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Heat Illness Prevention in Indoor Places of Employment Training

Heat Illness Prevention in Indoor Places of Employment Training
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Heat Illness Prevention in Indoor Places of Employment Training

On July 23, 2024, the California Office of Administrative Law approved California Code of Regulations, Title 8, §3396. This standard applies to most workplaces where the indoor temperature reaches 82℉ or the heat index reaches 87℉.

Our expert-led Heat Illness Prevention in Indoor Places of Employment Training ensures your organization’s full compliance while prioritizing employee safety. From environmental risk factors to emergency response procedures, we cover all aspects required by the new standard.

For more information on current enforcement and implementation trends of this or other laws, please contact us.

Regulatory bodies
  • California Occupational Safety & Health Association (Cal/OSHA)
Who needs it

Employers of most workplaces where the indoor temperature reaches 82℉ or the heat index reaches 87℉ must provide training to both workers and supervisors on several topics, including the steps the employer is taking to comply with this regulation. Required topics include:

  • Environmental and personal risk factors for heat illness.
  • The employer’s procedures for complying with this regulation.
  • The importance of frequent water consumption.
  • The importance and methods of acclimatization.
  • Signs and symptoms of the different types of heat illness.
  • The importance of workers immediately reporting to the employer signs and symptoms of heat illness in themselves or co-workers.
  • The employer’s procedures for responding to signs and symptoms of heat illness, such as first aid.
  • Emergency response procedures, including contacting emergency medical services with clear directions to the worksite.
  • Prior to supervising workers, the supervisor must be trained in all of the information listed above and how to monitor and respond to hot weather reports, if the work area is affected by outdoor temperatures.
Regulation reference
  • Title 8, Section 3396 of the CCR.
What our training provides:

CDMS will conduct comprehensive training sessions covering all topics required Title 8, Section 3396 of the CCR, ensuring that both workers and supervisors are reasonably anticipated to result in exposure to the risk of heat illness. CDMS can also create a written Heat Illness Prevention plan, which is also a requirement under §3396.

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What is the scope of the Heat Illness Prevention in Indoor Places of Employment regulation?

The regulation applies to all indoor work areas where the temperature equals or exceeds 82 degrees Fahrenheit when employees are present. However, some specific conditions and exceptions apply, such as teleworking locations not under employer control, incidental heat exposures, and certain emergency operations.

 

When did the Heat Illness Prevention in Indoor Places of Employment standard become effective?

The California Office of Administrative Law approved California Code of Regulations, Title 8, §3396 on July 23, 2024. This means the standard became effective on this date, requiring employers to comply with the new regulations for heat illness prevention in indoor workplaces from July 23, 2024 onward. It’s important for employers to have familiarized themselves with these requirements and implemented necessary changes to their workplace policies, procedures, and infrastructure by this date to ensure compliance with the new standard.

This effective date marks a significant step in protecting indoor workers from heat-related illnesses in California, expanding on the existing protections for outdoor workers. Employers should have used the time leading up to this date to prepare their workplaces, train their staff, and develop or update their Heat Illness Prevention Plans to meet the new requirements.

 

At what temperature does an employer need to implement all provisions of this regulation, including control measures?

An employer must implement all provisions, including control measures, when:

  • The temperature equals or exceeds 87°F
  • The heat index equals or exceeds 87°F
  • Employees wear clothing that restricts heat removal and the temperature equals or exceeds 82°F
  • Employees work in a high radiant heat area and the temperature equals or exceeds 82°F

 

What are the water provision requirements?

Employers must provide access to potable drinking water that is fresh, pure, suitably cool, and free of charge. The water should be located as close as practicable to work areas and in indoor cool-down areas. If not plumbed, water must be provided in sufficient quantity at the beginning of the shift (one quart per employee per hour for the entire shift). 2 gallons, per employee, per 8-hour shift.

 

What are the requirements for cool-down areas?

Employers must maintain one or more cool-down areas at all times when employees are present. These areas should be large enough to accommodate employees on rest periods, located close to work areas, and maintained at less than 82°F when feasible. Employees must be allowed and encouraged to take preventative cool-down rests when needed.

 

How often should temperature and heat index measurements be taken?

Initial measurements should be taken when it’s reasonable to suspect that the regulation applies. Additional measurements should be taken when a heat wave is forecasted.

 

What control measures are required when temperature or heat index thresholds are exceeded?

Employers must use a combination of engineering controls, administrative controls, and personal heat-protective equipment to minimize the risk of heat illness. The selection of control measures should be based on the environmental risk factors present in the work area.

 

What should be included in emergency response procedures?

Emergency response procedures should include effective communication methods, protocols for responding to signs and symptoms of heat illness, procedures for contacting emergency medical services, and ensuring clear directions to the worksite can be provided to emergency responders.

 

What are the acclimatization requirements?

During a heat wave, all employees must be closely observed where no effective engineering controls are in use. New employees in high-heat areas must be closely observed for the first 14 days of employment.

 

What topics should be covered in employee training?

Training should cover environmental and personal risk factors for heat illness, employer procedures for compliance, importance of water consumption, acclimatization, types of heat illness and their symptoms, reporting procedures, and the employer’s emergency response procedures.

 

What additional training is required for supervisors?

In addition to the employee training topics, supervisors must be trained on procedures to implement the regulation, how to respond when an employee shows signs of heat illness, and how to monitor and respond to weather reports if the work area is affected by outdoor temperatures.

 

What should be included in a Heat Illness Prevention Plan?

The plan should include procedures for water provision, access to cool-down areas, temperature and heat index measurement, control measures implementation, emergency response, and acclimatization.

 

How does the regulation define “clothing that restricts heat removal”?

It’s typically defined as full-body clothing covering arms, legs, and torso that is either waterproof, designed to protect from chemical, biological, radiological, or fire hazards, or designed to protect the wearer or work process from contamination. Often impermeable, the wearer’s body heat is unable to dissipate.

 

What is considered a “high radiant heat area”?

A high radiant heat area is defined as a work area where the temperature is at least five degrees Fahrenheit greater than the ambient temperature nearby. Areas can include heat-generating appliances, cooktops, boilers, and machinery.

 

Are there any facility exemptions to this regulation?

Yes, exemptions include certain prisons, jails and juvenile detention centers.

 

How long must records of temperature and heat index measurements be kept?

Records must be retained for 12 months or until the next measurements are taken, whichever is later. Note, only the temperature, or the heat index temperature, whichever is higher, must be recorded.

 

Can the Heat Illness Prevention Plan be integrated with other safety plans?

Yes, the plan can be integrated into the employer’s Injury and Illness Prevention Program or the outdoor Heat Illness Prevention Plan, §3395.

 

What languages should the Heat Illness Prevention Plan be written in?

The plan must be written in both English and the language understood by the majority of the employees.

 

How should employers involve employees in the implementation of this regulation?

Employers should have effective procedures to obtain active involvement of employees and their union representatives in planning and conducting temperature measurements and identifying and evaluating other environmental risk factors.

 

What is the definition of a “heat wave” according to this regulation?

For the purpose of this regulation, a heat wave is defined as any day when the predicted high outdoor temperature will be at least 80°F and at least 10°F higher than the average high daily outdoor temperature for the preceding five days.

 

Are there specific requirements for vehicles regarding this regulation?

Yes, vehicles with effective and functioning air conditioning are exempt from the temperature and heat index measurement requirements. However, vehicles without effective and functioning air conditioning are subject to the regulation when temperatures reach the specified thresholds.