Rising temperatures, rising concerns

In the fall of 2021, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) published an Advance Notice of Proposed Rulemaking (ANPRM) for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. With that publication, OSHA began the rulemaking process to consider a heat-specific workplace standard.

The recycling industry is well-aware of the threat excessive heat poses, and many companies in the sector have done a good job of ensuring their employees are protected, says Tony Smith, vice president of safety at the Institute of Scrap Recycling Industries (ISRI), Washington. “Our members, in general, get people acclimated before putting them out in the workplace,” he says.

Smith adds that ISRI continues to watch what OSHA is doing around establishing a heat-specific workplace standard and coaching its members to follow best practices. While he says there is no specific regulation as of early 2022, “there will be.”

Why is a standard needed?

The agency says a standard specific to heat-related injury and illness prevention “would more clearly set forth employer obligations and the measures necessary to more effectively protect employees from hazardous heat. The ultimate goal is to prevent and reduce the number of occupational injuries, illnesses and fatalities caused by exposure to hazardous heat.”

The public comment period for the ANPRM closed Jan. 26. For three months, OSHA says it gathered information, perspectives and technical expertise on issues that might be considered in developing a heat standard. These issues include the scope of a standard, heat stress thresholds for workers across various industries, heat acclimatization planning and heat exposure monitoring, as well as the nature, types and effectiveness of controls that a standard could require.

When the ANPRM was announced in the fall of 2021, U.S. Department of Labor Secretary Marty Walsh said, “As we continue to see temperatures rise and records broken, our changing climate affects millions of America’s workers who are exposed to tough and potentially dangerous heat. We know a disproportionate number of people of color perform this critical work and they, like all workers, deserve protections. We must act now to address the impacts of extreme heat and to prevent workers from suffering the agony of heat illness or death.”

“While heat illness is largely preventable and commonly underreported, thousands of workers are sickened each year by workplace heat exposure, and in some cases, heat exposure can be fatal,” Jim Frederick, deputy assistant secretary of labor for OSHA, said when the ANPRM was published. “The [ANPRM] for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings is an important part of our multipronged initiative to protect indoor and outdoor workers from hazardous heat.”

The U.S. Department of Labor’s Bureau of Labor Statistics (BLS) reports that from 2011 to 2019, environmental heat cases resulted in an average of 38 fatalities per year and an average of 2,700 cases with days away from work. From 2015 to 2020, OSHA conducted approximately 200 heat-related inspections annually, with about 15 heat-related fatality inspections annually. The agency says many of these inspections resulted in OSHA citations under the general duty clause, Section 5(a)(1) of the Occupational Safety and Health Act, for exposing workers to heat-related hazards. However, because the cause of death often is listed as a heart attack, when the actual cause was exposure to a heat-related hazard, heat-related deaths are underreported, according to OSHA. The agency says heat is the leading cause of death among weather-related workplace hazards.

To help address this threat, OSHA implemented a nationwide enforcement initiative on heat-related hazards in September of last year. The agency also is developing a National Emphasis Program on heat inspections and is forming a National Advisory Committee on Occupational Safety and Health Heat Injury and Illness Prevention Work Group to provide a better understanding of challenges and identify and share best practices to protect workers.

The enforcement initiative “expands on OSHA’s ongoing heat-related illness prevention campaign by setting forth the enforcement component and reiterating its compliance assistance and outreach efforts.” It prioritizes heat-related interventions and inspections on days when the heat index exceeds 80 F, encouraging employers to implement proactive interventions, such as water, rest and shade, as well as acclimatization of new workers or those returning to the workforce after an absence of a week or more.

Addressing the threat

ISRI’s Smith says the association has given its members the necessary resources to understand the signs and symptoms of heat or cold stress in the workplace. This includes information on recognizing and preventing heat rash, heat cramps, heat exhaustion and heatstroke.

Jerry Sjogren, senior director of safety at ISRI who last worked for E.L. Harvey & Sons, Westborough, Massachusetts, says his previous company “always worried about [heat exposure] with our workers.” E.L. Harvey & Sons posted urine color charts in all the company’s bathrooms, he says. Sjogren also would stress to employees that feeling thirsty likely meant they already were dehydrated.

Ryan Nolte, director of safety outreach at ISRI, says when working in the heat, in addition to encouraging workers to drink cool water, take breaks in cool or shady areas and rest as needed, managers might want to consider altering their hours of operation to begin earlier in the day.

Smith mentions the heatwave that affected the Pacific Northwest last summer. He says ISRI member companies altered their work schedules or ceased operations at times because their employees were not acclimatized to that degree of heat.

“Almost nobody wants to be uncomfortable,” Nolte says. “I don’t know of anyone who is thirsty that won’t get a drink.” However, he adds, supervisors could find it more challenging to get employees to drink water rather than pop or coffee.

While sports drinks might seem like a viable alternative to water, Sjogren says they should be consumed in moderation because of their high sugar and electrolyte content.

The U.S. Department of Health and Human Services (HHS) suggests employees should be well-hydrated before they begin their shifts. When working in the heat, the agency recommends drinking 8 ounces of water every 15 to 20 minutes, or 24 to 32 ounces per hour, to be consumed over shorter intervals rather than a large amount infrequently. HHS cautions against drinking more than 48 ounces per hour, which can cause a medical emergency because the concentration of salt in the blood becomes too diluted.

HHS also cautions against drinking alcohol within 24 hours of working in the heat, noting that doing so can increase the risk of heat illness.

Engineering controls also can help address heat in the workplace, though they are not always possible in outdoor operations. Engineering controls ISRI suggests include air-conditioned mobile equipment cabs and air conditioning in break rooms or the use of fans.

When it comes to work practices, in addition to encouraging water consumption, ISRI advises employers that rotating job functions among workers, distributing the workload evenly over the day and incorporating work/rest cycles and reducing physical demands during hot weather, if possible, can help minimize overexertion and heat exposure in the workplace. The association also suggests that employers have an emergency plan in place that specifies what to do if a worker has signs of heat-related illness.

“Comfort is king,” Smith says, advising employers to ensure their employees have access to water, popsicles and shade when working in excessive heat “so they are productive and happy and returning to work.”

Sjogren adds that with the current labor issues the recycling industry is facing, ensuring employees are comfortable at work is even more important because it could affect employee retention. “If you don’t make them comfortable, they will find something else.”

The author is editor of Recycling Today and can be reached at dtoto@gie.net.