wave - A heat wave is forecast by NWS or a local news station. A
heat wave is when the daily maximum temperature exceeds 95°F or when
the daily maximum temperature exceeds 90°F and is 9°F or more above
the maximum reached on the preceding days.
F. Excessive Heat Warning - An Excessive Heat Warning is issued within 12
hours of the onset of extremely dangerous heat conditions. The general
rule of thumb for this Warning is that the maximum heat index temperature
is expected to be 105°F or higher for at least 2 days and nighttime air
temperatures will not drop below 75°F.
G. Excessive Heat Watches - Heat watches are issued when conditions are
favorable for an excessive heat event in the next 24 to 72 hours. A Heat
Watch is used when the risk of a heat wave has increased but its
occurrence and timing is still uncertain.
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H. Excessive Heat Outlooks - Outlooks are issued when the potential exists
for an excessive heat event in the next 3-7 days. Outlook provides
information for those who need considerable lead-time to prepare for the
event.
I. Heat Priority Days - Days when the National Weather Service forecasts
that the Heat Index will be 80° F or above on its website.
XI. Roles and Responsibilities
A. Area Office
1. Role of the Compliance Safety and Health Officers (CSHOs): On
heat priority days, the CSHO should be aware of the potential for
heat-related illnesses during inspection activities and will
investigate heat-related hazards where appropriate. The CSHO
must take time to develop the best strategy to gather and document
each prima facie element and determine whether additional
resources or assistance may be necessary. The CSHO shall utilize
the information provided in the appendices of this instruction to
develop heat stress cases. The CSHO shall ensure that each
violation is cited in accordance with this Instruction and Chapter 4
of the FOM.
Area Offices should work with the Regional Office to contact the
Office of Occupational Medicine and Nursing early in the inspection
(especially in fatality or hospitalization cases) to obtain Medical
Access Orders, if needed, and for technical assistance from the
Health Response Team on the use of WBGT instrumentation. The
Regional Office may also contact the Directorate of Enforcement
Programs, Office of Health Enforcement, for assistance with
enforcement policy.
2. Role of the Area Director (AD): Upon notification of a potential heat
related case, the AD should confer with the CSHO and provide
guidance and assistance if necessary. The AD will also ensure the
CSHO is prepared to be in elevated temperature conditions
themselves and have the necessary personal protective equipment
available. The AD should conduct “go/no-go” checks throughout the
inspection process to validate or appropriately guide the CSHO in
developing violation(s). Following the completion of fieldwork, the
AD shall review the violation(s) prior to submission to the OEP. The
AD shall ensure that each violation is cited in accordance with this
Instruction and Chapter 4 of the FOM.
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B. Regional Office
1. Role of the Regional Administrator (RA): The RA has the approval
authority for all heat related cases and will resolve any
disagreements that may develop between OEP and the AD
regarding the evaluation of the violation(s). The RA refers heat
cases to the Directorate of Enforcement Programs (DEP) for any
novel case processing, review and approval where required.
2. Role of the Office of Enforcement Programs (OEP): It is the role of
OEP to conduct a critical review of all violations to ensure that any
proposed violations are supported by the documentation in the
casefile. OEP will work with the AD to strengthen the violation(s)
and obtain needed technical information. OEP will reach out to
OOMN, as necessary. OEP will coordinate with RSOL to resolve
any legal and factual issues that surface during the review. OEP
works directly with DEP to resolve concerns where National Office
approval is required.
3. Role of the Regional Heat Coordinator (Regional Industrial
Hygienist): The Regional Heat Coordinator is responsible for
assisting CSHOs and Area Offices to develop heat-related
enforcement actions, monitoring the status of all heat inspections
within the region, and coordinating the field staff training program.
4. Office of Solicitor (RSOL): RSOL will provide guidance throughout
the development of the violation. RSOL will work with OEP to
resolve any legal and factual issues that surface.
XII. Policy
A. At any time of the year the scope of other programmed inspections can be
expanded to address heat-related hazards where worksite conditions or
other evidence, such as heat priority days, suggest there could be heat
hazards.
B. OSHA 300 logs shall be analyzed for heat related illnesses where heat-
related hazards may be present.
C. Prior to submittal to the Assistant Regional Administrator of Enforcement
Programs (hereinafter referred to as ARA-EP), the AD shall thoroughly
review all proposed violations. All considerations in this instruction will be
evaluated prior to regional review.
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D. A Hazard Alert Letter (hereinafter HAL) may be proposed where all the
elements of a general duty clause violations are not present. See Chapter
4, Section III.F.2.b of the FOM.
E. All proposed violations and HALs under this REP shall be submitted to the
ARA-EP for review and concurrence prior to issuance.
F. If the CSHO learns of previous or potential exposures to elevated
environmental heat, the CSHO shall evaluate to determine the existence
of a hazard warranting a violation or HAL. If the CSHO believes that a
violation or HAL cannot be supported, the CSHO should alert the
employer to areas of concern and provide the employer with information
on how to develop an effective heat-illness prevention program. This could
be done in the form of an intervention package and entered into OIS as an
intervention. This approach allows the agency to initiate heat-related
assessments throughout the year despite the temperature and to influence
employers' implementation of early interventions to prevent illnesses and
deaths among workers who are most at-risk.
G. OSHA interventions, i.e., having discussions with employers about
important steps they can take and providing heat posters and other
outreach materials, are critical to mitigating potential hazards and
preventing heat-illnesses before they occur. Inspections should be
completed and citations, if any, should be issued expeditiously to facilitate
prompt abatement.
XIII. Inspection Process
A. Procedures
1. Area Office Responsibilities
a. The Area Office will develop a program to monitor weather data
within its jurisdiction, paying close attention to publicized heat
advisories, watches, warnings, and/or heat waves to proactively
address heat hazards in targeted areas.
b. Heat-related inspections should be reported to the regional heat
coordinator as soon as possible.
c. Area Offices should work with the Regional Office to contact the
Office of Occupational Medicine and Nursing early in the
inspection (especially in fatality or hospitalization cases) to obtain
Medical Access Orders, if needed, and for technical assistance
from the Health Response Team on the use of WBGT
instrumentation. The Regional Office may contact the Directorate
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of Enforcement Programs, Office of Health Enforcement, for
assistance with enforcement policy.
2. Area Director Responsibilities
a. Instruct CSHOs traveling in the field on heat priority days to be alert
to circumstances where employees may be performing moderate or
strenuous work in hot conditions and to conduct an onsite referral
inspection.
b. Instruct CSHOs to assess the potential for heat-related illnesses
during all inspections and review the employer’s heat illness
prevention plan where appropriate.
3. CSHO Responsibilities
a. CSHOs should use the OSHA-NIOSH Heat Safety App as a
resource. This app provides current and projected heat indices for
that day at the current location. The display indicates the hazard
levels as caution, warning or danger in heat index ranges and
offers recommended actions to protect workers. NWS provides
certified historic weather data to document conditions at the time of
an incident and prior days.
b. Review OSHA 300 logs for any entries indicating heat-related
illness(es).
c. Review injury and illness reports and obtain any records of any
hospitalizations and corresponding reporting requirements. Also
review any reports indicating emergency room visits and/or
ambulance transport, even if hospitalizations did not occur.
d. Interview workers for reports of headache, dizziness, fainting,
dehydration, or other symptoms that may indicate heat-related
illnesses.
e. Review employer's plan to address heat exposure, including
acclimatization procedures (especially for new and returning
workers), work-rest schedules, access to shade and water (with
electrolytes when needed), and any training records associated
with implementing a heat illness prevention program.
f. Document, where possible, the heat index on the OSHA-NIOSH
Heat App, using the screen save feature on a mobile phone or
tablet.
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g. On heat priority days, CSHOs should be prepared to conduct
WBGT sampling during programmed planned inspections when
they observe work activities.
h. Explore emergency response planning:
• Is someone trained to recognize dizziness, confusion, or
other symptoms suggestive of heat stroke?
• Is there access or planning for access to shade (air
conditioning, vehicle cabs, tents, etc.?
• Is someone authorized to call 911 in situations where
confusion and or confused speech occurs? Is there a plan to
deal with heat stroke?
Note: WBGT readings will be in accordance with procedures on
conducting WBGT sampling and performing workplace
assessments, OSHA Technical Manual, Section III, Chapter 4.
WBGT sampling is considered a more accurate indicator of the
effects of heat on individuals than dry bulb thermometer readings.
Dry bulb readings measure air temperature only. When appropriate,
CSHOs should also conduct workload assessments through direct
observation of work practices/operations and employee interviews.
They should particularly note if heavy or bulky clothing or
equipment is used. The information obtained from employer and
employee interviews should be verified during the walkaround
inspection.
i. Identify conditions and activities relevant to heat-related hazards.
These can include, but are not limited to:
• Potential sources of heat-related illnesses (e.g., working in
direct sunlight, a hot vehicle, areas with hot air, near a gas
engine, furnace, boiler, or steam lines).
• WBGT calculations and/or other temperature
measurements.
• Heat advisories, warnings, or alerts.
•
The use of heavy or bulky clothing or equipment.
• The types of activities performed by the employees and
whether those activities can be categorized as moderate,
heavy, or very heavy work.
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•
The length of time in which a worker is continuously or
repeatedly performing moderate to strenuous activities.
• Heat-related illnesses among new workers. The presence
of any recent vacation time or breaks in employment
prior to complaints of heat-related symptoms.
• The availability of rest breaks, water, and shade on site.
B. Exemptions and Limitations
Before initiating enforcement activities, the CSHO will determine if an
inspection is limited through OSHA Instruction CPL 02-00-051,
“Enforcement Exemptions and Limitations under the Appropriations Act.”
Health inspections are not affected by exemptions under this directive.
C. Interface with Other Inspection Activities
Several OSHA standards may also be applicable to address certain
aspects of worker protection in hot environments including, but not limited
to, use of personal protective equipment, sanitation, medical services and
first aid, and recordkeeping.
The Recordkeeping regulation at 29 CFR §1904.7(b)(5) requires that
employers record certain work-related injuries and illnesses. If a worker
requires medical treatment beyond first aid, the worker's illness or injury
must be recorded. However, if a worker merely requires first aid treatment
for the worker's condition, the employer is not required to record the
condition. For example, if a worker becomes unconscious, the worker's
condition must be recorded. However, if a worker is only instructed to
drink fluids for relief of heat stress, the worker's condition is not
recordable. Refer to 29 CFR §1904.7(b)(5) for an explanation of the
difference between medical treatment and first aid. Recordkeeping issues
must be managed in accordance with OSHA Instruction, CPL 02-00-135.
The Sanitation standards at 29 CFR §1910.141, 29 CFR §1915.88, 29
CFR §1917.127, 29 CFR §1918.95, 29 CFR §1926.51, and 29 CFR
§1928.110 require employers to provide potable water.
The general construction safety training and education standards for
construction at 29 CFR §1926.21 and 29 CFR §1926.20 require a Safety
and Health Program as well as frequent and regular safety and health
inspections.
Follow-up inspections, referrals, complaints, fatalities, and catastrophes
will still be inspected under procedures outline in the FOM.
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D. Basis of Inspection
Whenever an inspection is begun under this REP, the CSHO will include
in the casefile narrative a description of the circumstances which initiated
the inspection.
E. Size of Employer
Establishments with ten or fewer employees will be included in this
program because of the hazardous nature of high environmental
temperatures. Safety violations discovered under this program will be
addressed in accordance with CPL 02-00-051 (CPL 2-0.51J)
“Enforcement Exemptions and Limitations under the Appropriations Act.”
F. VPP and Partnership Sites
If an employer and/or contractor are a Voluntary Protection Program
(VPP) employer or have passed an annual OSHA Partnership verification
inspection, the terms of the VPP and/or partnership agreement will be
followed. A list of current VPP sites and partnerships within the Area
Office jurisdiction will be maintained and made available for CSHO review.
G. Citations
Citations for violations will be issued in accordance with the FOM,
Chapters IV, V, VI and VII. A citation for failure to provide an adequate
heat illness prevention program will be addressed under the General Duty
Clause or 29 CFR 1960.8 for federal agencies.
Any proposed citation for heat-related hazards, where the employer's
procedures to protect workers are inadequate, will be issued under the
General Duty Clause ("GDC"), Section 5(a)(1) of the OSH Act or 29 CFR
1960.8 for federal agencies. Citations for heat related hazards will be
issued for both indoor and outdoor work activities when all elements of a
GDC violation are established. CSHOs should document the relationship
between the workplace exposure(s) and the potential for heat-related
illness(es), specifically including all conditions and activities that present
heat-related hazards.
Ensure that the hazard is clearly described in the citation and avoid solely
describing an employer's failure to implement specific heat stress
abatement measures. The Regional Solicitor's office will be consulted prior
to issuing any heat-related 5(a)(1) citations. A sample Alleged Violation
Description (AVD) for a heat-related illness 5(a)(1) violation is in Appendix
C.
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A Hazard Alert Letter (HAL) may be sent when all the elements of a GDC
violation are not present. A sample Hazard Alert Letter (HAL) is in
Appendix D and in OIS respectfully. Issuance of citations or HALs should
be expedited so abatements can be implemented and achieved earlier to
protect other employees exposed to the hazard.
H. Inspection Resources
All OSHA personnel participating in this REP must be familiar with the
policies and procedures described in this instruction.
I. CSHO Personal Protective Equipment (PPE)
CSHOs shall use personal protective equipment suitable for general
industry or construction inspections.
XIV. Recording in OIS
A. Enforcement Inspections
Enforcement inspections completed under this initiative will be coded in
OIS in the inspection Type sub-tab as follows:
1. Initiating Type will be coded “Programmed Planned” except when the
inspection is conducted because of a complaint, referral, or
fatality/catastrophe. These will be coded as the appropriate
“unprogrammed” activity.
2. Local Emphasis Program will be coded with SFOHEAT for all
programmed and unprogrammed inspections.
3. Where an establishment is within a targeted NAICS under the Outdoor
and Indoor Heat-Related Hazards National Emphasis Program it will
also be coded HEATNEP.
4. Additional Codes will be coded to indicate the industry type as follows:
Types ID Value Industry
N 02 HEATCON Construction
N 02 HEATGI General Industry
N 02 HEATMT Maritime
N 02 HEATAG Agriculture
N 02 HEATLNGSHR Longshoring
B. Compliance Assistance Interventions
16

Interventions completed under this initiative will be coded as compliance
assistance as follows:
1. Regional Emphasis Program will be coded as SFOHEAT.
2. Where an establishment is within a targeted NAICS under the Outdoor
and Indoor Heat-Related Hazards National Emphasis Program it will
also be coded HEATNEP.
3. Other Emphasis Areas will include any applicable additional codes and
the codes specific to the construction, general industry, maritime or
agriculture activity covered by the inspection per XIV.A.4.
C. Data Accuracy
Area Offices and the Regional Office shall periodically check their OIS
databases to verify accuracy of the data for the initiative.
XV. Outreach
All REPs must contain an outreach component that must be ongoing throughout
the effective period of the program. These outreach efforts should be coordinated
with or include the consultation program for the area. However, OSHA has
continually conducted outreach at the National, Regional, and Area Office levels
through the heat campaign that was first initiated in 2011, so this requirement
has been met.
A. Outreach Methods
Methods at the Area Director’s discretion can consist of one or more of the
following:
1. Broadcast mail-outs for program information
2. Stakeholder meetings
3. Targeted training sessions
4. Presentations to the affected group(s)
5. OSHA heat exposure website
B. Outreach During Inspections
During heat inspections, CSHOs should provide employers and
employees with information about available education and training
resources and publications, as appropriate. CSHOs should provide
employers and employees with materials highlighting heat illness
prevention in English and Spanish, or other languages, as applicable and
available. They should also recommend employers and employees visit
the OSHA Heat Illness exposure webpage for additional resources.
17

C. All outreach activities shall be entered into OIS and coded appropriately.
XVI. Partnership and Alliances
In the event outreach efforts result in interested groups developing an alliance or
partnership, the Area Director will ensure that these efforts conform to current
National and Regional Policy.
XVII. Evaluations
The Regional Office will evaluate the impact of the REP at the midpoint of the
program as well as at the expiration. Information and data from OIS along with
input from the Area Director will be used in the program report. Elements to be
considered in the evaluation are contained in OSHA Instruction CPL 04-00-002.
XVIII. Whistleblower Protections
Workers requesting inspections, complaining of heat-related exposure, or
reporting illnesses or retaliation, may be covered under one or more
whistleblower protection statutes. Inform the workers of their protections from
retaliation and refer them to www.whistleblowers.gov for more information,
including how to file a retaliation complaint. If the worker is alleging some form of
retaliation, the AO must submit a referral to the Regional Whistleblower
Protection Program.
Appendix A: First Aid for Heat Stress
The NIOSH website provided the reference information below:
18

Heat Rash: skin irritation caused by excessive seating during hot, humid
weather.
Symptoms of heat rash include:
Red clusters of pimples or small blisters.
More likely to occur on the neck and upper chest, in the groin, under the
breasts and in elbow creases.
Workers experiencing heat rash should:
Try to work in a cooler, less humid environment when possible.
Keep the affected area dry.
Dusting powder may be used to increase comfort.
Heat Cramps: affect workers who sweat a lot during strenuous activities. This
sweating depletes the body’s salt and moisture levels. Low salt levels in muscles
causes painful cramps. Heat cramps may also be a symptom of heat exhaustion.
Symptoms of heat cramps include:
Muscle pain or spasms are usually in the abdomen, arms, or legs
Workers with heat cramps should:
Stop all activity and sit in a cool place.
Drink clear juice or a sport drink.
Do not return to strenuous work for a few hours after the cramps subside
because further exertion may lead to head exhaustion or heat stroke.
Seek medical attention if any of the following apply:
o The worker has heart problems.
o The worker is on a low sodium diet.
The cramps do not subside within one hour.
Heat Syncope: fainting (syncope) episode or dizziness that usually occurs with
prolonged standing or sudden rising from a sitting or lying position. Factors that
may contribute to heat syncope include dehydration and lack of acclimatization.
Symptoms of heat syncope include:
 Light-headedness
 Dizziness
 Fainting
 Heavy sweating
Extreme weakness or fatigue
Dizziness or light-headedness
 Nausea
19

Clammy, moist skin
Pale or flushed complexion
 Muscle cramps
Slightly evaluated body temperature
Fast and shallow breathing
Workers with heat syncope should:
Sit or lie in a cool place when they begin to feel symptoms.
Slowly drink water, clear juice, or a sports beverage.
Heat Exhaustion: the body's response to an excessive loss of water and salt,
usually through excessive sweating. Workers most prone to heat exhaustion are
those that are elderly, have high blood pressure, and those working in a hot
environment.
Symptoms of heat exhaustion include:
Heavy sweating
Extreme weakness or fatigue
Dizziness or lightheadedness
 Nausea
Clammy, moist skin
Pale or flushed complexion
 Muscle cramps
Slightly elevated body temperature
Fast and shallow breathing
Treat a worker suffering from heat exhaustion with the following:
Have them rest in a cool, shaded, or air-conditioned area.
Have them drink plenty of water or other cool, nonalcoholic beverages.
Have them take a cool shower, bath, or sponge bath.
Heat Stroke: the most serious heat-related disorder. It occurs when the body
becomes unable to control its temperature: the body's temperature rises rapidly,
the sweating mechanism fails, and the body is unable to cool down. When heat
stroke occurs, the body temperature rises to 104°F or higher. Heat stroke victims
have brain dysfunction that causes mental changes. Heat stroke can cause
death or permanent disability if emergency treatment is not given.
Symptoms of heat stroke include:
 Confusion
Slurred speech
 Unconsciousness
 Hallucinations
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 Seizures
Hot, dry skin (no sweating) or heavy sweating
 Chills
Throbbing headache
High body temperature
Take the following steps to treat a worker with heat stroke:
Call 911 and notify their supervisor.
Move the sick worker to a cool shaded area.
Cool the worker aggressively using methods such as:
i. Immersing them in water.
ii. Removing their clothes and covering them with towels soaked with
water.
iii. Spraying, sponging, or showering them with water.
iv.Fanning their body.
21

Appendix B: Targeted Industries
Heat-related hazards can be found in every industrial sector, including general industry,
construction, maritime, and agriculture. To increase the likelihood of preventing heat-
related illnesses and make efficient use of OSHA resources, OSHA compliance officers
should inquire about heat illness prevention programs during any inspection, regardless
of the actual temperature.
Appendix B includes three tables of industries (NAICS codes at the 4-digit level) with
the following: 1) High numbers or high incidence rates of heat related illnesses from
Bureau of Labor Statistics (BLS) data; 2) Elevated number of days away from work
(BLS) or high numbers of severe cases of heat related illnesses as indicated by death
or hospitalization (from OSHA severe injury reports made by employers), or an OSHA
heat inspection since 2018. Table 1 are non-construction industries in ListGen, Table 2
are construction industries and Table 3 are non-construction industries not found in
ListGen.
NOTE: It should not be assumed that employee exposure to heat occurs in all
establishments within the industries listed in the tables below. The AO may delete from
their target list any establishment that does not have an exposure to heat-related
hazards or an establishment that has had a comprehensive or partial health inspection
that addressed heat hazards with an Opening Conference date occurring within the
twelve (12) previous months.
Table 1. Non-construction industries that are in ListGen are likely to have heat-
related hazards.
2017 NAICS Code
(4-digit level)
2017 NAICS Title
1121 Cattle Ranching and Farming
1151 Support Activities for Crop Production
2131 Support Activities for Mining
3211 Sawmills and Wood Preservation
3241 Petroleum and Coal Products Manufacturing
3251 Basic Chemical Manufacturing
3272 Glass and Glass Product Manufacturing
3311 Iron and Steel Mills and Ferroalloy Manufacturing
3314
Nonferrous Metal (except Aluminum) Production and
Processin
g
3323 Architectural and Structural Metals Manufacturing
22

3329 Other Fabricated Metal Product Manufacturing
3361 Motor Vehicle Manufacturing
3362 Motor Vehicle Body and Trailer Manufacturing
3363 Motor Vehicle Parts Manufacturing
3364 Aerospace Product and Parts Manufacturing
3365 Railroad Rolling Stock Manufacturing
3366 Ship and Boat Building
3369 Other Transportation Equipment Manufacturing
3371
Household and Institutional Furniture and Kitchen Cabinet
Manufacturing
4239 Miscellaneous Durable Goods Merchant Wholesalers
4241 Paper and Paper Product Merchant Wholesalers
4242 Drugs and Druggists' Sundries Merchant Wholesalers
4243 Apparel, Piece Goods, and Notions Merchant Wholesalers
4244 Grocery and Related Product Merchant Wholesalers
4245 Farm Product Raw Material Merchant Wholesalers
4246 Chemical and Allied Products Merchant Wholesalers
4247 Petroleum and Petroleum Products Merchant Wholesalers
4248
Beer, Wine, and Distilled Alcoholic Beverage Merchant
Wholesalers
4249 Miscellaneous Nondurable Goods Merchant Wholesalers
4413 Automotive Parts, Accessories, and Tire Stores
4442 Lawn and Garden Equipment and Supplies Stores
4881 Support Activities for Air Transportation
4882 Support Activities for Rail Transportation
4883 Support Activities for Water Transportation
4884 Support Activities for Road Transportation
4889 Other Support Activities for Transportation
4921 Couriers and Express Delivery Services
4922 Local Messengers and Local Delivery
5311 Lessors of Real Estate
23

5617 Services to Buildings and Dwellings
5621 Waste Collection
5622 Waste Treatment and Disposal
5629 Remediation and Other Waste Management Services
6231 Nursing Care Facilities (Skilled Nursing Facilities)
7211 Traveler Accommodation
8111 Automotive Repair and Maintenance
8113
Commercial and Industrial Machinery and Equipment (except
Automotive and Electronic) Repair and Maintenance
8114 Personal and Household Goods Repair and Maintenance
The AO should use C-Target to find active construction sites to add to their list of heat
inspections from April 1 to October 31 or on a heat priority day (when the National
Weather Service forecasts that the Wet Bulb Globe Temperature will be 81° F or
above). (Note that if a project from the C-Target list is inspected, the Area Office must
account for all projects from that list by either inspection or deletion in accordance with
CPL 02-00-155). Where OSHA is conducting an inspection for other purposes, a heat-
related inspection shall be opened for all hazardous conditions observed in plain view
(such as, for example, employees or temporary workers in high exposure areas without
adequate acclimatization or access to water, rest, and shade).
Table 2. Construction industries that are likely to have heat-related hazards
1
.
2017 NAICS Code
(4-digit level)
2017 NAICS Title
2371 Utility System Construction
2372 Land Subdivision
2373 Highway, Street, and Bridge Construction
2379 Other Heavy and Civil Engineering Construction
2381 Foundation, Structure, and Building Exterior Contractors
2382 Building Equipment Contractors
2383 Building Finishing Contractors
1
Construction inspections (C-Target) or local list should be scheduled from a list of construction worksites rather
than construction employers, due to the mobility of the construction industry, the transitory nature of
construction worksites, and work that frequently involves more than one construction employer on the site.
24

2389 Other Specialty Trade Contractors
For certain industries not included in ListGen alternative sources may be utilized (e.g.,
ReferenceUSA). The AO should use local knowledge to add these industries in Table 3
to the inspections list.
Table 3. Industries not included in ListGen or Construction that are likely to have
heat-related hazards.
2017 NAICS Code
(4-digit level)
2017 NAICS Title
1112 Vegetable and Melon Farming
1113 Fruit and Tree Nut Farming
2213
Water, Sewage and Other Systems (maybe State or local
jurisdiction)
4411Automobile Dealers
4412 Other Motor Vehicle Dealers
4821 Rail Transportation (maybe Federal jurisdiction)
4885Freight Transportation Arrangement
4911Postal Service
5611Office Administrative Services
5612 Facilities Support Services
5613 * Employment Services
5614 Business Support Services
5615 Travel Arrangement and Reservation Services
5616 Investigation and Security Services
5619 Other Support Services
6117 Educational Support Services
8112Electronic and Precision Equipment Repair and Maintenance
9281
National Security and International Affairs (includes Customs
and Border Patrol, and Transportation Security Administration)
Table 4. Industries where heat related inspections have been conducted in former
Region IX Area Offices since 2012 and not included in ListGen or Construction
that are likely to have heat-related hazards.
25

2017 NAICS Code
(6-digit level)
2017 NAICS Title
236115
New Single-Family Housing Construction (except For-Sale
Builders)
236220 Commercial and Institutional Building Construction
311812Commercial Bakeries
322211 Corrugated and Solid Fiber Box Manufacturing
493110 General Warehousing and Storage
541320Landscape Architectural Services
541620 Environmental Consulting Services
561612 Security Guards and Patrol Services
722511Full-Service Restaurants
722513Limited-Service Restaurants
922140Correctional Institutions
928110 U.S. Customs and Border Patrol
*Note: Establishments within the Temporary Help Services (NAICS 5613) industry
should not be automatically included in the targeting list for programmed inspections.
Although this industry has been among the top industries with OSHA enforcement
activities related to heat, this has primarily occurred where services occurred at a high-
hazard host. Therefore, to effectively address heat-illness hazards for Temporary Help
Services, where OSHA is conducting an inspection for other purposes, a heat-related
inspection shall be opened for all hazardous conditions observed in plain view (such as,
for example, temporary employees working in high exposure areas without adequate
acclimatization or access to water, rest, and shade).
Sources for injury and illness data:
I.Bureau of Labor Statistics (BLS) Fatality cases 2015-2019 due to exposure to
heat
II.BLS days away from work cases, incidence rates, and median days away from
work 2015-2019 due to exposure to heat
II I.OSHA severe injury reports of fatalities and hospitalizations 2018-2020.
Hospitalization reports include all employer-reported referrals with Event Title
"Exposure to Environmental Heat”. Fatality reports include all fatality
investigations with victim type "Fatality-OSHA Covered" and any of the following
26

public page keywords: Heat Stroke, Heat Exhaustion, Heat-Related Illness, High
Temperature, Overheated, Heat.
IV.OSHA inspections 2018-Aug 2021, inspections with additional codes, HEATGI,
HEATCON, HEATMI, or HEATAG.
V.OSHA Inspections 2016-Sept 2021, inspections with a general duty keyword of
HEAT.
VI.OSHA Hazard Alert Letters and 5a1 citations, 2018-Aug 2021, violations with the
“Heat” General Duty Clause keyword.
27

Appendix C: Sample AVD for Heat-Related
5(a)(1) Violation
The 5(a)(1) AVD language for heat related hazard violations of Section 5(a)(1) must
specify the heat related hazard, such as the source of heat (e.g. environmental
temperature measurements and information on heat-generated equipment), including
any specific workplace conditions or practices making exposes employees vulnerable
to a likelihood of heat-related illness (e.g., performing moderate to very hard roofing
work, dumping heavy refuse bins while running behind a sanitation truck, wearing
impermeable protective clothing, and lack of acclimatization of new or returning
workers), as applicable. The alleged heat-related hazard descriptions should not
include the employer’s failure to implement any specific abatement measures such as
acclimatizing workers for the heat, failure to provide drinking water, shade or air
conditioning, or training workers on heat stress.
Sample AVD:
On or about and at times prior to [the date of the incident], employees were exposed to
the recognized hazard of high ambient heat from [list sources of and conditions of
ambient heat, such as direct sun, boiler, steam, furnace, combustion engine] during the
performance of their job duties, including [describe specific task(s)].
[Describe temperature, relative humidity, WBGT measurements and calculations, and
any aggravating factors such as heavy or bulky clothing, duration of exposure, direct
sunlight, and level of workload. Include any NOAA heat advisory or alert that supports
a high ambient
hazardous heat condition and WBGT if known]. Such exposures are likely to lead to the
development of serious heat-related illnesses such as, but not limited to, heat cramps,
heat stress, heat exhaustion and heat stroke. [Describe any heat-related incidents/
illness that occurred].
Where the information is available and applicable to the ins
pection, the case file should
document factors such as the employer's knowledge of the hazard, the reading on the OSHA-
NIOSH App (use the camera screen s
hot function to save the image of the reading, when
possible), WBGT temperature, if possible, wind speed and /direction, radiant heat, cloud cover,
length of time the work was performed, and other sources of heat in the workplace.
Additionally, document whether any exposed employees wer
e temporary workers, new hires, or
employees returning from prolonged leave periods who were not acclimatized. When listing
availability of feasible abatement methods in the citation, document all potential measures the
employer failed to implement that would have materially reduced or eliminated the hazard of
heat-related illness, such as providing cool, drinking water, frequent breaks
, cooling or shaded
areas, and access to first aid/prompt medical attention. NOTE: Do not set forth recommended
measures as alternative options. Use language such as "Among other methods, feasible and
acceptable measures to abate this hazard may include:" At the end of listing the proposed
measures, insert the
28

following: "The listing of these available abatement methods does not necessarily mean that
any one measure is sufficient to abate the hazard".
Any water or other fluids provided by the employer should be cool and provided in a location
that is fam iliar to the employees, near the work, easy to access, and in sufficient quantity for
the duration of the work.
29

Appendix D: Sample Hazard Alert Letter
(HAL)
SAMPLE HAZARD ALERT LETTER
Note: This letter must be adapted to the specific circumstances noted in each
inspection. The letter below is an example of the type of letter that may be appropriate
in some circumstances. If the employer has implemented or is in the process of
implementing efforts to address hazardous heat conditions, those efforts should be
recognized and encouraged, where appropriate. CSHOs should tailor the recommended
controls outlined below to the specific needs of the employer. Italicized and bracketed
text are for OSHA compliance use only and should not be included in the letter.
Dear Employer:
An inspection of your workplace and evaluation of your OSHA recordkeeping logs at
[
location] on [date] disclosed the following workplace condition(s) which have been
associated with the development of heat-related illnesses in workers:
[
Describe the work performed for each task or job, including the type of PPE worn, the source of heat,
WBGT and duration of the heat exposure, reading on the OSHA-NIOSH heat app during the inspection,
any heat notifications from the National Weather Service, and any other information relevant to workers'
exposure to the risk of heat-related illness
].
In the interest of workplace safety and health, I recommend that you voluntarily take the
necessary steps to materially reduce or eliminate your workers' exposure to the
conditions listed above, including, but not limited to, the following:
General Controls:
General controls include training, personal protective equipment (PPE), administrative
controls, health screening, and heat alert programs.
1. Training: inform workers of the following (Modify this list as appropriate for the
specific situation):
a. Hazards of heat-related illnesses.
b. How to avoid heat-related illnesses by recognizing and avoiding situations
that can lead to heat-related illnesses.
c. Recognition of signs and symptoms of heat-related illnesses.
d. First-aid procedures.
e. Employer's program to address heat-related illnesses.
2. Personal Protective Clothing and Equipment: (CSHOs should recommend the
appropriate PPE).
a. Hats for work outdoors in the sun.
b. For indoor work, loosely worn reflective clothing to deflect radiant heat,
such as vests, aprons, or jackets.
30

c. Cooling vests and water-cooled/dampened garments may be effective
under elevated temperature and low humidity conditions. However, be
aware that cooling vests can become an insulator when they reach the
body's temperature.
d. In environments where respirator usage is necessary, consult with an
industrial hygienist to determine the appropriate clothing to prevent heat
stress while still protecting the workers.
e. Consider the use of dermal patches for monitoring core temperature to
better identify when workers need to be removed from the work area.
f. Consider the use of heart rate monitoring to better identify when workers
need to be removed from the work area. Both sustained (180 minus age)
and recovery (120 bpm after a peak work effort) heart rates are
recommended guidelines for limiting heat strain.
3. Administrative Controls: (CSHOs should consult the OSHA Technical Manual,
Section III Chapter 4 for additional information).
a. Schedule hot jobs for cooler parts of the workday, and routine
maintenance and repair work should be scheduled for the cooler seasons
of the year when possible.
b. Provide adequate cool drinking water on the worksite that is easily
accessible and permit employees to take frequent rest and water breaks.
c. Use relief workers and reduce physical demands of the job.
d. Have air-conditioned or shaded areas available for water breaks and rest
periods.
4. Health Screening and Acclimatization:
a. New workers should be allowed to get used to hot working environments
by using a staggered approach over 7-14 days. For example, begin work
with 50% of the normal workload and time spent in the hot environment,
and then gradually increase the time over a 7–14-day period. The same
should be done for workers returning from an absence of three or more
days, staging acclimatization over three consecutive days.
b. Workers should be made aware of the following:
i. Medications such as the following can increase risk of heat stress:
• Amphetamines -sometimes prescribed for narcolepsy or
attention deficit hyperactivity disorder (ADHD),
• Diuretics -water pills,
• Antihypertensives -blood pressure medication,
• Anticholinergics -for treatment of chronic obstructive
pulmonary disease (COPD), and
• Antihistamines -allergy medications.
ii. Dangers of using illegal drugs and alcohol in hot work
environments. Illegal amphetamines such as methamphetamine
are particularly hazardous when heat stress is present.
31

iii. Some conditions, such as pregnancy, fever, gastrointestinal illness,
heart disease, and obesity, may increase the risk of heat-related
illness. Workers should be advised to check with their doctors if
they have any questions. (Please note: the employer is NOT
entitled to know whether workers have these conditions, but only
whether workers have any health conditions that limit their ability to
perform their job duties. In some instances, workers with chronic
conditions may need extra time to become acclimatized or may
need other accommodations, such as more frequent breaks or
restricted work.)
iv. Workers should consult a doctor or pharmacists if they have
questions about whether they are at increased risk for heat-related
illness because of health conditions they have and/or medications
they take.
You may voluntarily provide this Area Office with progress reports on your efforts to
address these heat-related conditions in your workplace. OSHA may return to your
worksite to further examine the conditions noted above.
Sincerely,
Area Director
Enclosures
32

Appendix E: CSHO Pre-Inspection Checklist
Here are some things to consider before proceeding with any inspection:
a. Ensure the availability and use of all necessary and appropriate personal
protective equipment (PPE).
b. Ensure all PPE, inspection equipment, and media are retrievable and ready for
use.
c. Review any relevant cleaning procedures for equipment and the vehicle,
government (GOV) or personal (POV).
d. For all heat inspections, the manager/supervisor/CSHO, in consultation with
designated regional office staff, will develop and document a risk assessment
that includes an exposure control plan, Job-Hazard Analysis, and PPE hazard
assessment prior to entry and update it as necessary for each inspection, to
include individual inspection risks that may not otherwise be captured in a
general or overall worksite assessment. Individual inspection risks may be
based on factors such as industry type, or on-site hazard location.
e. Ensure GOV or POV is road-ready to include gas/fuel, first aid kit, hand sanitizer,
disinfecting wipes, or other cleaning and/or disinfecting agents (as required), and
bags to dispose of contaminated PPE and used disinfecting wipes.
f. Ensure there is enough water available to drink a cup of water every 15 minutes
while performing an inspection on a heat priority day. Ensure the air conditioning
in the GOV or POV is adequate to provide a cool place to rest during inspections
on heat priority days.
g. Develop a document request letter in advance of the opening conference (e.g.,
programs, OSHA Form 300/300A, and summaries) to be provided to the
employer during the opening conference if needed.
33

Appendix F: Additional Resources
For Additional Information – OSHA and NIOSH
For more information on heat stress and educational products for safety and health
professionals, employers, and workers, visit
• OSHA-NIOSH Heat Safety Tool Smartphone App: Heat Safety Tool Application
• OSHA Educational Resources: Fact Sheets/ Posters (en Espanol)
• OSHA Webpages: Heat Illness Prevention, Occupational Heat Exposure
• OSHA-NIOSH Info Sheet: Protecting Workers from Heat Illness
• NIOSH Topic Page on Heat Stress
• OSHA Technical Manual (OTM), Section III: Chapter 4
• Fact Sheet: Biden Administration Mobilizes to Protect Workers and Communities
from Extreme Heat
34