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Preventing and Responding to Heat Illness

Elements of Your Written Program and Effective Work Practices

SHADE AND OTHER COOLING MEASURES

What is in T8CCR 3395?

T8CCR 3395(b) Definitions state:

“Shade” means blockage of direct sunlight. One indicator that blockage is sufficient is when objects do not cast a shadow in the area of blocked sunlight. Shade is not adequate when heat in the area of shade defeats the purpose of shade, which is to allow the body to cool. For example, a car sitting in the sun does not provide acceptable shade to a person inside it, unless the car is running with air conditioning. Shade may be provided by any natural or artificial means that does not expose employees to unsafe or unhealthy conditions.

T8CCR 3395(d) Access to shade states:

(1) Shade required to be present when the temperature exceeds 85 degrees Fahrenheit. When the outdoor temperature in the work area exceeds 85 degrees Fahrenheit, the employer shall have and maintain one or more areas with shade at all times while employees are present that are either open to the air or provided with ventilation or cooling. The amount of shade present shall be at least enough to accommodate 25% of the employees on the shift at any time, so that they can sit in a normal posture fully in the shade without having to be in physical contact with each other. The shaded area shall be located as close as practicable to the areas where employees are working.

(2) Shade required to be available when the temperature does not exceed 85 degrees Fahrenheit. When the outdoor temperature in the work area does not exceed 85 degrees Fahrenheit employers shall either provide shade as per subsection (d)(1) or provide timely access to shade upon an employee's request.

(3) Employees shall be allowed and encouraged to take a cool-down rest in the shade for a period of no less than five minutes at a time when they feel the need to do so to protect themselves from overheating. Such access to shade shall be permitted at all times.

Exceptions to subsection (d):

(1) Where the employer can demonstrate that it is infeasible or unsafe to have a shade structure, or otherwise to have shade present on a continuous basis, the employer may utilize alternative procedures for providing access to shade if the alternative procedures provide equivalent protection.

(2) Except for employers in the agricultural industry, cooling measures other than shade (e.g., use of misting machines) may be provided in lieu of shade if the employer can demonstrate that these measures are at least as effective as shade in allowing employees to cool.

Best Practices and Warnings

To prevent heat illness, there must be a balance between heat load on the body (heat produced internally by the body and gained from external sources) and heat released from the body to allow the body to cool.

You can provide shade to employees to allow their bodies to cool during breaks (see Benefits of Rest Breaks), at lunch, or during a cool down rest periods (see Cool Down Rest Periods) should one become necessary. Except for employers in Agriculture, you can use one or more Alternative Cooling Measures (in lieu of shade) to provide cooling to your employees, see Shade and Other Cooling Measures. To use these Alternative Cooling Measures you must make sure they are safe to use for the conditions in your workplace and demonstrate that they are at least as effective as shade in allowing employees to cool. Also, during high heat you may need to add one or more Alternative Cooling Measures to prevent heat illness.

No matter how you choose to provide cooling for your employees remember to ensure that:

  • Sufficient supplies of potable drinking water are close by
  • Individuals are encouraged to frequently drink sufficient amounts of water
  • Employees are able to assume comfortable body postures

Ways To Provide Cooling


Best Practices

Ways to Provide Shade

You can provide cooling from shade by using:

  • Pop-ups

    Mobile shading

  • Canopies

    Mobile shading  Mobile shading

  • Umbrellas

    Umbrella used for shade  Umbrella used for shade

  • Structures that are mechanically ventilated or open to air movement (e.g., semi finished garages or other unfinished structures). If two or more stories are available employees can rest in the lowest floor in the shade.

    Permanent shade  Men drinking water

  • Tarpaulins tied to 4 posts
  • Lean-tos
  • Conex mounted RV canopies
  • Full and thick tree canopies that block direct sunlight
  • Buildings
  • Enclosed areas only if they provide cooling comparable to shade in the open air

Providing Cooling from Shade

  • It is a good idea to set up the shade in advance, if at 5:00 p.m. the night before, the temperature is predicted to exceed 85 F. Or if you want to monitor the temperature during the work hours, perform hourly checks of the temperature at the worksite on the day of work and set up the shade immediately if the temperatures exceeds 85 Degrees.
  • Set-up in advance portable umbrellas, canopies, and other portable devices used for providing shade

    Drinking water in shaded area

  • Move portable shade areas as close to work areas as possible.
  • In situations where trees or other vegetation are used to provide shade, have a designated person evaluate the thickness and shape of the shaded area before assuming that sufficient shadow is being cast to protect employees throughout the shift.
  • Have a designated person to point out the daily location of the shade structures to the workers.
  • Do not let employees sit directly on the ground as it may add more heat to the body. Instead, provide blankets, chairs, benches, etc.
  • 2 weeks in advance (or as many days in advance as possible), go on the internet (www.noaa.gov), call the National Weather Service or check the Weather Channel TV to view the extended weather forecast in order to plan in advance the work schedule. Find out whether high heat is expected and if additional work schedule modifications will be necessary. This type of advance planning should take place all summer long.
  • Prior to each workday, have a designated person monitor the weather using www.noaa.gov or a thermometer at the worksite see Monitor The Weather. Based on the weather, make modifications to the work schedule such as stopping work early, rescheduling the job, working at night or during the cooler hours of the day, and increasing the number of water and rest breaks. The designated person can check the temperature every 60 minutes to ensure that once the temperature:
    • exceeds 85 degrees Fahrenheit, the shade structures are accessible to the workers.
    • equals or exceeds 95 degrees Fahrenheit High Heat Procedures are implemented.

Warning

Shade is adequate only when it completely blocks the direct sunlight and allows the body to cool. In adequate shade people and objects in the shade do not cast shadows in the area of blocked sunlight. Shade is not adequate when it does not allow the body to cool.

Do not provide shade by using:

  • Metal storage sheds and other similar out-buildings unless they provide a cooling environment comparable to shade in the open air
  • The interior of vehicles. This is because they keep heating up in the sun and do not provide cooling unless the air-conditioning system is continually running and working effectively
  • Areas underneath or near equipment (e.g., tractors) or vehicles as they expose employees to other potential hazards

Smart Tips

Other Cooling Measures

You can use alternative ways to cool the body besides shade except if you are in agriculture. Before using alternative cooling measures make sure they are safe to use for the conditions in your workplace and you must demonstrate that they are at least as effective as shade in allowing employees to cool

Alternative cooling measures include, but are not limited to, cooling employees by:

  • Putting them in an air-conditioned environment, if available
  • Using misting machines
  • Using cooling vests (e.g., commercially available ice vests)
  • Using water-cooled garments (e.g., hoods, vests and "long johns"). These require a battery-driven circulating pump, liquid-ice coolant, and a container
  • Using battery operated, portable cooling devices or equipment
  • Using air cooled garments (e.g., suits or hoods)