Heat Illness Prevention Enforcement Q&A
Updated: July 2018
- Where and when does this standard apply?
- What is meant by "outdoor places of employment"?
- Are there other regulations that apply to the risk of heat illness?
- What are the environmental risk factors for heat illness?
- What is the best way to monitor the weather and evaluate the severity of environmental risk factors for heat illness?
- What is considered sufficient access to drinking water?
- What is considered sufficient access to shade?
- What are high-heat procedures and what industries are required to comply with this subsection?
- What emergency response procedures must an employer implement?
- What is acclimatization, and how should employers address it under the heat-illness prevention standard?
- How is training evaluated for compliance with the standard?
- What written procedures should an employer develop to comply with the requirements of this standard?
- Where can I get more information on heat illness?
Where and when does this standard apply?
This standard applies to all outdoor places of employment. In addition, the following industries are subject to additional requirements in high heat (temperature that equals or exceeds 95 F)
(see Q&A No. 8a and 8b):
- Oil and gas extraction, and
- Transportation and delivery of agricultural products and of construction or other heavy materials (e.g., furniture, lumber, freight, cargo, cabinets, industrial or commercial materials).
The standard's provisions apply at all times when employees work outdoors. Some provisions are triggered at specific times, for instance, the shade requirement described in Q&A No. 7 and the High-Heat Procedures addressed by Q&A No. 8a.
What is meant by "outdoor places of employment"?
An outdoor place of employment is best thought of as one that is not an indoor workplace. A workplace with a roof and enclosed sides is generally considered an indoor workplace.
For the purposes of this standard, the distinguishing quality of indoor workplaces is that they reduce the risk factors that commonly lead to heat illness. (For information about environmental risk factors for heat illness, see Q&A Nos. 4 and 5.)
For example, a building that provides sufficient ventilation and cooling, either by natural or mechanical means, and blocks exposure to direct sunlight will be considered an indoor workplace. Sheds, packing sheds, and partial or temporary structures such as tents, lean-tos, and structures with one or more open sides can be either indoor or outdoor workplaces depending on the circumstances.
In many cases, these structures may actually be hotter than the environment outside of them because of heating by the sun and conditions inside like limited air circulation or lack of insulation. A structure in this category may be considered an outdoor workplace if it does not significantly reduce the net effect of the environmental risk factors that exist immediately outside of the structure.
On the other hand, open areas like agricultural fields, forests, parks, equipment and storage yards, outdoor utility installations, tarmacs, and roads are obvious examples of outdoor workplaces. Outdoor workplaces also include construction sites in which no building shell has been completed and areas of construction sites that are outside of any building shells that may be present. Outdoor areas adjacent to buildings (e.g., loading docks) may also be considered outdoor places of employment.
Are there other regulations that apply to the risk of heat illness in outdoor places of employment?
Yes. They include requirements for employers to have an effective Injury and Illness Prevention Program (IIPP) and to provide for drinking water, first aid, and emergency response. There are also requirements tailored to specific industrial operations. Areas where these regulations overlap or augment 8 CCR §3395 will be noted in the more specific sections below.
Employers should note, however, that 8 CCR §3203 requires an employer to establish, implement, and maintain an effective IIPP. All IIPPs must include effective procedures for hazard identification, evaluation, and control, hazard correction, investigation of employee injuries and illnesses, and communication with employees about health and safety matters. All of these requirements apply to the hazards posed by exposure to outdoor heat as well as other hazards.
The requirement for effective communication is particularly relevant to heat illness prevention. In evaluating compliance with this requirement, Cal/OSHA determines what the employer does to account for the whereabouts of all employees at appropriate intervals during the work shift and at the end of the shift. This is a critical procedure to follow when the outdoor work environment creates a heat hazard that could result in the collapse of an employee due to heat illness.
What are the environmental risk factors for heat illness?
8 CCR §3395 defines environmental risk factors for heat illness as including ". . . air temperature, relative humidity, radiant heat from the sun and other sources, conductive heat sources such as the ground, air movement, workload severity and duration, protective clothing and personal protective equipment worn by employees."
Some of these factors, in particular air temperature, radiant heat, air movement, and conductive heat sources, determine how much an employee's body is heated from external sources. Relative humidity, air movement, protective clothing, and some personal protective equipment affect an employee's ability to cool through the evaporation of sweat and contact with cooler air. Workload intensity and duration, which can be increased by use of personal protective equipment, add to the employee's heat burden by producing metabolic heat.
It is essential and required that supervisors and workers be effectively trained to understand how environmental and personal risk factors, as well as the added burden of heat load on the body caused by exertion, clothing, and personal protective equipment, can increase the risk of heat illness.
For example, some employees can be at risk of heat illness even when temperatures are considered mild, if they wear chemical protective clothing such as hazardous material (HAZMAT) suits designed to be impervious or resistant to liquids, or other clothing or body coverings that significantly interfere with the body's ability to dissipate heat compared with normal clothing. Water, emergency procedure, and certain shade requirements are applicable all year round, but employers should also address the particular hazards presented by these conditions in their Heat Illness Prevention Program.
What is the best way to monitor the weather and evaluate the severity of environmental risk factors for heat illness?
Some requirements of the standard are triggered by outside temperatures. It is, therefore, critical that employers track the weather and routinely check for approaching heat waves. Heat waves are one of the main causes of heat-related illnesses and fatalities in the state. For example, according to an analysis by Cal/OSHA of heat related illnesses in 2006, 84% of the confirmed occupational heat illnesses in 2006 occurred during the July heat wave.
This analysis also identified the key role that supervisors play in preventing worker fatalities due to heat illness. This finding highlights the value of training supervisors so that they can make the fullest use of their supervisory power to control safety on the job. Knowing how to monitor weather reports, making it a daily practice to do so, and taking appropriate action in response to predicted hot weather are all an essential part of a supervisor's training, hence the requirement that this training be provided to all supervisors whose employees perform outdoor work.
The supervisor should use a thermometer to keep track of the temperature at the worksite on hot days. A simple thermometer available at hardware stores can be used to measure the outdoor ("dry bulb") temperature, as long as it is taken in an area where there is no shade. The temperature measurement must be taken in an area with full sunlight and the bulb or sensor of the thermometer should be shielded from direct contact with sunlight (with the hand or some other object) while taking the measurement.
What is considered sufficient access to drinking water?
Adequate water is required at all times, regardless of outdoor temperature and must be made available at no cost to the employee.
Water is the body's single best defense against heat other than removing heat exposure itself. In conditions of high heat and strenuous work, the human body can lose over a quart of fluid per hour just by sweating. Continuous replacement of this lost fluid is critical to allowing the body to maintain the life-preserving cooling benefits of perspiration. This is why it is so important to ensure the presence of, ready access to, and consumption of pure, fresh, and cool drinking water.
The water must be potable (i.e., fit to drink), fresh, pure, suitably cool, and provided to employees free of charge. Water must be located as close as practicable to the areas where employees are working. The purpose of these requirements is to encourage workers to drink water often and avoid making the workers interrupt their work in order to do so. To ensure that water is fresh, pure, and suitably cool, Cal/OSHA advises employers or supervisors to visually examine and smell/taste the water and pour some on their skin.
- When is water fresh and pure?
Water must be potable (i.e., fit to drink) and free from odors that would discourage workers from drinking it. If an employer supplies individual water containers, the containers must be clean, and a source of potable water (e.g., a municipal water source) must be readily available. Water from non-approved or non-tested water sources (e.g., untested wells) is not acceptable. If hoses or connections are used, they must be manufacture-approved for potable drinking water systems, as shown on the manufacturer's label.
- When is water suitably cool?
Water provided to employees, whether by Igloo® or other container, is not required to be maintained at a specific temperature. Rather, the employer should ensure that the water is cool enough to be pleasant and not so cool as to cause discomfort. In hot weather, it is recommended that employers have ice on hand to keep the water cool.
- When is water as close as practicable to where employees are working?
Potable drinking water must always be placed in locations readily accessible to all employees, so that employees can easily drink while working. When an employee has to interrupt work in order to drink, the chances go down that the employee will drink enough water to protect fully against heat illness. Employers are, therefore, encouraged to consider creative means of placing water near working employees (for instance, on harvesting machinery).
During a Cal/OSHA inspection, the inspector may ask the supervisor to describe the factors the employer considered in deciding where to place water. For example, although the employer may state it is impossible to place water stations within rows of crops where employees are working, it may be possible to place the water stations at the end of rows. Because water containers are smaller than shade structures, they can be placed closer to employees than shade structures. Placing water only in designated shade areas or where toilet facilities are located may not be sufficient. When employees are working across large areas, water should be placed in multiple locations. For example, on a multi-story construction site, water should be placed in a safely accessible location on every floor where employees are working.
Employers may supply employees with individual water bottles/containers (preferably insulated) provided hygiene is ensured (i.e., clean bottles for each employee) and a source for water replenishment is readily available. It is not permissible for an employer to require employees to supply their own water or water containers, even if the employer reimburses the employees for the cost.
- What is the required amount of water and what are "effective procedures for replenishment"?
When unlimited drinking water is not immediately available from a plumbed system or otherwise continuously supplied, the employer must provide enough water for every employee to be able to drink one quart of water, or four eight-ounce cups, per hour.
If an employer chooses not to provide the full-shift quantity of drinking water at the start of a work shift (e.g., two gallons per employee for an eight-hour shift), the standard requires effective written procedures for drinking-water replenishment allowing each employee to drink one quart per hour. In other words, a sufficient quantity of water must always be present and readily accessible allowing every employee to consume at least one quart of water per hour until the water supply has been replenished.
A water-supply procedure that depends on replenishment during the work shift is out of compliance if it is not reliable. An employer is also out of compliance if at any time drinking water is not available to employees, or if the practice is to wait until the water vessel is empty to replenish it. It is similarly impermissible for an employer to replenish the drinking-water supply only when requested by employees.
- What is meant by encouragement to drink water?
The standard requires not only that water be provided, but that employers encourage employees to drink it frequently. The importance of this cannot be overstated. Employees are there to work, and many of them may not feel how urgently their bodies need water. The 2006 Cal/OSHA Heat Illness analysis showed that although 90% of the worksites had drinking water at the site, 96% of the employees suffering from heat illnesses were dehydrated.
The tendency of employees to be unaware of and/or not respond to their body's need to hydrate is an unfortunate but preventable cause of heat illness.
In their employee training sessions, employers must emphasize the importance of drinking water frequently throughout the day, especially in high heat. By removing any barriers that may exist to access, making the access distance as short as reasonable, and making the water station inviting by using ice and shade, employers can actively facilitate and encourage the frequent drinking of water.
- Are there other regulations that apply to the provision of water?
Yes. The following Title 8 standards apply to the provision of drinking water:
- Construction: 8 CCR §1524
- Hand labor in agriculture: 8 CCR §3457
- Mining: 8 CCR §6975
- All other places of employment: 8 CCR §3363
These standards require employers to provide sufficient quantities of drinking water in the work settings covered by the particular standard.
- When is water fresh and pure?
What is considered sufficient access to shade?
- When must shade be provided?
When temperatures exceed 80 F, shade structures must be erected if no other shade is readily available.
Even if temperatures do not exceed 80 F, employers must still provide timely access to shade if requested by an employee. It is helpful to have the shade erected if the weather is hot enough that the shade can help employees cool off.
Employers should monitor predicted weather temperatures in advance (on television, radio or the internet) to know when the temperature is likely to exceed 80 F. Employers are expected to know if the temperature is in fact exceeding 80 F at the worksite.
- What are appropriate sources of shade?
Shade may be provided by any natural or artificial means that do not expose employees to unsafe or unhealthy conditions and do not deter or discourage use.
For example, buildings, canopies, lean-tos, or other partial or temporary structures that are either ventilated or open to air movement may provide shade. Trees can also provide shade that is superior to artificially provided shade and are accepted as compliant sources of shade if the following conditions are met:
- The canopy of the trees must be sufficiently dense to provide substantially complete blockage of direct sunlight, and
- The branches from the trees must not be so low to the ground that employees must crouch or cannot sit up straight without contacting vegetation.
Spots of sunlight are acceptable as long as, overall, the shade provides substantially complete blockage of sunlight. Where trees or other vegetation are used to provide shade, the thickness and shape of the canopy must, given the changing angles of the sun, result in a sufficient shadow being cast to protect employees from the sun during the entire shift.
The interior of a vehicle may not be used to provide shade unless the vehicle is air-conditioned and the air conditioner is running throughout the workday. Similarly, metal storage sheds and other outbuildings do not provide protection from sunlight which meets the definition of shade unless they provide a cooling environment comparable to shade in open air (i.e., they must be mechanically ventilated or open to air movement).
- When is shade of sufficient quality?
Shade is blockage of direct sunlight. Blockage is sufficient when objects do not cast a shadow in the shaded area. An enclosed area used to provide shade must allow cooling at least comparable to the cooling that would be provided in a shaded unenclosed area in the same location.
- What is acceptable access and location?
Shade must be easy for employees to reach and its location must not deter or discourage access or use. Workers should not have to encounter any obstacles or hazardous or unreasonably unpleasant conditions to reach the shade or while resting in it. For example, employees should not have to cross traffic or waterways to reach the shade nor should it be located next to portable toilet facilities or where employees would sit on wet or muddy ground or come in contact with branches, brush, and thorns.
The shaded area must let employees assume a comfortable posture and must not cause exposure to another health or safety hazard. Therefore, the shade requirement cannot be met by using areas underneath mobile equipment, like a tractor, or areas that require employees to crouch in order to sit fully in the shade.
The shade, whether natural or structural, must be as close as practicable to where employees are working, given the working conditions and layout of the worksite. During a Cal/OSHA inspection, the inspector may ask the supervisor to describe the factors the employer considered in deciding where to place shade structures. Because shade is more portable than bathroom facilities, it can and should be placed closer to where employees work. This may involve placing shade structures in multiple areas over large worksites and/or moving the structures as the work area changes (such as movement across fields and rows).
- How much shade must be available?
Employers must ensure there is enough shade for all employees taking a rest and recovery period (breaks) at any one time to sit comfortably and fully in the shade without touching each other. This does not mean that employers are required to provide enough shade to accommodate all of the employees on the shift at the same time. Employers may, for example, rotate the breaks among employees. They may also erect additional structures on an as-needed basis. Any such procedure must be clearly and accurately described in the employer's written Heat Illness Prevention Plan.
The rules and recommendations described above for breaks also apply to meal breaks. The only difference is that employers are required to provide shade for all employees who choose to remain in the general area of work or in areas designated for recovery and rest periods. Employers may rotate employees in and out of meal periods, like with recovery and rest periods. Employers are not required to provide shade for employees who choose to spend meal periods in their own air-conditioned vehicles. However, employers may not require or pressure employees to eat their lunch in their own vehicles or go off site to eat.
- What if it is unsafe to provide a shade structure?
When providing a shade structure would be unsafe or infeasible, the employer may provide alternate access to shade that provides equivalent protection.
For example, it may be unsafe to erect a shade structure near the edge of a trench or ravine, or when high winds could cause a shade structure placed near workers to blow away and hit them or create a hazard to others in the area. Furthermore, establishing a shade structure on a continuous basis may be infeasible for employees who constantly move from site to site (e.g., meter readers or irrigation installers). In these cases, the employer must document this determination and specify what alternatives to shade will be provided to afford equivalent protection.
- When may employers use cooling measures other than shade?
Nonagricultural employers may provide cooling measures other than shade if they can demonstrate that the alternative is at least as effective as shade.
For example, misting machines are acceptable when the employer can demonstrate that they are at least as effective as shade at allowing the body to cool.
- What are the requirements for encouraging workers to rest in the shade?
The employer is required to allow and encourage employees 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. Waiting until symptoms appear before seeking shade and recovery creates a significant risk of developing heat illness. It is crucial that workers not be rushed while taking the cool-down rest, since the purpose of the cool-down rest in the shade is to reduce heat stress on the employee. Shade removes sunlight as a source of heat, and since people produce more metabolic heat while working, resting out of direct sunlight reduces heat stress while also reducing the heart rate.
Encouraging employees to take a cool-down rest in the shade is of primary importance particularly for employees who are paid on a piece-rate basis, as they would be less inclined to use this preventive rest. Water should be available in the rest area so that employees are encouraged to drink more water.
Employees must be monitored during a cool-down rest and asked if they are experiencing any symptoms of heat illness, including simple fatigue. If any signs or symptoms of heat illness are observed or reported, the employer must not order the employee back to work and must continuously observe the employee until the signs or symptoms have abated. Common early signs and symptoms of heat illness may include pale skin, heavy sweating, headache, muscle cramps, and fatigue. If no sign or symptom of heat illness is observed or reported, monitoring may be periodic, rather than continuous.
If an employee exhibits or complains of any sign or symptom of heat illness, appropriate first aid, and emergency response procedures (if necessary) should be initiated without delay. Progression to more serious illness can be rapid and can include altered coordination and speech, mental confusion, unusual behavior, nausea, vomiting, hot dry skin, unusually profuse sweating, loss of consciousness, and seizures. The affected employee may be unable to self-diagnose these problems.
If heat illness is suspected, emergency medical personnel should be contacted immediately. No employee with signs or symptoms of heat illness should be left unattended or sent home without being offered onsite first aid or provided emergency medical services, as discussed in subsection (f) of 8 CCR §3395 (see Q&A No.9).
"Preventative cool-down rest periods" at agricultural worksites are discussed in subsection (e) of 8 CCR §3395 (see Q&A No.8d).
- When must shade be provided?
What are high-heat procedures and what industries are required to comply with this subsection?
High heat procedures apply to the following industries:
- Landscaping (except for employment by an employer who operates a fixed establishment where the work is to be performed and where drinking water is plumbed),
- Oil and gas extraction, and
- Transportation (except for employment that consists of operating an air-conditioned vehicle and does not include loading and unloading).
When temperatures reach or exceed 95 F, employers listed in the industries noted above must implement the high-heat preventive procedures listed in subsection (e) of 8 CCR §3395 and described below:
- How should employers monitor employees during high heat?
During periods of high heat, it is crucial that employees be monitored for early signs and symptoms of heat illness to help ensure that sick employees receive treatment immediately and progression to serious illness is arrested. If an employee suffers syncope (fainting), disorientation, loss of consciousness, or other symptoms of heat illness while working unobserved, initial medical treatment may be delayed, resulting in a serious or fatal illness.
Because each worksite is unique, the standard gives employers options and flexibility in observing and monitoring employees. When employees work in small groups of no more than 20 workers, direct observation by a supervisor or designee may be sufficient. When there are too many employees to allow direct observation, the employer may use the buddy system and pair up employees. With the buddy system, the employer must train the employees to stay in contact, observe each other throughout the day, and immediately report any signs or symptoms of heat illness. For employees who are required to work alone, the employer may communicate with the employee by radio or cell phone, provided there is adequate coverage. The employee must be contacted regularly and as frequently as practicable throughout the day, since an employee in distress may not be able to summon help on his or her own.
Employers may use different methods to monitor for heat illness. Whatever method is used, the employer must be able to ascertain the condition of employees at regular intervals and provide emergency services when an employee reports symptoms of heat illness or is unable to respond.
- Who should be authorized to call for emergency services?
All employees must be trained to recognize the signs and symptoms of heat illness and must be allowed to call for emergency medical services when necessary. If, however, all employees in a crew are designated to call for emergency medical services, many will be reluctant to do so. Therefore, employers should specifically assign one or a small number of employees per crew to call for emergency medical services. A designated employee may be either supervisory or non-supervisory.
- When pre-shift meetings are required, what should they cover?
Pre-shift meetings are meant to provide supervisors and employees with a brief review of high-heat procedures. The meetings are not meant to review every element previously covered in regular training or in orientation. The employer may determine whether the training is required based on the predicted temperature in the area.
Topics that should be covered in pre-shift meetings include staying hydrated and taking cool-down rests, identifying the employees who should call for emergency medical services when needed, and how employees will be observed. For employees working remotely, the employer may conduct pre-shift meetings by cell phone or radio.
- When are preventative cool-down rest periods required in agriculture?
When temperatures reach or exceed 95 F, employers must provide one ten-minute "preventative cool-down rest period" every 2 hours. During the first 8 hours of a shift, the cool-down periods may be provided at the same time as the rest periods already required by Industrial Welfare Commission Order No. 14 (8 CCR §11140). Such rest periods must be counted as hours worked.
If employees work longer than 8 hours, the employer must provide an additional 10-minute cool-down rest period every 2 hours. For example, if the shift extends beyond 8 hours, an additional rest period is required at the end of the eighth hour of work. If the shift extends beyond 10 hours, another is required at the end of the tenth hour.
Employers must ensure that employees actually take the cool-down rest periods required under this section. Merely offering the opportunity for a break is not enough.
Employers are required to provide additional breaks as soon as the temperature equals or exceeds 95 F. For example, even if the temperature does not reach 95 F until the last half of an eight-hour shift, the employer must ensure that employees take cool-down rest periods starting at the end of the eighth hour of work if the shift will last longer than eight hours.
Cal/OSHA does not require employers to keep records of breaks issued under this section, but doing so is the best practice and would benefit them.
What emergency response procedures must an employer implement?
The importance of rapidly and effectively obtaining emergency medical services in the event of a serious injury or illness cannot be overstated. Particularly at non-fixed worksites or at sites that are difficult to locate or access, the employer, having evaluated whether the worksite is served by the 911 system, needs to be ready to contact and communicate with emergency responders.
Emergency medical services must be provided as quickly as possible if an employee suffers heat illness. The employer's procedures must include contacting emergency medical services when necessary, as well as taking immediate steps to keep a stricken employee cool and comfortable once emergency service responders have been called. The goal is to stop the rapid progression to more serious illness, which can include mental confusion, loss of consciousness, and seizures.
As a result, employers must ensure that supervisors and employees are trained to recognize the signs and symptoms of heat illness, take steps immediately to prevent the progression of heat illness, provide basic first aid (such as cooling towels and shade), obtain emergency medical services, and not allow an employee with signs or symptoms of heat illness to be left alone or sent home without being offered onsite first aid or provided with emergency medical services. Employers, however, are not required to provide medical personnel on site, and supervisors and employees are not expected to have medical expertise to diagnose heat illness.
Establishing emergency response procedures is particularly important at non-fixed or remote worksites or worksites that are difficult to locate or access. If employees cannot reach emergency medical services directly (because cell phone coverage is inadequate, for example), the employer must designate a person who can immediately contact emergency services on behalf of the employees and can provide emergency services with accurate directions to the worksite. The employees must be able to reach this person quickly (such as by radio) to request that emergency medical services be summoned.
If, however, employees are able to contact emergency medical services directly, they must be allowed to do so in an emergency and must not be required to contact a supervisor first.
Employers must be prepared to transport employees safely to a place where they can be reached by an emergency medical provider where necessary. Mobile crews must be provided with a map of their location or detailed, clear, and precise directions that can be given to emergency responders.
Employers should also be aware that the following title 8 regulations require first aid and emergency responses in specific industries:
- Construction: 8 CCR §1512
- All other places of employment: 8 CCR §3400
- Agriculture: 8 CCR §3439
- Logging and sawmills: 8 CCR §6251
- Petroleum drilling and production: 8 CCR §6511-6512
- Petroleum refining, transportation and handling: 8 CCR §6767
- Tunneling: 8 CCR §8420-8421
- Telecommunications: 8 CCR §8602(e)
What is acclimatization, and how should employers address it under the heat-illness prevention standard?
Acclimatization is a process by which the body adjusts to increased heat exposure. The body needs time to adapt when working in hotter environments. Employees are more like to develop heat illness if they are not allowed or encouraged to take it easy when a heat wave strikes or when starting a job that newly exposes them to heat. Acclimatization is fully achieved in most people within 4 to 14 days of regular work involving at least 2 hours per day in the heat.
During heat waves, employers must be vigilant, especially with new employees who are not acclimatized. A supervisor or designee must closely observe employees. Best practices include finding ways to lessen the intensity of employees' work during a heat wave and during two-week break-in periods of new employees.
For purposes of this section, "heat wave" means any day in which the predicted high temperature for the day will be at least 80 F and at least 10 degrees Fahrenheit higher than the average high daily temperature for the preceding five days.
How is training evaluated for compliance with the standard?
Employers must train all employees, both supervisory and nonsupervisory, on the risk factors for heat illness, signs and symptoms of heat illness, methods to prevent heat illness, and policies and procedures established to comply with this regulation. Training must be provided before the beginning of work involving a risk of heat illness. Training that is given close in time to the hot season is more effective than training given during colder seasons without follow-up refresher training. As a best practice, some employers use a daily "tailgate meeting" approach for the refresher training, starting out each work shift with a brief safety reminder about issues considered particularly relevant to the work to be performed that day.
The basic test of training is its effectiveness. Cal/OSHA evaluates compliance by examining both content and how it is presented. To be effective, training must be understood by employees and given in a language the employees understand. The test of compliance is whether training has occurred, whether the required content has been provided, and whether the training has been effective in communicating the essentials to employees.
To evaluate compliance, Cal/OSHA personnel ask supervisory and nonsupervisory employees about required training elements. The questions are designed to determine whether employees received training through methods generally recognized as effective and whether they understood its content. Inspectors will not expect all answers to be correct but will look for indicators that the employer has made a good-faith effort to communicate all the essential information.
Employers must ensure that their work procedures are consistent with the information provided in the training.
Cal/OSHA recommends that employers maintain records of the training required in this subsection, as specified in 8 CCR §3203 (on Injury and Illness Prevention Programs).
There are additional topics that supervisors must be trained on. Such training is crucial: the 2006 Cal/OSHA Heat Illness analysis showed that 63% of the supervisors of employees who died from heat stroke had not been trained in the prevention of heat illnesses.
The additional topics for supervisors are as follows:
- The procedures the supervisor must follow to implement the company's Heat Illness Prevention Plan (see Q&A no. 12),
- The procedures to follow when an employee exhibits or reports symptoms consistent with possible heat illness, including which steps to follow to provide first aid and immediate medical treatment,
- How to monitor weather reports and how to respond to hot weather advisories.
All employees and supervisors must be trained on every detail of the employer's emergency response procedures.
What written procedures should an employer develop to comply with the requirements of this standard?
The employer must develop, put in writing, and implement effective procedures for complying with the requirements of this standard. A compliant Heat Illness Prevention Plan (HIPP) includes the following subsections of 8 CCR §3395:
- Procedures for providing sufficient water, as described in subsection (c),
- Procedures for providing access to shade, as described in subsection (d),
- High-heat procedures in accordance with subsection (e),
- Emergency response procedures, outlined in subsection (f), and
- Acclimatization methods and procedures in accordance with subsection (g).
A Heat Illness Prevention Plan that is little more than a restatement of the safety orders does not satisfy the standard; instead, it must be specific and customized to the employer’s operations. Employees and supervisors must be trained in these procedures so they understand and can implement the employer's plan. The most successful employers teach and make their system work using a teamwork approach.
The HIPP must be written both in English and in the language understood by the majority of employees. It must be available to employees at the work site, as well as to representatives of Cal/OSHA upon request. The plan will be considered available at the work site if, for example, it is accessible on a cell phone or other electronic device that is available for employees to use for this purpose upon request.
The HIPP may be integrated into the employer's Injury and Illness Prevention Program required under 8 CCR §3203.
Where can I get more information on heat illness?
Numerous resources and heat illness publications can be found online at this link: https://www.dir.ca.gov/dosh/HeatIllnessInfo.html