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Preventing and Responding to Heat Illness

What is Required from T8 CCR 3395?

Written Procedures - There are four training topics listed that must be in writing and must be made available to employees and to representatives of the Division of Occupational Safety and Health (DOSH) upon request. They include the employers’ procedures for:

  • Complying with the requirements of T8 CCR 3395
  • Responding to symptoms of possible heat illness, including how emergency medical services will be provided should they become necessary
  • Contacting emergency medical services, and if necessary, for transporting employees to a point where they can be reached by an emergency medical service provider
  • Ensuring that, in the event of an emergency, clear and precise directions to the work site can and will be provided as needed to emergency responders.

Provision of Water - Employees shall have access to potable drinking water meeting the requirements of T8 CCR 1524, 3363, and 3457, as applicable. Where it is not plumbed or otherwise continuously supplied, it shall be provided in sufficient quantity at the beginning of the work shift to provide one quart per employee per hour for drinking for the entire shift. Employers may begin the shift with smaller quantities of water if they have effective procedures for replenishment during the shift as needed to allow employees to drink one quart or more per hour. The frequent drinking of water, as described in Employee Training, shall be encouraged (see 1. Sufficient Amounts of Drinking Water).

Shade – means blockage of direct sunlight. Canopies, umbrellas and other temporary structures or devices may be used to provide shade. 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. (see 2. Shade and Other Cooling Measures).

Preventative Recovery Period - means a period of time to recover from the heat in order to prevent heat illness (see 2. Shade and Other Cooling Measures and 4. Preventative Recovery Periods).

Access to Shade - Employees suffering from heat illness or believing a preventative recovery period is needed, shall be provided access to an area with shade that is either open to the air or provided with ventilation or cooling for a period of no less than five minutes. Such access to shade shall be permitted at all times. Except for employers in the agriculture 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 (see 2. Shade and Other Cooling Measures and 4. Preventative Recovery Periods).

Acclimatization - means temporary adaptation of the body to work in the heat that occurs gradually when a person is exposed to it. Acclimatization peaks in most people within four to fourteen days of regular work for at least two hours per day in the heat (see 5. Acclimatization).

Training in all the following topics must be provided to all supervisory and non-supervisory employees.

Employee training (see Training) topics include the:

  • Environmental and personal risk factors for heat illness
  • Employer’s procedures for complying with the requirements of T8 CCR 3395
  • Importance of frequent consumption of small quantities of water, up to 4 cups per hour, when the work environment is hot and employees are likely to be sweating more than usual in the performance of their duties
  • Importance of acclimatization
  • Different types of heat illness and the common signs and symptoms of heat illness
  • Importance to employees of immediately reporting to the employer, directly or through the employee's supervisor, symptoms or signs of heat illness in themselves, or in coworkers
  • Employer’s procedures for responding to symptoms of possible heat illness, including how emergency medical services will be provided should they become necessary (*)
  • Employer’s procedures for contacting emergency medical services, and if necessary, for transporting employees to a point where they can be reached by an emergency medical service provider (*)
  • Employer’s procedures for ensuring that, in the event of an emergency, clear and precise directions to the worksite can and will be provided as needed to emergency responders. (*)

Supervisor training (see Training) - Prior to assignment to supervision of employees working in the heat, training on the following topics must be provided including the:

  • Information required to be provided by the employee training section above
  • Procedures the supervisor is to follow when an employee exhibits symptoms consistent with possible heat illness, including emergency response procedure. (*)
  • Procedures the supervisor is to follow to implement the applicable provisions of T8 CCR 3395

(*) Shown above means for more information see Smart Tips for Providing Emergency Response

Other Regulatory Requirements

  1. Ensure the availability of personnel certified to provide first aid at their work sites (see T8 CCR 1512, 3400, 3421, 3439, 6251).

Best Practises - Your Written Program

Cal/OSHA investigations showed that in 80% of the cases in which suspected heat illness occurred, the employer did not have a heat illness prevention program. Heat illness is preventable. Preventing heat illness protects your workers and is good business. Health and safety problems and other health problems like heart attacks and falls, may result from heat illness at the workplace. Heat illness may increase the costs of doing business by:

  • Reducing employee productivity and efficiency
  • Increasing your medical and emergency services costs
  • Taking up supervisory and administrative time
  • Increasing workers’ compensation premiums

Smart Tips

The best way to prevent and respond to heat illness is to put into place an effective written program. To maximize the effectiveness of your program consider the following:

  • Tailor it to include procedures and measures that apply to your particular work site, activities and employees at any given point in time
  • Put into place the necessary work practices to prevent, recognize, and respond to heat illness
  • Communicate your work practices to employees in real time
  • Build in flexibility by adjusting your work practices so you are prepared to respond as temperature and other risk factors change throughout the work day

To assist you in developing and putting into place your Written Heat Illness Prevention Program, see the follows information: