Long anticipated since the Outdoor Heat Illness Prevention Standard (T8 §3395) was adopted in 2006, California’s Occupational Safety and Health Standards Board approved a new Indoor Heat Illness Standard on June 20, 2024 and it is now in effect as of July 23, 2024. The Indoor Heat Illness Standard is codified as Title 8 §3396.
When will it take effect?
The Indoor Heat Illness Standard took effect on July 23, 2024.
What businesses are impacted?
Almost every indoor business in California where temperatures may reach 82°F and workers may be present is subject to the requirements. This includes offices, warehouses, manufacturing, laboratories, and others.
There is no minimum employee threshold for compliance.
Exemptions apply to certain law enforcement detention facilities, and companies where their workforce is 100% remote.
Are the rules the same for indoor and outdoor workspaces?
There are some differences between the two, but there are similar elements: The requirements for employers to create a written plan, offer fresh water, access to shade (or a cooling area), emergency response procedures and mandatory training for both employees and supervisors. Each of these provisions has very specific requirements.
Why is this important?
According to the National Weather Service, heat is the leading weather-related killer in the U.S. After the Outdoor Heat Illness Prevention Standard was passed, Cal/OSHA embarked on a multi-year enforcement campaign, and as a result, citations for violations of §3395 are the second most commonly cited standard (right behind Injury, Illness, and Prevention Plans, §3203). One might expect similar enforcement activities for the new standard.
What should our clients do now that the rule is in effect?
We advise our clients to immediately start taking temperature readings in areas impacted by the new rule. This includes any production areas, warehouses, storerooms. Pay special attention if your production areas contain conductive heat sources, such as boilers.
Employers should also begin implementing the required written plan, fresh water provision, access to cooling areas, emergency response procedures, and mandatory training for both employees and supervisors.
Find out if your company is at risk and how CDMS can help.
CDMS’s Role:
Training and plan development are now available to our California clients to ensure compliance with the new rule. Please reach out to service@cdms.com to schedule training or request assistance with your Indoor Heat Illness Prevention Plan.
