As the heat of summer continues, here’s what OSHA expects you to be doing for your crews

By Bethany C. McCurdy, Michael Best

The weather in the Midwest has reached into the low to mid-90s, lately, with heat indices even higher.  As usual, temperatures were even higher in southern areas of the country.  As we move into the hot days of summer, you should make sure you have measures in place to keep your employees cool.  OSHA has in place a new emphasis program that focuses on heat illness and injury in both indoor and outdoor settings.  Temperatures this high are in the Danger Zone on OSHA’s Heat Index app.  Your employees are likely not fully acclimatized/acclimated to the heat and under those circumstances, you should not only be sure your employees have access to water, shade, etc., but you may also want to consider reducing the time employees are exposed to the heat, increasing frequency of breaks, or perhaps starting earlier in the day.  If you have air conditioning, get that up and running as soon as possible, or bring in industrial fans to help keep the air moving (but watch those extension cords).

Also, as a reminder, the things OSHA looks for in a heat illness and injury program are:

  • Is there a written program?
  • How did the employer monitor ambient temperature(s) and levels of work exertion at the worksite?
  • Was there unlimited cool water that was easily accessible to the employees?
  • Did the employer require additional breaks for hydration?
  • Were there scheduled rest breaks?
  • Was there access to a shaded area?
  • Did the employer provide time for acclimatization of new and returning workers?
  • Was a “buddy” system in place on hot days?
  • Were administrative controls used (earlier start times, and employee/job rotation) to limit heat exposures?
  • Did the employer provide training on heat illness signs, how to report signs and symptoms, first aid, how to contact emergency personnel, prevention, and the importance of hydration?

They will also be on the lookout for:

  • Potential sources of heat-related illnesses (e.g., working in direct sunlight, a hot vehicle, or areas with hot air, near a gas engine, furnace, boiler, or steam lines),
  • The use of heavy or bulky clothing or equipment, including personal protective equipment,
  • Estimate workload exertions by observing the types of job tasks performed by employees and whether those activities can be categorized as moderate, heavy, or very heavy work, considering both average workload and peak workload,
  • Duration of exposure during which a worker is continuously or repeatedly performing moderate to strenuous activities.

This emphasis program allows OSHA to open up inspections on this issue alone.  As you know, once OSHA is on-site, anything in plain sight may be cited.  While this may seem a bit overwhelming, the main things to remember are Water, Rest, and Shade—that’s the mantra from OSHA.  So get those coolers out, water bottles chilled, and be ready for the heat.

Photo of Bethany McCurdyBethany C. McCurdy, Senior Counsel with Michael Best,
can be reached at or 414.225.2753.
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