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Employers are responsible for protecting workers from hazardous heat exposure. Industrial plants can streamline their turnaround process, increase compliance, and reduce workforce risk by engaging Dräger as their safety technology partner.
Workers in outdoor and indoor work settings without adequate climate controls are at risk of hazardous heat exposure and associated adverse health effects, including heat stroke and even death, if not treated properly. Each year in the U.S., environmental heat exposure causes about 40 reported fatalities and 33,890 work-related injuries and illnesses requiring time off, although these statistics are likely underestimated.
To protect workers and hold employers responsible for heat-related harm prevention, OSHA has published the Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings standard. Under the proposed rule, employers would be required to deploy protective controls when employees are exposed to a heat index of 80°F (initial heat trigger) for more than 15 minutes in any given 60-minute period. Additional provisions apply when the heat index reaches 90°F (high heat trigger).
Consider the various plant scenarios for indoor workers that pose risks for hazardous heat exposure as defined by OSHA, from working in a compressor room or warehouse, to performing turnaround (TAR) tasks in confined spaces. In any of these cases, the nature of the work performed (e.g., hot work) can increase temperature and humidity levels. Additionally, the PPE required for tasks (e.g., helmet, gloves, face shields) can reduce the worker's heat tolerance by decreasing the body's ability to cool down.
Implementing solutions for monitoring indoor heat and humidity fluctuations, recording worker time in hazardous heat zones, and ensuring safety protocols are followed are just a few of the compliance challenges plant HSE leaders, operations managers, work crew supervisors and TAR managers face.
In preparation of the new OSHA standard and helping meet employers’ obligations for keeping workers safe, this article presents:
- Answers to the five key questions on the proposed OSHA standard
- Six key compliance challenge areas facing employers, including public comments on OSHA’s proposed regulations
- How Dräger’s X-Viz® smart safety monitoring equipment and services can help employers overcome these challenges to support enhanced worker protection and safety and safety for confined space, and other indoor areas.
5 key questions and answers on the proposed OSHA standard
At 376 pages, the proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings standard presents detailed information on topics ranging from the mechanisms of heat-related health effects to estimated compliance costs for employers. OSHA published the proposed rule in the Federal Register in Q3 2024, and an informal public hearing is pending (scheduled for June 16, 2025). It is reasonable to assume that impacted employers are still in the process of understanding how, if passed, the standard will impact their operations and teams. For those looking for a high-level summary of the standard, the following are five key questions and answers to frame the scope of proposed requirements.
“Heat remains a high priority issue for OSHA nationwide. Regardless of whether the newly proposed rule takes effect, employers should consider reviewing and updating their heat illness prevention programs to help address heat hazards and minimize enforcement risk.”
OSHA’s proposed heat rule: Key questions for plant safety leaders and operations managers
Q1. What entities are subject to the new OSHA standard?
A. The proposed standard would apply to all employers conducting outdoor and indoor work in all general industry, construction, maritime and agriculture sectors where OSHA has jurisdiction. Although an employer may have some work activities exempt from the proposed standard, other activities may be covered. It is the employer’s responsibility to determine which work activities are covered by the standard.
Q2. What must the written heat injury and illness prevention plan (HIIPP) contain?
A. All employers with 10 or more employees must develop a written, comprehensive HIIPP for each of their work sites that includes:
- A comprehensive list of the types of work activities covered by the HIIPP
- A description of the employer’s policies and procedures necessary to comply with the requirements of the proposed standard (e.g., means for monitoring temperatures)
- A list of one or more designated workplace heat safety coordinators with authority to ensure compliance with all aspects of the HIIPP
- A heat emergency response plan, including the employer’s responsibilities if an employee experiences signs and symptoms of heat-related illness or a heat emergency and appropriate contacts in the case of an emergency
The standard would require the employer to review and evaluate the effectiveness of its HIIPP whenever a heat-related injury or illness occurs that results in death, days away from work, medical treatment beyond first aid, or loss of consciousness, but at least annually. Following each review, the employer would be required to update the HIIPP, as necessary.
Q3. How do I determine when a heat trigger has been reached in a work zone?
A. For indoor work sites, an employer would be required to identify work areas where there is a reasonable expectation that employees are or may be exposed to heat at or above the initial heat trigger (HI of 80°F). The employer would also have to implement a plan for monitoring these areas to determine when exposures above the initial and high heat triggers occur (heat index).
Given temperature fluctuations that occur even during a single work shift, an employer would have to vigilantly monitor indoor and outdoor temperatures to determine when initial (HI of 80°F) and high heat (HI of 90°F) triggers are met and implement the applicable protective measures defined in its HIIPP.
Q4. What control measures will be required at the initial and high heat triggers?
A. When the initial heat trigger (HI of 80°F) is met or exceeded, an employer will be required to provide employees with the following:
- Cool drinking water
- Break areas with cooling measures
- Indoor work area controls
- Acclimatization protocols for new and returning unacclimatized employees
- Paid rest breaks to prevent overheating, if needed
- Regular and effective two-way communication
When the high heat trigger (HI of 90°F) is met or exceeded, an employer will be required to implement additional control measures, including:
- Mandatory rest breaks of 15 minutes at least every two hours
- Methods to monitor employees for signs and symptoms of heat-related illness, such as a buddy system where coworkers observe each other, or observation by a supervisor or heat safety coordinator
- A hazard alert to remind employees of key parts of the HIIPP (e.g., staying hydrated, taking rest breaks)
- Warning signs at indoor work areas with ambient temperatures that regularly exceed 120°F
- A means for the employer to stay in contact at least every two hours with employees working alone
OSHA’s proposed heat rule: Key questions for plant safety leaders and operations managers
Dräger’s X-Viz system can improve safety and reduce costs during shutdowns and maintenance
Many of the proposed regulation nuances are related to the duration of an employee’s exposure to the defined heat triggers. For example, if an employee is exposed to heat at or above the initial heat trigger for part of their work shift, the employer would only be required to provide protection during the time of exposure.
Q5. What forms of recordkeeping and documentation are required for compliance?
A. Employers of only indoor workplaces would be required to create written or electronic records of on-site temperature measurements and retain these records for a minimum of six months. An employer could comply with the recordkeeping requirement by using monitoring devices with sufficient storage capability, or by creating and maintaining written records based on monitoring devices that do not have digital recording capabilities.
Documentation of this information would assist OSHA in determining conditions at the work site and aid the employer in verifying its compliance with the standard's provisions. Employers could also use these records to identify trends in indoor temperatures and their effect on employee health and safety and establish conditions at the time of a heat-related injury or illness to prevent such events from recurring.
3 key compliance challenges and smart solutions to help address them
Publication of the proposed standard has raised questions among employers and other stakeholders on the economic and technological feasibility of compliance – from assessing heat risks to developing a plan to enacting protective protocols. At the close of the public comment period, January 14, 2025, Regulations.gov had received 43,436 comments.
The very nature of environmental temperature and its impact on the human body is variable and difficult to predict; therefore, attempts to implement standards and controls manually can be time-consuming, resource-intensive, costly, and prone to error.
What follows are three key compliance challenge areas facing employers subject to the pending rule, public comments on these challenges, and descriptions of how Dräger’s X-Viz® smart safety monitoring equipment and services can help address them with efficiency, accuracy, and cost-effectiveness.
Challenge 1: Monitoring ever-changing temperature and humidity conditions indoors
The burden is on the employer to monitor high-risk work zones to determine when initial (HI of 80°F) and high heat (HI of 90°F) triggers are reached or exceeded, and subsequently implement the applicable protective measures defined in its HIIPP.
In its public comment on the proposed rule, the Nuclear Energy Institute (NEI) noted the challenges for employers in complying with OSHA’s proposed monitoring requirements, stating:
“The proposed monitoring provisions are administratively and economically burdensome, especially for large employers. OSHA should streamline monitoring requirements to balance safety and feasibility. Continuous monitoring throughout the day is often unnecessary and impractical.”
Solution: Dräger’s X-Viz® smart safety monitoring equipment can automate this process through its comprehensive array of heat detection capabilities, including continuous temperature and humidity monitoring, along with the conversion to heat index values to support compliance with site requirements. It features predefined temperature thresholds that automatically trigger alerts for high heat and humidity conditions, helping ensure timely notifications for personnel. Dräger’s X-Viz® system can also communicate “hazard alerts” issued by the employer to notify employees of the importance of staying hydrated and taking the mandatory rest breaks (as well as additional breaks as needed) and the procedures to follow in an emergency.
Challenge 2: Down to the minute tracking of workers entering and exiting zones to implement controls at OSHA defined intervals
Under the rule, employers would be required to deploy protective controls when workers are exposed to a heat index of 80°F (initial heat trigger) for more than 15 minutes in any given 60-minute period. Added control measures are required when workers are exposed to a heat index of 90°F (high heat trigger), including mandatory rest breaks of 15 minutes at least every two hours.
Associated tasks include:
- Monitoring when each worker enters and exits a work zone
- Determining the heat hazards of that zone during the time the worker is in there
- Establishing when HI temperature triggers are reached
- Ensuring the appropriate protective controls are employed per the employer’s HIIPP
This public comment highlights the anticipated burden on plant managers:
“My concern is that safety managers and line level managers, will become burdened with the administration of this standard and will spend less time managing unsafe conditions and behaviors.”
Solution: Dräger X-Viz technology can help streamline alignment with the employer’s HIIPP through task and documentation automation. The solution time stamps when individual workers enter and exit designated work zones and the programming of pre-established temperature alarm thresholds alert employees when hydration or breaks are required. Employee entry into designated areas/confined spaces can be limited to those employees who have met the employer’s requirements, whether it is compliance with designated control measures or wearing the proper PPE for conditions before entry. This information can be tied to permits so that employees failing to comply can be held out from work until the requirements have been met.
Challenge 3: Real-time communication for rapidly identifying and intervening when a worker shows symptoms of heat stress
Under the proposed standard, employers would be required to provide regular and effective two-way communication with workers when the initial heat index trigger (80°F) is reached or exceeded in a work zone. When the high heat index trigger (90°F) is reached or exceeded, an employer would be required to implement methods to monitor employees for signs and symptoms of heat-related illness and stay in contact at least every two hours with employees working alone.
Concerns have been voiced in the public comments on placing the burden of monitoring for symptoms of heat stress on individuals without adequate knowledge and training to determine when an employee is in danger. Students at the University of Virginia’s Batten School for Leadership and Public Policy offered this comment:
“We are especially concerned with the idea of ‘monitoring symptoms.’ This phrase could have much subjectivity, and it places coworkers on the front lines to monitor signs of heat stress. These employees may not have the medical knowledge, time, or ability to ensure one another’s safety, even with training, and this rule opens them up to legal liability. They cannot take on the responsibility of a trained healthcare professional, absent protection from a corresponding Good Samaritan provision.”
Solution: The Dräger X-Viz helps to facilitate centralized, comprehensive, continuous oversight of employees, including those working in confined spaces, through 100% live video visibility, two-way radio communication, and robust emergency features. Dräger’s trained operators work closely with certified safety professionals and industrial hygienist who assist with the implementation and execution stages of the X-Viz Monitoring project.
If heat stress symptoms are detected through surveillance, attempts are made to contact the employee, followed by the activation of emergency alarms. Site emergency response personnel are promptly notified to ensure a rapid response.
Conclusion
By understanding important questions and compliance challenges associated with the proposed rule, an employer can take proactive steps to mitigate heat-related risks and develop a comprehensive HIIPP. The integration of smart safety monitoring solutions, such as Dräger’s X-Viz® technology, can streamline compliance efforts by automating temperature tracking, real-time worker monitoring and recordkeeping, ultimately helping to enhance workplace safety and reducing the risk of heat-related injuries and illnesses.
For references and additional information, including a link to this full white paper, please visit draeger.com.
