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A Critical Review of OSHA Heat Enforcement Cases, Lessons Learned

"This article reviews Federal OSHA 2012-2013 heat enforcement cases using identified essential elements of heat illness prevention to evaluate employers’ programs and makes several recommendations to better protect workers from heat illness.

This article, published in the April 2016 edition of the Journal of Occupational and Environmental Medicine published by American College of Occupational and Environmental Medicine, was co-authored by two OSHA’s Directorate of Technology Support and Emergency Management (DTSEM) staff members along with a former Graduate Nurse intern."

Doug Kalinowski

Directorate of Cooperative and State Programs


Objectives: The aim of the study was to review the Occupational Safety and Health Administration’s (OSHA) 2012 to 2013 heat enforcement cases, using identified essential elements of heat illness prevention to evaluate employers’ programs and make recommendations to better protect workers from heat illness. Methods: (1) Identify essential elements of heat illness prevention; (2) develop data collection tool; and (3) analyze OSHA 2012 to 2013 heat enforcement cases. Results: OSHA’s database contains 84 heat enforcement cases in 2012 to 2013. Employer heat illness prevention programs were lacking in essential elements such as providing water and shade; adjusting the work/rest proportion to allow for workload and effective temperature; and acclimatizing and training workers. Conclusions: In this set of investigations, most employers failed to implement common elements of illness prevention programs. Over 80% clearly did not rely on national standard approaches to heat illness prevention.

The knowledge that workers in hot workplaces are at risk of heat stress, heat illness, and possible death from heat stroke is not new. Military medicine since the Roman Empire has long supported battle readiness through appropriate guidance on managing heat illness. Scientists have made important contributions to the understanding of heat illness and addressed methods to assess the environmental contribution to heat stress. State governments have acted to prevent heat illness; for example, California and Washington have regulatory requirements addressing occupational heat stress. The Occupational Safety and Health Administration (OSHA) does not have a specific heat-related regulation, but uses section 5(a)(1) of the OSH Act for enforcement action in heat illness cases.

Death is a well-documented consequence of workplace exposure to heat. The National Institute for Occupational Safety and Health reported 423 heat-related deaths among outdoor workers from 1992 to 2006. Table 1 shows the Bureau of Labor Statistics’ Census of Fatal Occupational Injuries data on worker heat deaths in 2004 to 2014.11

Heat deaths are infrequent and dramatic events, but heat illness occurs frequently. In North Carolina in 2008 to 2010, workrelated heat illnesses were the most common cause for work-related emergency department visits among persons aged 19 to 45 years. In Maricopa County, Arizona, in 2002 to 2009, outdoor work in construction and agriculture accounted for 35% of heat-related deaths in men. In the United States during 1992 to 2006, 68 workers died of heat stroke in crop production. The annual average fatality rate of 0.39 heat deaths per 100,000 crop workers was almost 20 times the rate of heat-related deaths in all US civilianworkers. Particularly in agriculture, the number of heat illnesscases is likely underestimated because some surveys excludeworkers on small farms.

After the California Division of Occupational Safety andHealth (CalOSHA) established a Heat Illness Prevention Program,OSHA modified and expanded CalOSHA materials in 2011 toinitiate a Campaign to Prevent Heat Illness in Outdoor Workers(OSHA Heat Campaign). In 2014, in preparation for the fourthyear of the OSHA Heat Campaign, Federal OSHA convened aworkgroup to evaluate the effectiveness of existing heat illnessprevention materials and tools and to identify needed changes(Workgroup members: Sheila Arbury, MPH, Office of OccupationalMedicine and Nursing, Occupational Safety and Health Administration[OSHA]; Brenda Jacklitsch, MS, Education and InformationDivision, National Institute for Occupational Safety and Health,CDC; Opeyemi Farquah, Office of Science and Technology Assessment,OSHA; Michael Hodgson, MD, Office of OccupationalMedicine and Nursing, OSHA; Glenn Lamson, MS, Salt LakeTechnical Center, Directorate of Technical Support and EmergencyManagement, OSHA; Heather Martin, MSPH, Office of Scienceand Technology Assessment, OSHA; Audrey Profitt, MPH, Officeof Health Enforcement, OSHA). To do this, the workgroup planneda review of OSHA heat enforcement cases to determine theadequacy of employer heat illness prevention programs in orderto guide outreach efforts. In addition, the workgroup intended tocompare OSHA heat illness prevention materials to those of other organizations and update OSHA’s resources as needed....

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