Heat stress is fair game for citations under the General Duty Clause, Sec. 5(a)(1) of the Occupational Safety and Health Act. An OSHA Directive (TED 01-00-015) contains instructions for OSHA inspectors how to determine whether employers are taking adequate steps to protect workers from heat stress.
Step 1: Review the Injury Logs
The first step for inspectors to take, according to the Directive, is to review the OSHA 300 logs for indications of heat stress problems.
Step 2: Employer Interview Questions
The Directive next lists questions inspectors can pose during the employer interview part of the inspection:
Step 3: Employee Interview Questions
Questions for employee interviews include:
Step 4: Walkaround Inspection
The walkaround inspection should cover all affected areas. Heat sources, such as furnaces, ovens, and boilers, and relative heat load per employee should be noted. The Directive instructs that during the walkaround, inspectors determine the building and operation characteristics and whether engineering controls, e.g., ventilation or HVAC systems are functioning properly.
Inspectors should verify information obtained from the employer and employee interviews and perform temperature measurements and make other determinations to identify potential sources of heat stress.
Inspectors may want to discuss any operations that have the potential to cause heat stress with engineers and other knowledgeable personnel, says the Directive.
The remainder of the Directive provides technical instructions to help OSHA inspectors assess whether work conditions pose heat stress hazards.