Heat Illness Prevention
Revised HIP Standard to take effect May 1, 2015
After proposing the second revision to the Heat Illness Prevention standard since the original permanent standard took effect in 2006, Cal/OSHA and the Cal/OSHA Standards Board held a hearing on the August 2014 proposal and two proposed modifications to the original proposal in November and December 2014. The Board on Feb. 19 adopted the revision to the HIP standard. The revised standard will take effect on May 1, 2015.
The agency pushed the revised standard through in the face of continuing concerns expressed by representatives of farm employers.
The revised HIP standard makes several changes to the existing standard that will force employers to substantially change some of their practices for managing rest periods and providing shade. The new regulatory language also adds uncertainty in some areas, some of which the agency has indicated a willingness to clarify through guidance:
- Language borrowed from the Field Sanitation standard will require drinking water for employees to be “fresh, pure, and suitably cool.” The agency rejected numerous requests to set a different standard such as “potable” and declined to offer guidance as to what “suitably cool” will mean in enforcement practice.
- Shade for employees will have to be provided in a manner that does not deter or discourage its use, in addition to the long-standing ban against providing shade that exposes employees to unsafe or unhealthy conditions. Shade will have to be present when the temperature exceeds 80 degrees Fahrenheit. (Under the current standard, the temperature trigger is 85 °F.)
- The amount of shade present will have to be sufficient to accommodate all employees on recovery or rest periods or who remain onsite during meal periods so they can sit in a normal posture fully in the shade without having to be in physical contact with each other. (Under the current standard, shade sufficient to cover 25% of the employees on a shift is compliant.)
- An employee taking a preventative cool-down rest will have to be monitored for signs of heat illness and may not be ordered back to work until any signs or symptoms of heat illness have abated or five minutes have elapsed, whichever is later.
- An employee exhibiting signs of heat illness will have to be provided with appropriate first aid or emergency services.
- In “high heat” of at least 95 °F:
- Employees will have to be observed for alertness and signs of heat illness by means such as:
- Supervisor or designee observation of up to 20 employees;
- A buddy system; or
- Regular contact with a sole employee such as by radio or cellular phone.
- One or more employees must be designated to call for emergency medical services, and other employees must be allowed to call for those services when no designated employee is available to do so.
- A meeting with employees must be held before they start work to review high-heat procedures, to encourage them to drink plenty of water, and to remind them of their right to take a cool-down rest when necessary.
- Agricultural employees will be required to take a preventative cool-down rest period for at least 10 minutes every two hours; the agency has conceded that these breaks can be concurrent with IWC-required rest periods. In addition, employees working more than eight hours will have to take such a rest period at the end of the eighth hour of work and at the end of every even-numbered hour of work after that.
- Under a new subsection titled Acclimatization, employees will have to be closely observed during a “heat wave,” meaning any day on which the predicted high temperature will be at least 80 °F and at least 10 °F higher than the average high daily temperature of the prior five days.
FELS will provide materials to help meet your training needs for the revised HIP standard, along with other compliance resources. You can read the newly amended regulation at fels.net/find.
Heat Illness Resources
- California Division of Occupational Safety and Health
Suggested resources on their Web site:
- Heat Illness Prevention Training Powerpoint for Agricultural Employers (available in English and Spanish)
- Heat Hazards in Agriculture - A guide for employers to carry out tailgate training for workers (available in English and Spanish)
- Employer Sample Procedure for Heat Illness Prevention (available as a PDF or word document)
- Cal/OSHA Consultation Services Heat Illness Prevention etool
Suggested resources on their website:
- IIPP model program for agriculture, potable water, access at all times, and heat stress evaluation and control
- Cal/OSHA Heat Illness Prevention Newsletter: What You Need To Know (available in English and Spanish)
- Cal/OSHA Video: Protect Yourself Against Heat Stress and Illness (a transcript of the video is also provided)
- Cal/OSHA Consultation Services: (800) 963-9424
All consultations are confidential from Cal/OSHA Enforcement and are free of charge. [FAQs]
- Heat Illness Educational Campaign