Navigating Cal/OSHA’s New Indoor Workplace Heat Illness Prevention Standards

Cal/OSHA recently established a new set of rules in response to the growing number of heat-related worker injuries and fatalities: Heat Illness Prevention in Indoor Places of Employment. These rules will impact many California industries, especially manufacturing. Businesses affected by the new Cal/OSHA heat illness prevention standards will be required to develop written heat illness prevention plans, adhere to certain workplace requirements, and train workers on the dangers of heat illness.

To help California manufacturers better understand and comply with these rules, we’ll explain the following in this blog:

• Background information on the regulations
• Businesses affected and those identified as exempt
• Required safety measures

The Origin of the New Cal/OSHA Heat Illness Prevention Standards

To start, you should understand where this rule came from and when it took effect…

On June 20, 2024, the Occupational Safety and Health Standards Board approved the California Code of Regulations, Title 8, Section 3396, “Heat Illness Prevention in Indoor Places of Employment.” The Office of Administrative Law (OAL) then had 30 working days to review the proposal. On July 23, 2024, the standard was approved by the Office of Administrative Law (OAL) and immediately went into effect.  Before this, California had existing heat illness regulations, passed in 2016, that only pertained to outdoor workers. The text of that bill required Cal/OSHA to eventually create rules for indoor workers as well. After several years of delays, those rules have been adopted and are now in effect.

What Businesses Are Affected by the New Cal/OSHA Heat Illness Prevention Standards?

The new standards apply to any business under the jurisdiction of Cal/OSHA. However, the rules will only be relevant for indoor workplaces with temperatures above 82°F. 

Businesses that may face the most demanding adjustment periods include:

• Manufacturers
• Warehouses
• Distribution Centers
• Restaurants
• Data Centers

*Previous outdoor heat regulations remain unchanged

Notable Exceptions to the New Cal/OSHA Heat Illness Prevention Standards

Cal/OSHA has defined a few exceptions to the new indoor workplace heat illness prevention rules. These include...

Telecommuters

Employers are not responsible for heat-related illness for workers who work from a location of their choice, including those who work from home.

Incidental Heat Exposure

The new Cal/OSHA heat illness prevention standards also don’t apply to incidental heat exposures. Incidental heat exposures refer to exposure to temperatures at or above 82°F and below 95°F for less than 15 minutes in any 60 minutes. 

This exception does not apply to vehicles without effective air conditioning or shipping or intermodal containers during loading, unloading, or related work.

Required Safety Measures for Affected Industries

For affected industries, if and when your workplace temperature rises above 82°F, the following requirements must be met…

Provide Cool-Down Areas

Workers must have access to at least one cooldown area kept below 82°F. This area also needs to be:

• Blocked from direct sunlight
• Shielded from other high-radiant heat sources
• Large enough to accommodate workers on rest breaks
• Equipped with enough seating for workers to sit comfortably without touching each other
• As close as possible to work areas

Monitor and Encourage Cool-Down Rest Periods

Have Heat Assessment and Control Measures In Place

Supervisors need to be trained on how to check weather reports and respond to hot weather advisories for indoor workplaces that are affected by outdoor temperatures.

Employers must be able to measure both temperature and heat index and record whenever either one reaches 87°F.

Businesses must also implement control measures to keep workers safe. According to the regulations, “feasible engineering controls must be implemented first.”

Follow Emergency Response Procedures

Employers must provide first aid or emergency response to any worker showing symptoms of heat illness, which may include contacting emergency medical services.

Provide Training and Allow for Acclimatization

Employers must also provide training to both workers and supervisors on:

• Environmental and personal risk factors for heat illness
• Different types of heat illness and common symptoms
• Immediately reporting signs or symptoms of heat illness in themselves or other workers
• The employer’s procedures for complying with the Cal/OSHA heat illness prevention regulations
• The importance of staying hydrated

Supervisors specifically must also be trained on the following:

• How to implement emergency procedures
• Where the affected work area is, and how to monitor weather reports and hot weather advisories

Additionally, employers must closely observe new workers working in hot areas over a 14-day acclimatization period.

Establish a Heat Illness Prevention Plan

Finally, every business affected by the regulation must establish, implement, and maintain “an effective written Indoor Heat Illness Prevention Plan.” This plan must be written in both English as well as the language most employees understand. The plan must be made available to employees and representatives of Cal/OSHA upon request. 

At a minimum, the plan must include procedures for:

• The provision of water
• Access to cool-down areas
• Measuring temperature and heat index, and recording whichever is greater when one surpasses 87°F
• Identifying and evaluating all other environmental risk factors for heat illness
• Implementing heat control measures
• Emergency response
• Acclimatization

How CMTC Can Help You Stay On Top of Changing Regulations

Navigating California’s many ever-changing regulations can be challenging, but CMTC is here to help. Our team of experts is well-versed in the latest regulations and can assist California manufacturers in developing effective strategies to achieve compliance. From assessing current practices to implementing tailored safety measures, CMTC provides the support needed to ensure that your workplace meets the new standards while safeguarding employee well-being. Reach out to us today for guidance and resources to streamline your compliance process and maintain a safe, productive work environment!