Occupational Heat Exposure and the Requirements for a HSMP
With the Summer weather well underway and hot temperatures raging throughout the country, heat-related illnesses are also on the rise. With millions of workers exposed to occupational heat-related hazards each year, it is essential that you and your employees know and understand the extreme risks associated with heat stress. Join us here at GovGig as we dive into this very important topic.
The Bureau of Labor Statistics reports that over the last decade (2011-2021), the United States has experienced 436 occupational deaths due to heat-related illnesses. On a global scale, the situation is even more dire, with worker fatalities surpassing 1.9 million as per World Health Organization estimates. Beyond the recorded deaths, thousands of instances of heat-related illnesses and injuries occur annually, undeniably burdening both the US workforce and economy. The economic losses attributed to these issues have surpassed an alarming $100 Billion which truly many not even begin to scratch the surface regarding the true impact that these illnesses and injuries have both our workers and the companies which employ them.
With the consistent rise of heat-related illnesses and deaths in the United States annually, regulatory agencies have begun to place a refined focus on heat-illness prevention in an effort to both educate the workforce and implement measures to protect workers from harm. (See OSHA’s National Emphasis Program which aims to ensure that employees in high-hazard industries are protected from both indoor and outdoor heat-related hazards).
Heat Stress Monitoring Plan (HSMP) and Execution Requirements
While working on your federal construction project, it is essential that precautionary steps be taken to protect the workers that are performing work under your scope from harm. It is necessary that you understand the expectations by which you will be held accountable and that you both incorporate and execute these requirements via your project Accident Prevention Plan. Take the time to be familiar with the below Heat Stress Monitoring Plan requirements and your contractual obligations under this plan. (See EM 385 1-1 06.J.03 for a more exhaustive list of HSMP requirements under this standard)
1. Heat Stress Monitoring Plan Requirements- If you are working outdoors on your project during Spring and Summer weather, there is a high likelihood that HSMP requirements will follow. EM 385 1-1 specifies under what conditions a HSMP is required, including the following working conditions:
a. CONUS and OCONUS locations when hot/dry or hot/humid environments are forecasted.
b. Work is conducted in semi-permeable or impermeable clothing and/or heavy clothing such as arc-rated suits.
c. Work in confined work environment with minimal air movement.
d. Work when heat index is greater than 75° F (24° C) or dry temperature is 75° F with 55% humidity or Wet-Bulb-Glove Temperature (WBGT) exceeds the action level for various exertion levels in Table 2 of the TLV and Action Limit for Heat Stress Exposure in the current ACGIH TLV/ BEI booklet.
e. Work around heat-producing equipment, furnaces, boilers, asphalt pots, engines, compressors, etc.
2. Employee Training must be provided to all exposed employees and must at minimum cover the following areas:
- Knowledge of the hazards of heat stress;
- Recognition of predisposing factors, danger signs, and symptoms;
- Awareness of first-aid procedures for, and the potential health effects of, heat stroke;
- Employee responsibilities in avoiding heat stress;
- Dangers of using drugs, including therapeutic ones, and alcohol in hot work environments;
- Use of protective clothing and equipment; and
- Purpose and coverage of environmental and medical surveillance programs and the advantages of worker participation in such programs.
3. Heat Stress Monitoring- Temperature monitoring should be conducted beginning once the heat index is greater than the temperatures established under Section 06.J.01d. According to guidance provided by OSHA.gov’s Emergency Preparedness Page on Heat-Stress, workers should also be monitored “who are at risk of heat stress, such as those wearing semi-permeable or impermeable clothing when the temperature exceeds 70°F, while working at high metabolic loads (greater than 500 kcal/hour). Personal monitoring can be done by checking the heart rate, recovery heart rate, oral temperature, or extent of body water loss.” Section 06.L.03.g-i of the EM 385 manual also provides specific requirements for physiological monitoring including the requirements for work/rest regiments and radiant sun exposure.
4. Potable Drinking Water must “be available to employees and employees are encouraged to frequently drink small amounts, (e.g., 1/2 cup every 15-20 minutes). The water shall be kept reasonably cool 50-60° F (10-15° C) to encourage consumption. > See Section 02.C.”
5. Employee Acclimatization- “Workers who have not previously worked in a hot environment or have had a previous heat-related injury, or are known to be on medication, shall acclimatize with a regimen of increasing exposure each day of work.”
6. Rest and Recovery Areas- Rest and recovery areas, shade and applicable alternatives must be provided (where applicable) with intermittent rest and water breaks. Recovery areas could include air-conditioned enclosures, an air-conditioned vehicle, or a shaded area with fans or misting stations, among others.
7. Employee Exposure & Treatment- “Workers who experience heat stress shall seek medical attention. Workers who have more than one heat-related episode within a month shall have a doctor’s written release prior to returning to exposures in a potential heat stress environment.”
Please take the time to educate your workforce regarding the hazards of heat-related illnesses. Utilize provided resources such as the following to help to build your Heat Stress Monitoring Plan and employee training program:
· OSHA’s Safety Topic Information- Heat
· National Institute for Occupational Safety & Health (NIOSH)
· SHARP Temperature Statistics
· Oregon OSHA Heat-Stress Publications
· CDC Tips for Preventing Heat-Related Illness
· CDC Signs and Symptoms of Heat-Related Illness
Please reach out to us here at GovGig should you need assistance building your HSMP or if you would like further guidance relating to this important topic.
Best Regards,
Cory J. Grimmer, CSP, CHST