OSHA just revised and extended its NEP on heat stress. What does this mean in practical terms for employers and workers?
Responding Lexi Hagler, product manager, heat stress mitigation, Ergodyne, St. Paul, MN.
The biggest takeaway from the update seems to be a shift to enforcement from awareness and data collection. It really formalizes the “how” and “when” for inspectors in a way that provides a possible preview of what a federal heat standard might eventually look like. By adding Appendix I: Evaluation of a Heat Program and Appendix J: Citation Guide to the national emphasis program, inspectors have the tools to move to enforcement from observation much faster.
Appendix I is an 11-item checklist that lays out exactly what officers will be looking for to determine if a program effectively satisfies requirements. Appendix J gives more definition around what constitutes a heat hazard, along with guidance for building a case under the General Duty Clause. And as helpful as these appendices are for enforcement, they’re equally helpful for employers. It basically turns compliance into an open-book test. It’s all there in black and white. Mirroring the structure of your heat safety program to Appendix I and familiarizing yourself with how officers are being instructed to issue citations (Appendix J) are your best bets for building a defensible program and ensuring a clean audit when that knock on your doors comes.
Responding Lexi Hagler, product manager, heat stress mitigation, Ergodyne, St. Paul, MN.
The biggest takeaway from the update seems to be a shift to enforcement from awareness and data collection. It really formalizes the “how” and “when” for inspectors in a way that provides a possible preview of what a federal heat standard might eventually look like. By adding Appendix I: Evaluation of a Heat Program and Appendix J: Citation Guide to the national emphasis program, inspectors have the tools to move to enforcement from observation much faster.
Appendix I is an 11-item checklist that lays out exactly what officers will be looking for to determine if a program effectively satisfies requirements. Appendix J gives more definition around what constitutes a heat hazard, along with guidance for building a case under the General Duty Clause. And as helpful as these appendices are for enforcement, they’re equally helpful for employers. It basically turns compliance into an open-book test. It’s all there in black and white. Mirroring the structure of your heat safety program to Appendix I and familiarizing yourself with how officers are being instructed to issue citations (Appendix J) are your best bets for building a defensible program and ensuring a clean audit when that knock on your doors comes.
It’s also important to make sure your efforts are as visible as possible. Optics matter. At this point, any compliance safety and health officer driving down the road on a heat priority day (when the heat index is 80° F or above) can pull up on your worksite and initiate an audit if they see a crew working with no shade or water stations in plain view.
The message from OSHA is clear: If heat safety programs weren’t already being treated like a documented, enforceable process, they should be now.
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Original article published by Safety+Health an NSC publication