What is OSHA’s National Emphasis Program on Heat Hazards?

Heat plays a large part in how we plan our day. We often put off work that creates heat or highly strenuous tasks to a time when the weather is more conducive to our needs. However, that cannot always be done. Sometimes a task must be done on a rigid schedule or is of an emergency nature so that work cannot be put off to a later, cooler, time of day. To that end, OSHA has developed a National Emphasis Program (NEP) to give some guidance to companies on how to work in the heat and keep employees safe.

What is OSHA’s NEP on Heat Hazards?

OSHA will conduct programmed (pre-planned) inspections in targeted high-risk industries on any day that the National Weather Service has announced a heat warning or advisory for the local area.

The NEP went effective on April 8, 2022 and will remain in effect for 3 years unless canceled or extended by a superseding directive.

The NEP establishes heat priority days when the heat index is expected to be 80 degrees Fahrenheit or higher. During these days OSHA will:

• Initiate compliance assistance in the list of targeted high-risk industries; and,
• Inspect any alleged heat-related fatality/catastrophe, complaint or referral regardless of whether the worksite is within the list of targeted high-risk industries.

What are the Targeted High-Risk Industries?

OSHA’s NEP on heat hazards targets over 70 high-risk industries based on:

• Bureau of Labor Statistics (BLS) on incidence rates of heat-related illnesses
• Elevated numbers of fatalities or hospitalizations reported to OSHA
• Highest number of heat-related General Duty Clause violations over the last 5 years

These include but are not limited to:

General Industries That are Likely to Have Heat-Related Hazards:

NAICS Code        NAICS Industry Sector Title

1121                      Cattle Ranching and Farming
1151                      Support Activities for Crop Production
2131                      Support Activities for Mining
3118                      Bakeries and Tortilla Manufacturing
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 Processing
3315                      Foundries
3323                      Architectural and Structural Metals Manufacturing
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
4931                      Warehousing and Storage
5311                      Lessors of Real Estate
5617                      Services to Buildings and Dwellings (includes landscaping services, tree removal and tree trimming services)
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

Construction Industries That are Likely to Have Heat-Related Hazards

NAICS Code        NAICS Industry Sector Title

2361                      Residential Building Construction
2362                      Nonresidential Building Construction
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
2389                      Other Specialty Trade Contractors

Industries not Included in General Industry or Construction That are Likely to Have Heat-Related Hazards

NAICS Code        NAICS Industry Sector Title

1112                      Vegetable and Melon Farming
1113                      Fruit and Tree Nut Farming
2213                      Water, Sewage and Other Systems (may be State or local jurisdiction)
4411                      Automobile Dealers
4412                      Other Motor Vehicle Dealers
4821                      Rail Transportation (may be Federal jurisdiction)
4885                      Freight Transportation Arrangement
4911                      Postal Service
5611                      Office Administrative Services
5612                      Facilities Support Services
5613                      Employment Services
5614                      Business Support Services
5616                      Investigation and Security Services
5619                      Other Support Services
6117                      Educational Support Services
7225                      Restaurants and Other Eating Places
8112                      Electronic and Precision Equipment Repair and Maintenance
9281                      National Security and International Affairs (includes Customs and Border Patrol, and Transportation Security Administration)

What Will the OSHA Auditors Be Inspecting When They Come to Your Facility?

During heat-related inspections, inspectors will:

• Review OSHA 300 Logs and 301 Incident Reports for any entries indicating heat-related illness(es). 
• Review any records of heat-related emergency room visits and/or ambulance transport, even if hospitalizations did not occur. This may require the use of a Medical Access Order.
• Interview workers for symptoms of headache, dizziness, fainting, dehydration, or other conditions that may indicate heat-related illnesses, including both new employees and any employees who have recently returned to work.
• Determine if the employer has a heat illness and injury program addressing heat exposure, considering the following:
  • Is there a written program?
  • How did the employer monitor ambient temperature(s) and levels of work exertion at the worksite?
  • Was there unlimited cool water that was easily accessible to the employees?
  • Did the employer require additional breaks for hydration?
  • Were there scheduled rest breaks?
  • Was there access to a shaded or cool area?
  • Did the employer provide time for acclimatization of new and returning workers?
  • Was a “buddy” system in place on hot days?
  • Were administrative controls used (earlier start times, and employee/job rotation) to limit heat exposures?
  • Did the employer provide training on heat illness signs, how to report signs and symptoms, first aid, how to contact emergency personnel, prevention, and the importance of hydration?
• Document conditions relevant to heat-related hazards, including:
  • The heat index and additional weather data from that day, e.g., heat alerts from the NWS, data from the OSHA-NIOSH Heat Safety Tool App, saving a screenshot on a mobile phone or tablet. Additional information may be needed for indoor heat investigations.
  • Observe and document current conditions and those at the time the incident occurred (for unprogrammed inspections), including:
    • Observed wind speed
    • Relative humidity
    • Dry bulb temperature at the workplace and in the shaded rest area
    • Wet-bulb globe temperature at the workplace, (ensure the equipment has been properly calibrated prior to use)
    • Cloud cover (no clouds, 25%, 50%, 75%, 100%)
    • The existence of any heat advisories, warning or alerts the previous days
  • Identify 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, or areas with hot air, near a gas engine, furnace, boiler or steam lines).
    • The use of heavy or bulky clothing or equipment, including personal protective equipment.
    • Estimate workload exertions by observing the types of job tasks performed by employees and whether those activities can be categorized as moderate, heavy or very heavy work, considering both average workload and peak workload.
    • Duration of exposure during which a worker is continuously or repeatedly performing moderate to strenuous activities.
  • OSHA believes a review of any potential heat-related hazards should be included in any programmed or unprogrammed inspection where radiant heat sources exist in indoor work areas or at outdoor work areas on heat priority days. OSHA advises inspectors to conduct compliance assistance and document it where heat-related hazards do not warrant issuing citations.
  • Inspectors can use the OSHA-NIOSH Heat Safety Tool App as a resource.

How Can You Prevent Heat Illness at Work?

Dangerous heat exposure can occur indoors or outdoors, in any season. Employers can keep workers safe by following these simple safety practices:

• Follow the 20% Rule — on the 1st day, don’t allow employees to work more than 20% of a shift at full intensity in the heat. Increase their time by no more than 20% a day until they are used to working in the heat.
• Provide cool drinking water – encourage workers to drink at least one cup every 20 minutes, even if they are not thirsty.
• Rest breaks — allow workers time to recover from heat in a shady or cool location.
• Dress for the heat — have workers wear a hat and light-colored, loose fitting, breathable clothing if possible.
• Watch out for each other — encourage workers to monitor themselves and others for signs of heat illness.
• Look for any signs of heat illness, including fainting, dizziness, nausea, and muscle spasms, and act quickly — when in doubt, call 911.
• Offer training on the hazards of heat exposure and how to prevent illness.
• Develop an Emergency Action Plan on what to do if a worker shows signs of heat-related illness.

Need Help in Getting Your Documentation in Order?

Do you need assistance in developing a formal heat illness and injury program compliant with this initiative? Do you need assistance in determining your potential heat exposures? iSi can help! Contact us today!