What to Expect in an OSHA Heat-Related Inspection

On April 8, 2022, OSHA launched its National Emphasis Program (NEP) to protect workers from heat-related hazards in indoor and outdoor workplaces. Through the program, OSHA will conduct workplace inspections aimed at identifying heat-related hazards before workers suffer preventable injuries, illnesses or fatalities. This NEP applies to all industries. The NEP became effective on April 8, 2022, and will remain in effect for three years, unless canceled or extended by a superseding directive.

What to Expect

Establishments identified for programmed inspections will have inspections for heat-related hazards completed at the same time as their programmed inspections. Inspections will follow the normal OSHA inspection procedures, starting with an opening conference, a walk-through and a follow-up with a closing conference.

During inspections for heat-related hazards, employers should expect that Compliance Safety and Health Officers (CSHOs) will:

 

  • Review OSHA 300 Logs and 301 Incident Reports for any entries indicating heat-related illnesses;
  • Review any records of heat-related emergency room visits or ambulance transportation, even if hospitalizations did not occur (this may require the use of a Medical Access Order);
  • Interview workers for symptoms such as headaches, dizziness, fainting, dehydration or other conditions that may indicate heat-related illnesses, including both new employees and any employees who have recently returned to work; and
  • Determine whether employers have effective heat-related illness and injury prevention programs in place addressing heat exposure on-site.

 

Questions They May Ask

When determining whether employers’ heat-related illness and injury prevention programs are effective, CHSOs will ask the following questions:

 

• Is there a written program in place?

• How does the employer monitor ambient temperature(s) and levels of work exertion at the worksite?

• Is there unlimited cool water that is easily accessible to employees on-site?

• Does the employer require additional breaks for hydration?

• Are there scheduled rest breaks?

• Is access to a shaded area provided?

• Does the employer provide sufficient time for the acclimatization of new and returning workers?

• Is a “buddy system” in place for hot days?

• Are administrative controls used (e.g., earlier start times and employee/job rotation) to limit heat exposure?

• Does the employer provide training on signs of heat-related illnesses, ways to report these signs, steps for performing first aid, methods for contacting emergency personnel, heat-related illness prevention measures and hydration best practices?

 

CHSOs will document the conditions relevant to heat-related hazards amid inspections and identify employee activities that are relevant to such hazards.

OSHA is also providing outreach programs for heat-related illnesses. These programs may provide further compliance assistance, tools and resources.

 

Source: OSHA Heat-related Hazard NEP

 

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