Cal/OSHA Indoor Heat Illness Protections Become Effective July 24, 2024

In 2005, California introduced its outdoor heat standard for employers. Then in 2016, the Legislature passed Senate Bill 1167, which directed Cal/OSHA to create a heat standard for indoor places of employment by January 1, 2019. Almost eight years since that bill was approved, the Department of Industrial Relations has announced implementation of the finalized indoor heat illness standard.

Application: This standard applies to indoor work areas when the temperature reaches 82 degrees. In air-conditioned offices, it’s unlikely that the temperature will ever reach this threshold. Other environments, particularly those without environmental controls, can easily reach 82 degrees and higher in California’s summer heat. Even those workplaces with environmental controls may have some areas where temperatures are higher than others (e.g., restaurant kitchens may reach higher degrees than guest areas).

Access to Water and Cool-Down Areas: Once workplace temperatures reach 82 degrees, employees must have access to “fresh, pure, suitably cool” water provided free of charge and as close to employees as practicable and in cool-down areas. Employers should encourage frequent drinking.

Employers are also required to provide “cool-down areas” large enough to accommodate all employees on recovery, rest, or meal periods. Unless it is “infeasible,” these cool-down areas must be maintained at less than 82 degrees. Employees must be permitted to take preventive cool-down rests as often as they feel the need, and employees must be monitored for signs of heat illness during these preventive cool-down rests. Whether this monitoring is done by a coworker or a manager, those responsible for monitoring should be adequately trained so they are familiar with heat illness symptoms and how to provide treatment. This cool-down area may be indoors or outdoors, but must be blocked from direct sunlight and shielded from other radiant heat sources. Cool-down rests may be in addition to normal rest and meal periods, and are considered paid work time.

Emergency Response Procedures: All covered employers must develop emergency response procedures, which are similar to those required by the outdoor heat standard. Topics to address include: How can employees call for emergency services? How should supervisors or coworkers provide first aid to those suffering from heat illness? How will you ensure that emergency responders can reach ill/injured employees?

Higher-Heat Procedures: There are additional requirements when the temperature or heat index is 87 degrees or higher, or when the temperature is at least 82 degrees and employees are exposed to radiant heat (such as from working on asphalt or near heated equipment) or must wear clothing that restricts heat removal. In these cases, employers are required to measure and record temperatures and heat indexes, whichever is greater, when heat exposure is expected to be the greatest. These employers are also required to identify and evaluate environmental factors that could contribute to the risk of heat illness (e.g., air temperature, air movement, relative humidity, radiant heat, workload.) They should involve employees and managers in both temperature measurement and risk factor evaluation. Using this information, they are required to develop control measures to mitigate environmental risk factors for heat illness.

Employee & Supervisor Training: All employees must be provided with effective training regarding heat illness precautions. Training topics must include environmental and personal risk factors for heat illness, employer procedures for providing water and cool-down rest periods, common signs and symptoms of heat illness, and the importance of immediately reporting potential symptoms in themselves or in coworkers. Supervisors must receive additional training on procedures for monitoring the weather and how to respond when an employee exhibits or reports symptoms.

Written Heat Illness Prevention Plan: Covered employers must establish and implement an effective Indoor Heat Illness Prevention Plan. This information may be included in your Injury & Illness Prevention Plan (IIPP) or an existing Heat Illness Prevention Plan relating to outdoor work areas. The plan must be provided in both English and the language understood by the majority of employees, and made available to all employees during work hours.

What’s Next? Determine whether any of your company’s work areas may reach temperatures of 82 degrees or higher. (“Incidental exposure” where an employee is exposed to temperatures at or above 82 degrees but below 95 degrees for less than 15 minutes does not apply.)

If you believe the new Cal/OSHA standard applies to you, begin to evaluate your workplace for “cool-down areas” of sufficient space to accommodate any employees taking recovery, rest, or meal breaks. Measures will need to be taken to lower the temperature of this cool-down area below 82 degrees unless this is infeasible, and water must be provided to employees during work hours.

Contact Sierra HR Partners if you would like to discuss specific steps for implementing these requirements, including preparation or editing of your Heat Illness Prevention Plan.