Hao Nguyen, Esq.
Senior Product and Regulatory Counsel, ComplyAuto
On July 23rd, a new standard for Heat Illness Prevention in Indoor Places of Employment was approved by the Secretary of State and became effective immediately. The standard applies to all indoor work areas where the temperature equals or exceeds 82 degrees Fahrenheit.
The new standards generally require dealers and other employers to provide indoor workers with water, rest breaks, and cool-down areas whenever the indoor temperature in the job site hits 82 degrees or greater for heat illness prevention.
What Is an Indoor Place of Employment?
Cal/OSHA defines indoor places of employment as spaces that are under a ceiling or overhead covering that restricts airflow and that are enclosed along the entire perimeter by walls, doors, windows, dividers, or other physical barriers that restrict airflow, whether open or closed. Generally, any workplace with a roof and enclosed sides is considered an indoor workplace. This will likely apply to many if not all dealership service departments and body shops.
While this indoor heat rule is similar in many ways to Cal/OSHA’s outdoor heat rule, one important difference is that you now must measure the temperature and heat index in the indoor place of employment and record whichever is greater whenever the temperature or heat index reaches 87 degrees Fahrenheit (or the temperature reaches 82 degrees for workers working in clothing that restricts heat removal or high-radiant-heat areas).
How Do I Measure the Temperature and Heat Index?
According to Cal/OSHA’s Frequently Asked Questions, the temperature can be measured with a thermometer that is freely exposed to the air but shielded from radiant heat sources, such as the sun, hot objects, hot surfaces, hot liquids, and fire. This air temperature must be measured in the immediate area where workers are located and recorded in degrees Fahrenheit. The rules provide a heat index chart based on the temperature and relative humidity.
What Else Does the New Rule Require?
The new rule requires covered employers at indoor worksites to maintain a Heat Illness Prevention Plan, with certain procedures such as access to cool-down areas, emergency response procedures, and provision of water.
Specifically, this rule applies to all indoor work areas in the following scenarios:
- The temperature equals or exceeds 87 degrees Fahrenheit when employees are present.
- The heat index equals or exceeds 87 degrees Fahrenheit when employees are present.
- Employees wear clothing that restricts heat removal, and the temperature equals or exceeds 82 degrees Fahrenheit.
- Employees work in a high-radiant-heat area and the temperature equals or exceeds 82 degrees Fahrenheit.
Further, just like many of Cal/OSHA’s new rules (such as its Workplace Violence Prevention Plan rule), this one requires a written plan that can be incorporated into an employer’s injury and illness prevention program (commonly referred to as an IIPP). The outdoor and indoor heat illness prevention plans can be integrated as one.
In Summary:
The new rule will require all California dealers to immediately implement the following:
- Create a Heat Illness Prevention Plan to include instances of indoor heat illness;
- Establish a “cool-down area” that is kept below 82 degrees Fahrenheit;
- Train all employees on the new indoor heat illness requirements and their rights under this new rule;
- Install equipment to measure the temperature and heat index; and
- Record daily temperature checks if certain temperature thresholds are met or exceed.
By using our online tools, dealers will be able to fulfill these new requirements, complete employee supervisor and non-supervisor training, and stay on top of recordkeeping requirements easily and efficiently.
Questions?
Review our FAQ or contact us at info@complyauto.com / (661) 214-9760 for more information on this or our many other service offerings in privacy, data protection, cybersecurity, EHS, and OSHA compliance.