Anticipating Number of Days That Exceed OSHA Proposed Heat Triggers

Ernest N. Morial New Orleans Convention Center 

OSHA's Heat Illness and Illness Prevention in Outdoor and Indoor Settings Proposed Rule requires a heat injury and prevention plan (HIIPP) for each worksite if an initial or high heat trigger are met. Initial or high heat triggers are met when the heat index or the WBGT equivalent exceeds 80°F or 90°F, respectively. Additionally, employers should establish acclimatization schedules for new workers and workers who may be gone from the worksite for extended periods. To help anticipate the exceedances of the heat triggers, we conducted a retrospective analysis to determine how many counties in each US state exceeded either of the heat triggers in the month of July from 2020-2025. In this period, there were 17,511 instances where a county in the U.S. was above the initial heat trigger based on temperature alone. Additionally, there were 6,899 instances where a county in the U.S. was above the high heat trigger based on temperature alone. Thus, a HIPP would have to be enacted for a time period for jurisdicted worksites. To better understand impacts at the local level, a case study was performed for Randolph County, West Virginia to derive the number of heat trigger days based on heat index calculations and identify instances where reacclimatization would have been needed for workers in July 2023. This retrospective analysis provides an indication of the frequency of days that the elements of a HIIPP will need to be in place to protect workers from potential heat stress hazards.

A. Kramer, ToxStrategies, Asheville, NC, USA.; LA. Racz, ToxStrategies, Tallahassee, FL, USA; S. Vivanco, Orange County, CA, USA; J. Panko, ToxStrategies, Pittsburgh, PA, USA. 

None. 

Regulatory compliance

Risk assessment and management

Thermal stress protection and monitoring