The Aluminum Anodizing Council’s Committee of Advocacy and Government Affairs is preparing comments to address an Occupational Safety and Health Administration proposal on heat injury.
In August, OSHA published a proposed rule on "Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings" in the Federal Register (89 Fed. Reg. 70698). The AAC’s Committee of Advocacy and Government Affairs is preparing comments on this proposed rule for the AAC membership.
The AAC asks members to submit comments to them by November 15 so they can include them in their responses.
“Please include the rationale for your comments and, if possible, provide data and information to support your comments or recommendations,” the committee says. Comments should be sent to Mila Pandzic at the email addressmpandzic@tso.net.
The AAC says the proposed heat standard would apply to all employers and be triggered when employees are exposed to heat indexes of 80ºF for more than 15 minutes in any 60 minute period.
“For indoor work sites of relevance to anodizing facilities, employers would be required to identify areas where the heat index could be 80ºF or more and include a temperature ‘monitoring plan’ in their written Heat Injury and Illness Prevention Plan ("HIIPP"),” the AAC says. “A written HIIPP will be required for all employers with more than ten employees.”
The HIIPP must be reviewed and evaluated if a recordable heat illness occurs. The HIIPP must include the following elements: a list of work activities covered by the HIIPP; a description of actions to be taken in compliance with the heat standard; how temperatures will be monitored (e.g., relying on the National Weather Service “heat index” or performing cumbersome wet bulb globe temperature (WBGT) measurements); emergency phone numbers and first aid procedures if an employee has a heat-related illness; and a list of designated “heat safety coordinators” with authority to implement the HIIPP.
“There is an extensive list of heat injury prevention measures, including providing cool drinking water; providing air-conditioned break areas, paid rest breaks; and two-way communications with workers,” the AAC says.
Additional provisions are included-e.g., more breaks (15-minute rest breaks every two hours), an observation/buddy system or “heat safety coordinator” to monitor workers for signs of heat illness, and training—that would apply at the “high heat trigger” of a heat index of 90ºF. Employers must monitor temperatures to determine when the high heat trigger is met.
“All employees covered by the HIIPP must receive training in heat injury recognition, prevention, and the elements of the HIIPP. Supervisors receive additional training for worker monitoring and emergency response,” the AAC says. : Retraining and HIIPP revision become necessary if a recordable heat injury occurs.”
More information can be found at https://www.osha.gov/heat-exposure/rulemaking
