The Occupational Safety and Health Administration (OSHA) has announced a National Emphasis Program (NEP) focused on heat hazards, effective April 8, 2022. Under the NEP, OSHA will be conducting proactive inspections for heat-related hazards—in both outdoor and indoor work environments. It thus behooves employers to ensure they have implemented appropriate safety measures to protect employees from such hazards before potentially coming under OSHA’s heat lamp—er, spotlight.
Namely, the NEP outlines certain triggers for heat-related inspections:
Bottom line: employers should be cognizant, particularly on hot days, that OSHA may come knocking. And if that happens, the NEP mandates several steps OSHA must take in inspecting heat-related hazards, including but not limited to:
The NEP marks the most recent in a series of OSHA efforts to address heat hazards in the workplace. Last fall, OSHA announced a National Enforcement Initiative and published an Advanced Notice of Proposed Rulemaking, which is the first step on the long path to a federal heat standard.
Given OSHA’s keen focus on heat hazards, employers—especially those in the targeted industries—can consider several steps now to best protect themselves and their employees. For example, employers should ensure their safety policies address heat-related hazards; implement acclimatization periods for new employees who are not yet adjusted to working full days in high heat; develop a means to monitor the heat index and employee exposure to heat; and train employees on heat-related illness and emergency response.