DES PLAINES, Ill. — If there’s one lesson dry cleaners should take from decades of Occupational Safety and Health Administration (OSHA) enforcement, it’s that documentation matters. When OSHA inspectors arrive, one of the first things they ask for is proof of training and written plans. The proposed heat-stress regulations follow this same pattern, making proper documentation and training just as important as the physical measures like fans and water access.

This new proposed law about preventing heat injury in the workplace was the topic of a recent webinar hosted by the Drycleaning & Laundry Institute (DLI), presented by Katelyn Kratz of the Heartland Fabricare Association (HFA). The webinar examined a proposed OSHA regulation that would establish new requirements for preventing heat-related illness in the workplace.

In Part 1 of this series, we explored the proposed heat-stress regulations and why they matter for dry cleaners. In Part 2, we looked at what operators will need to do to comply with the proposed new law. Today, we conclude by examining the training, documentation and emergency planning requirements that are essential for compliance — and often the first things OSHA inspectors look for.

“Some of the biggest fines that are given to people are based on training and the documentation of that training,” Kratz says.

The foundation of compliance is the employer’s heat injury and illness prevention plan, Kratz says. Employers would be required to develop a written plan that identifies heat hazards, evaluates risks and puts controls in place to reduce heat stress. 

These hazards include general air temperature, she says, but also equipment that puts off radiant heat, such as pressing equipment, machinery and boilers.

Training also represents a critical component, Kratz says, and cannot be treated as a one-time event. Employers must train workers and supervisors about heat risks, how to recognize heat illness, how to prevent heat stress, and what to do in an emergency. 

“It can’t just be, ‘Here are the signs of heat stress — tell us when you experience that,’” Kratz says. “You have to talk through your company’s specific emergency plan and where people can go for a rest break. You also need to tell them that they’re allowed to take those rest breaks and that those rest breaks have to be paid.”

This training must occur annually and be documented each time, Kratz says, with records kept in employee files. While the proposed regulation states that documentation only needs to be kept for a minimum of six months, OSHA routinely asks for training records during inspections, so she advises employers that it’s best to keep them longer. The training should ideally be conducted within 30 days of the warmer season or heat-related work.

“If your warm season isn’t until July, doing your training right now would be awfully silly,” Kratz says. “We’d want to wait until June to do that specific training.”

Emergency response planning is another documentation requirement that demands attention, Kratz says. Employers must assign workers to be responsible for executing the emergency plan and rehearsing or reviewing it annually. The plan should clearly outline what to do if a worker shows signs of heat or other serious heat illness.

Recordkeeping, Kratz says, extends beyond training to include monitoring and any heat-related incidents. When a high-heat alert is issued, operators should write down the date, the temperature, the heat index and the actions taken. This documentation demonstrates compliance and provides a record of due diligence.

“That recordkeeping will save you so much money in the event that OSHA comes and actually does an inspection,” Kratz says.

When there is a heat-related emergency, there should be a plan in place, Kratz says. According to the National Institute for Occupational Safety (NIOSH), this includes:

• Taking the worker to a clinic or emergency room, or calling 911 if medical care is unavailable
• Someone staying with the worker until help arrives
• Removing the worker from the hot area
• Providing liquids to drink
• Removing unnecessary clothing, including shoes and socks
• Cooling the worker with cold compresses, or having them wash their head, face and neck with cold water

“We want to make sure that they are drinking sips of cool water,” Kratz says. “Not that we are flooding their system with water, but slowly sipping that water. We don’t want to make them nauseous by having them gulp down water quickly, but those frequent sips of cool water are very helpful.”

A crucial element of the emergency plan is employee involvement, Kratz says. The employer must seek input and involvement from all workers. This isn’t just a regulatory checkbox — it’s practical wisdom. The people doing the work often have the best insights into what will actually work in practice.

“You as an employer or a supervisor cannot create this plan on your own,” Kratz says. “You need to actually consult the employees who work for you and what makes sense for them. They need to be part of the plan creation.”

The proposed OSHA rule is designed to be flexible, with special considerations for small businesses like most dry cleaners, Kratz says. Air conditioning is not required, and many of the required measures — water, fans, rest breaks — are relatively affordable. The key is starting early to develop policies, budget for any needed equipment, and train staff before summer heat arrives.

“Eventually, this is going to come down the pike,” Kratz says. “We want to start implementing this and working on our policies now. We want to start implementing these things so that it doesn’t become an emergent situation come June, July or August.”

For Part 1 of this series, click HERE. For Part 2, click HERE.