DES PLAINES, Ill. — In working conditions where high temperatures can be a factor, such as those in a drycleaning plant, keeping employees safe from heat exhaustion, heatstroke and other hazards is a top concern.
Katelyn Kratz of the Heartland Fabricare Association (HFA) and Safety and Environmental Compliance Consultants addressed this topic during a recent webinar hosted by the Drycleaning & Laundry Institute (DLI). She examined a proposed Occupational Safety and Health Administration (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. Today, we’ll look at what operators will need to do to comply with the law in making.
Trigger Temperatures
The proposed rule focuses on eight specific areas of prevention: hydration, environmental monitoring, emergency procedures/plans, body cooling, acclimatization, textiles/personal protective equipment, physiological monitoring, and what the legislation calls “heat hygiene” — which essentially is annual training on heat-related illness and prevention.
A critical element of the regulations is two temperature thresholds that trigger specific actions, Kratz says. The first trigger is 80 F, and the second is the high-heat trigger of 90 F. These triggers are based on the heat index, she adds, which combines both temperature and humidity.
“When we hit that initial heat trigger within any workday of 80 degrees, then we have to start those initial protocols,” Kratz says. “When we hit that 90-degree atmospheric temperature, then we have to do all of the high-heat protocols, which get a little more intense.”
When temperatures climb above 80, Kratz says, employers must take steps to reduce risk, including monitoring conditions and providing water, shade or cool rest areas.
Employees are allowed to take optional rest breaks based on their needs. When the temperature reaches the high-heat trigger of 90, the safety requirements are greater, including mandatory 15-minute paid rest breaks every two hours, heat hazard alerts, and active employee observation for signs of heat illness.
One of the requirements is water access, Kratz says. Workers should be able to have a water bottle with them or have access to bottled water or a fountain nearby. The water must be cool enough to encourage drinking, and employers must provide access to one quart of drinking water per employee per hour.
“That means eight quarts over an eight-hour day,” Kratz says. “If you have a large facility, that could mean a lot of bottles of water.” She recommends considering more cost-effective options like drinking fountains or refillable water bottle stations. And, because workers will be drinking more water, access to working restrooms is also required.
No AC Requirement
One bit of good news for employers, Kratz says, is that air conditioning is not mandatory.
“OSHA is not requiring employers to install a permanent cooling system,” she says, noting that portable air-conditioning units, high-powered fans or portable dehumidifiers in designated break areas can all be used to comply. Indoor break areas also don’t need to be in a separate room — they can be integrated within the main workspace as long as employees can take breaks there without working.
“It could be a space with a picnic table and a couple extra fans and water,” Kratz says. “That could be what you do in order to actually accommodate this rule.” Employers should be aware, however, that fan use when ambient temperatures exceed 102 has been demonstrated to be harmful under some conditions. They must evaluate humidity levels to determine if fans should be avoided at those extreme temperatures.
Getting Used to the Heat
One area the law covers is getting employees used to the heat of the workplace, and not just thrown in. Acclimatization would be required for new employees or for people returning after a period greater than 14 days. A worker taking a week’s vacation doesn’t need to be reacclimated.
There are a couple options for acclimatizing new employees, Kratz says.
One option follows guidelines from the National Institute for Occupational Safety and Health (NIOSH), which recommends starting with 20% of the usual work duration in heat on the first day and increasing by no more than 20% each subsequent day. By Friday, an employee could be working in a hot environment full-time. For employees returning after an extended absence, the recommendation is to start with no more than 50% of the usual work duration and gradually increase.
The second option would be to train new employees as if a high-heat trigger were present, following all high-heat protocols, whether or not they exist at that time. This means providing 15-minute breaks every two hours, Kratz says, and monitoring for symptoms, maintaining two-way communication, providing alerts and requiring water intake.
“What do I do with somebody if they’re brand-new and they can only work 20% of the day?” Kratz asks. “Do the rest of their training on that first day. Do their other OSHA compliance training. Train them on the front end. If your front of house is much cooler, put them there.”
Signs and Observation
High-heat areas that regularly exceed 120, such as boiler rooms, must be labeled as high-heat areas under the proposed new law. “Signage indicating ‘Authorized Employees Only’ can help protect workers who shouldn’t be in those spaces,” Kratz says, “and limit liability if unauthorized personnel enter anyway.”
When the high-heat trigger is reached, employers must also provide heat hazard alerts and actively observe employees for signs of heat illness. These alerts can be text messages, emails, posters or verbal notifications from supervisors.
For observation, employers can designate supervisors or use a buddy system where workers monitor each other. The limitation is that one supervisor can observe a maximum of 20 employees, and they must be close enough to communicate with and see those they’re observing.
While mandating some of these regulations might take some effort, Kratz believes that OSHA has taken care not to make them too difficult for owners.
“The regulations are designed with flexibility in mind,” Kratz says. “Small businesses in particular are given consideration to implement feasible controls that don’t break the budget.”
Come back Tuesday for the conclusion of this series, where we’ll cover the critical training and documentation requirements that can make or break OSHA compliance. For Part 1, click HERE.
Have a question or comment? E-mail our editor Dave Davis at [email protected].
