MIOSHA-MEMO-COM-12-1R1
July 15, 2013
Heat-Related Illness Inspections
MIOSHAMichigan Occupational Safety and Health Administration
Department of Licensing and Regulatory Affairs / AGENCY
MEMORANDUM
DOCUMENT IDENTIFIER:
MIOSHA-MEMO-COM-12-1R1 / DATE: July 15, 2013
SUBJECT: Heat-Related Illness Inspections
I. Purpose:
/The purpose of this memorandum is to describe the enforcement aspect of the Michigan Occupational Safety and Health Administration (MIOSHA) heat-related illness campaign to raise awareness among workers and employers of the risks associated with working in hot environments.
II. Scope:
/This memorandum applies to compliance inspections conducted by the Construction Safety and Health Division (CSHD), the General Industry Safety and Health Division (GISHD) and consultative activities by the Consultation, Education and Training (CET) Division.
III. References:
/A. Centers for Disease Control and Prevention, Morbidity and Mortality Weekly Report (MMWR), Vol. 57: No. 24:647-653, June 20, 2008, Heat-Related Deaths Among Crop Workers --- United States, 1992—2006.
B. Occupational Safety and Health Administration (OSHA), TED 01-00-015 [TED 1-0.15A], January 20, 1999, OSHA Technical Manual.
IV. Distribution:
/MIOSHA Staff; OSHA Lansing Area Office; S-Drive Public Folder Accessible; MIOSHA Weekly; and Internet Accessible.
V. Contact:
/Patricia Meyer, Director, Construction Safety and Health Division (CSHD), Adrian Rocskay, Director, General Industry Safety and Health Division (GISHD), and Nella Davis-Ray, Director, Consultation, Education and Training (CET) Division
VI. Cancellations:
/This memorandum cancels all previous versions of this agency memorandum.
VII. History:
/History of previous versions include:
MIOSHA-MEMO-COM-12-1, January 6, 2012
VIII. Originator:
/ /Martha B. Yoder for/Barton G. Pickelman, Deputy Director
Michigan Occupational Safety and Health Administration
Significant Changes
Integrated Management Information System (IMIS) code for heat inspections in agriculture was added.
Added note to Appendix C.
Added more detailed references for historical weather data in Appendix G.
Added new Appendix H, General Duty Violation Conditions.
The purpose of this memorandum is to describe the enforcement aspect of the MIOSHA heat-related illness campaign to raise awareness among workers and employers of the risks associated with working in hot environments. The U.S. Centers for Disease Control and Prevention reported 423 heat-related deaths among workers in agricultural and non-agricultural worksites over a period from 1992-2006. The goal of the MIOSHA campaign is to raise employers' and workers' awareness and to prevent heat-related illnesses and deaths. The campaign focuses mainly on consultation and training of outdoor workers in the construction and agricultural industries. However, the enforcement component outlined in this memorandum sets forth the duty of employers to prevent heat-related illnesses and deaths in both indoor and outdoor workplaces.
Heat-related illnesses generally occur when body heat generated by physical work is exacerbated by ambient heat and humidity. Heat-related illnesses range from a mild form of heat cramps to heat stroke, which can lead to death.
Typical indoor worksites where heat-related illnesses may occur include foundries, brick-firing and ceramic plants, glass production facilities, rubber products factories, electrical utilities (particularly boiler rooms), bakeries, confectioneries, commercial kitchens, laundries, food canneries, chemical plants, mining sites, and smelters. Outdoor operations conducted in hot weather, such as agriculture, landscaping, construction operations, refining (gas and oil well operations), asbestos removal, and hazardous waste site activities, especially those that require wearing protective clothing, also may cause heat-related illnesses among exposed workers.
During inspection activity, safety officers and industrial hygienists (SO/IHs) should address heat-related illnesses at both indoor and outdoor worksites where potential heat-related hazards may exist, and inspections should include a review of the employers' plans to address heat exposure.
MIOSHA’s consultation program will use the same guidance as the enforcement divisions when addressing heat-related illnesses at both indoor and outdoor worksites where potential heat-related hazards may exist.
This memorandum outlines inspection guidance taken from the OSHA Technical Manual, Section III, Chapter 4. In addition, the following documents are attached:
Appendix A: Heat-Related Illness Inspection Guidance
Appendix B: Sample General Duty Clause Citations for Exposure to Heat Hazard
Appendix C: Heat Index Chart from National Oceanic and Atmospheric Administration (NOAA)
Appendix D: Employer Questionnaire
Appendix E: Employee Questionnaire
Appendix F: Sample Safety/Health Recommendation
Appendix G: Heat-Related Information Links
Appendix H: General Duty Violation Conditions
SO/IHs should use the attached information as a guide along with the OSHA Technical Manual when conducting heat-related investigations.
APPENDIX A
Heat-Related Illness Inspection Guidance
Purpose: To provide guidance to industrial hygienists (IHs) investigating workplace conditions that pose a risk of heat-related illness. MIOSHA does not have a regulation relating to working in hot environments. Any proposed citations for heat-related illnesses will be addressed by the general duty clause, section 11(a) of the Michigan Occupational Safety and Health Act (Act 154 of 1974, as amended). Heat-related illness violations will be issued for both indoor and outdoor work activities, but must only be issued when all elements of a general duty clause violation are documented and IHs can establish a link between the workplace exposure and the potential for heat-related illness(es). The Safety/Health Recommendation form may be used when all the general duty clause elements are not present. MIOSHA has regulations that may be applicable to work in hot environments including, but not limited to: personal protective equipment (PPE), sanitation, medical services and first aid, and recordkeeping.
Heat-Related Illnesses: During the course of any heat-related investigation, Safety Officers (SOs) /IHs may encounter a variety of heat-related illnesses such as the following:
· Heat Stroke / · Heat Collapse· Heat Exhaustion / · Heat Rashes
· Heat Cramps / · Heat Fatigue
Case File Documentation:
· In order for the agency to track its inspection activity on heat-related illnesses, it is essential to gather data related to this hazard. All inspections involving heat-related illnesses must be coded on the MIOSHA-1, in the box 42, Type: N, ID: 2, Value as either "HEATCON" (construction), "HEATGI" (general industry), or “HEATAG” (agriculture).
· Review MIOSHA 300 Logs for any entries indicating heat-related illness. Interview workers for reports of headache, dizziness, fainting, dehydration, or other symptoms that may indicate heat-related illnesses.
· Review injury and illness reports and obtain any records of emergency room visits and/or ambulance transport even if hospitalizations did not occur.
· Document the information listed in the attached questionnaires (Appendices D and E).
· Conduct a walk-around inspection and perform temperature measurements, including wet bulb globe temperature (WBGT) tests. Additionally, identify all potential sources of heat-related illnesses. The information obtained from employer and employee interviews should also be verified during the walk-around inspection. Consult the OSHA Technical Manual - Section III, Chapter 4 - Heat Stress for additional inspection procedures and documentation guidance.
· Document the heat index and any National Weather Service heat advisory or alert for the day of the inspection and/or the days employees became ill. (weather conditions, heat index, NOAA-advisory, wind speed/direction, relative humidity indoor/outdoor, direct sun)
· Document whether first aid or prompt medical attention are readily available.
A Section 11(a) citation shall be proposed for cases involving both indoor and outdoor workplace exposures when all the elements outlined in the Field Operation Manual (FOM) have been established and there is evidence of a serious heat-related hazard. Refer to the FOM, Chapter 6, Section II, for enforcement guidance on the application of the general duty clause.
Sampling Procedures:
· Conduct workload assessments. Information on performing workplace assessments can be obtained from the OSHA Technical Manual, Section III, Chapter 4.
· Conduct environmental sampling including wet-bulb globe temperature (WBGT) readings, which combine air temperature and humidity. Refer to the OSHA Technical Manual, Section III, Chapter 4, for information on conducting WBGT sampling.
Other Applicable Regulations:
· Both the occupational health PPE regulation, Part 433, Rule 5(1), and the general industry safety PPE regulation, Part 33, Rule 3308, require an employer to assess the workplace to determine if hazards are present, or likely to be present, that necessitate the use of PPE. The construction PPE regulation, Part 6, requires an employer to provide PPE.
· The administrative recordkeeping regulation, Part 11, requires that employers record certain work-related injuries and illnesses. If a worker requires medical treatment beyond first aid, the worker's illness or injury must be recorded.
· Both the construction sanitation regulation, Part 1, Rule 128(a), and the occupational health sanitation regulation, Part 474, Rule 420(2)(a)(i), require employers to provide potable water.
· The occupational health medical services and first aid regulation, Part 474, Rule 325.47201(2), requires that in the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, the employer shall ensure that a person or persons shall be adequately trained to render first aid. The construction medical services and first aid regulation, Part 1, Rule 132(3), requires a person who has a valid certificate in first aid training shall be present at the worksite to render first aid.
Appendix B
Sample General Duty Clause Citations for Exposure to Heat Hazard
The general layout for a citation of the general duty clause is described in agency instruction MIOSHA-COM-07-1, “Procedures for Writing SAVEs and Citations,” as amended. For employee exposure to excessive ambient heat, the following layout may be used:
MICHIGAN OCCUPATIONAL SAFETY AND HEALTH ACT, ACT 154, P.A. 1974, AS AMENDED, SECTION 11(a):
The employer did not furnish to each employee, employment and a place of employment, which was free from recognized hazards that were causing, or were likely to cause, death or serious physical harm to the employee. Employees were exposed to the hazard of excessive ambient heat from [specify the environmental or process sources generating the heat and any heat measurements taken] during the performance of their duties, which included [describe duties]. Such exposures may lead to the development of serious heat-related illnesses such as [describe heat-related illness(es) workers were at risk of developing; if there was an actual heat-related illness, then describe it]. [Describe any actions the employer took or failed to take that contributed to the risk of heat-related illness.]
Feasible and acceptable methods to abate this hazard include, but are not limited to:
1. Providing adequate amounts of cool, potable water and electrolyte replacements (specific recommendations should be made by medical consultation) in the work area and require employees to drink frequently.
2. Providing a work/rest regimen.
3. Training employees about the effects of heat-related illness, how to report and recognize heat-related illness symptoms and how to prevent heat-related illnesses.
4. Including a heat acclimatization program for new employees or employees returning to work from absences of three or more days.
5. Providing a cool, climate-controlled area where heat-affected employees may take their breaks and/or recover when signs and symptoms of heat-related illnesses are recognized.
6. Providing shaded areas where heat-affected employees may take their breaks and/or recover on worksites that do not have access to climate-controlled areas.
7. Providing specific procedures to be followed for heat-related emergency situations and procedures for first aid to be administered immediately to employees displaying symptoms of heat-related illness.
8. Using dermal patches for monitoring core temperature to better identify when workers need to be removed from the work area.
Sample No. 1:
MICHIGAN OCCUPATIONAL SAFETY AND HEALTH ACT, ACT 154, P.A. 1974, AS AMENDED, SECTION 11(a):
The employer did not furnish to each employee, employment and a place of employment, which was free from recognized hazards that were causing, or were likely to cause, death or serious physical harm to the employee. Employees who worked in the autoclave area were exposed to an indoor wet bulb globe temperature of 99.5 degrees Fahrenheit. Such exposures may lead to the development of serious heat-related illnesses such as heat cramps and heat exhaustion.
Feasible and acceptable methods of correcting this violation may include, but are not limited to, the following:
1. Develop a heat stress training program to inform employees about the effects of heat stress and how to recognize heat-related symptoms and prevent heat-induced illnesses.
2. Use cooling rooms, which can be used to offer a recovery area near hot jobs, and portable blowers with built-in air chillers, which can offer relief at the workstation.
3. Train employees to stay hydrated by drinking 5 to 7 ounces of water every 15 to 20 minutes throughout the work day and to avoid drinks with caffeine, alcohol, and large amounts of sugar.
4. Instruct employees to wear light-colored, loose-fitting, breathable clothing, such as cotton.
5. Implement a screening program to determine any causal factors that may affect the employee's heat illness susceptibility.
6. Establish a work/rest regimen so that exposure time to high temperatures and/or the work rate is decreased.
7. Utilize an acclimation program for new employees or employees returning to work from absences of three or more days.
8. Specify procedures to be followed for heat-related emergency situations.
9. Make provisions so that first-aid can be administered immediately to employees displaying symptoms of heat-related illness.
Sample No. 2:
MICHIGAN OCCUPATIONAL SAFETY AND HEALTH ACT, ACT 154, P.A. 1974, AS AMENDED, SECTION 11(a):
The employer did not furnish to each employee, employment and a place of employment, which was free from recognized hazards that were causing, or were likely to cause, death or serious physical harm to the employee. Each employee potentially exposed to the hazards of extreme heat was not fully trained in accordance with the employer's heat stress program.
Feasible abatement methods include, but are not limited to:
1. Providing employees training in appropriate languages (including annual training and training upon rehire) about the effects of heat stress and how to prevent, recognize, and report heat-related illness and implementing a record-keeping system to ensure that new employees receive such training, regardless of start date, prior to starting work.
2. Conducting daily pre-shift tailgate meetings on days involving extreme heat, during which employees will be reminded of the effects of heat stress, how to prevent heat-induced illness (such as, but not limited to, taking breaks to drink fluids, rest and protect from overheating, identifying places to cool off and the availability of cool, potable water and delivery of electrolyte replacement supplies at the worksite) and how to recognize, report, and respond to heat-induced illness.