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IT’S ALL OKAY UNTIL IT’S NOT:
WHY HEAT SAFETY CAN’T WAIT

Where’s all my Gen X’ers at? Let’s take a trip back in time and who remembers popular song “The Heat Is On, by Glenn Fry. This hit peaking at number 2 on the US Billboard Hot 100 in March of 1985. I am sure many of you just took a mental flashback, that is okay, so did I.

As the construction industry is quickly approaching the long days of summer, let’s pause and grab a big, tall ice cold glass of Southern Sweet tea and think about worker safety during these hot and humid days. July 2, 2024, OSHA formally introduced its first-ever proposed national heat standard called ‘Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings’.

When this information went public, as one would expect it generated quite a whirlwind of concerns and apprehensions within our industry.

When this information went public, as one would expect it generated quite a whirlwind of concerns and apprehensions within our industry.

As the construction industry is quickly approaching the long days of summer, let’s pause and grab a big, tall ice cold glass of Southern Sweet tea and think about worker safety during these hot and humid days. July 2, 2024, OSHA formally introduced its first-ever proposed national heat standard called ‘Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings’.

When this information went public, as one would expect it generated quite a whirlwind of concerns and apprehensions within our industry.

We are now in year number two of this standard and if you were not aware, OSHA has recently extended its efforts with an announcement on April 10, 2026 that the National Emphasis Program will remain in effect.

What does this mean for you if you are an employer, and conversely, what does it mean for you as an employee?

We must start at the beginning and ask the question; do you have a written company Heat Standard Plan for your company?

If so, GREAT!

A construction supervisor in a neon safety vest speaks to a group of workers around a pickup bed with water cooler on a job site.
Two construction workers in neon safety vests and hard hats near a large excavator, filling a cooler with bottled water and ice.

If you answered no, then this is where you must begin, because at any given time, OSHA may ask to see your written company Heat Awareness and Training Program.

Two construction workers wearing hard hats and high‑visibility vests rest on a dusty job site; one wipes sweat from his face with a cloth while the other drinks water.

How did we get here? Good question!

The simple answer is that this is a data driven standard, recognizing the physical and mental stress heat plays on workers who are building our homes, businesses, highways and our infrastructure in hot temperatures.

So, what does OSHA consider hot?

80°F is the Initial Heat Trigger.

This applies when employees are exposed to an 80°F heat index for over 15 minutes in any hour.

When the temperature climbs to 90°F, OSHA calls this High Heat Climate which requires a minimum of a 15-minute paid rest break every two hours.

It would be much too lengthy to discuss the pros and cons on both sides of the isle of this topic; therefore, I would like to focus my attention on this article the “Total Worker’s Safety”.

At the end of the day, it does come down to keeping our valued employee safe, which goes beyond any regulation or standard. We have a moral obligation beyond the General Duty Act to keep our workforce safe and healthy.

Heat stress and Heat Illnesses are not the same for all workers. People respond differently when working in hot environments. This is why training is not only important, but also imperative.

ELEMENT #1: TRAINING

The first element to this proposed standard is training. The Employer shall train their employees on the signs and symptoms of heat-related hazards and illness. This encompasses the recognition and the care to be given to illnesses or emergencies such as dehydration, heat exhaustion and heat stroke.

ELEMENT #2: ACCLIMATIZATION

This takes us to the second element of the proposed standard which is called the acclimation period.

This is probably the most ambiguous element of the five I will discuss.

OSHA uses the 20% Rule for new workers. A new worker whose body is not acclimated to hot temperatures should only work no more than 20% of the normal workday.

Subsequently workdays thereafter, another 20% can be added to the worker’s daily shift and so forth.

Greg First

ELEMENT #3: HYDRATION

The third element we need to comply with is employers are required to provide and/or make available unlimited supply of cold potable water.

No matter if employees bring their own form of hydration, the employer must always have water available.

With that said, the employee cannot be denied under any circumstances the opportunity to have water.

I always like to place a large emphasis on the shared responsibility between the employer and the employee when it comes to the topic of heat stress. The employer can do everything correct but if the employee does not do his part and arrive to work, as what I call, “Fit for Duty”, so who does take the blame if a worker falls ill to the heat. I believe this needs to be clearly communicated to all workers, they have a responsibility as well.

ELEMENT #4: SHADE

The fourth element of this proposed standard is called a place of shade. This means the employer must have available to them during working hours; a place to escape the direct sunlight. This can be outlined and identified within your company’s written plan or a job specific safety plan.

ELEMENT #5: COOLING STATIONS

The fifth and final element of the proposed standard is a cooling station.

I can see the eyes rolling already. Don’t overthink it. There are several areas where an employee can find a cooling station on all jobsites.

But let me circle back to my earlier mentioning of the importance of have a written company heat awareness training program. All that would be required is identifying areas such as a piece of equipment on the job that is equipped with A/C.

A company owned vehicle where an employee can retreat and find a cool area away from the heat. Lastly, allowing the employee to go to his personal vehicle is also perfectly acceptable.

IN CONCLUSION

I start many of my safety training classes with the saying,

“It’s All Okay, Until It’s Not.”

This is such a prolific statement.

None of this will come into question until an employee becomes ill or worse yet, the illness turns fatal.

This conversation applies to all, but we need to pay close attention to our aging workforce. They are the ones who are more receptive to these kinds of illnesses as heat related illnesses can be best described as the chameleon.

Heat stress will sneak up on you before you realize it and then it could be too late. Because the rule is still in the rulemaking phase, OSHA will rely on the National Empasis Program to conduct inspections and cite employers under the General Duty Clause.

Quick Summary of what OSHA has proposed under this Ruling:

Have a written Heat Related Illness and Prevention Program that outlines the following elements:

1). Training for all employees on the signs and symptoms of heat-related emergencies and illnesses and the
      temporary care to be given.

2). The Acclimation Period.

3). The Unlimited Supply of Cold Water.

4). A place of shade.

5). A cooling station.

“It’s All Okay, Until It’s Not”

This article was written by:

Greg First

Greg First
Safety Director
Conie Construction Company
1340 Windsor Ave.
Columbus, Ohio 43211
Think Safety First, LLC

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