OSHA wants to hear from small businesses on potential heat standard

Per the US Bureau of Labor & Statistics, there were 36 work-related deaths due to environmental heat exposure in 2021. This was a drop from 56 deaths in 2020 and the lowest number since 2017. Per these statistics, I would comment that the majority of people have determined on their own how to stay hydrated and how to avoid heat related illness. Comparing the HRI numbers to the roughly 1,200 deaths annually from Occupational Automobile Deaths, and we can clearly conclude efforts should be focused where it will have the largest impact. Add in the data for injuries and deaths related to the OSHA Focus 4 of: Slips, Trips, & Falls; Struck-by; Caught Between; and Electrocution for further clarification on where efforts need to be focused. The mission of OSHA is to assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance. When thinking about the statistics and standards related to worker safety, more benefit could be gained with time in the field, paying attention to the adherence of existing standards and codes and preventing injuries rather than creating new standards. As an example, looking at the standards for slips, trips, and falls, we learn that non-roofing contractors are required to utilize fall restraint or fall protection when less than 15' from a leading edge where a worker could fall 6'. For HVAC contractors, this standard is not easy to comply with when no provisions are provided to get on roofs, over parapet walls, or with any sort of fall restraint or fall protection provided. Without much effort, OSHA or any code enforcement officer could identify an unlimited number of HVAC units located less than 15' from the roof edge and find that no provisions have been provided to access this equipment. Buildings continue to be designed and built without taking servicing roof mounted HVAC into consideration. These conditions are solvable for an expense., but whose expense is it? The building owner? The contractor? Would a new standard help? Or do we simply need to find means and get help adhering to the existing standards? Creating a new standard is easy and it looks like something is being done to improve occupational health and wellness. With limited resources, OSHA should focus on making an impact to the highest rate of accidents, injuries, and illnesses as demonstrated by the historical data.

Heat standards are definitely overdue. Where I work, water breaks are mandatory, but in states like Texas, they have been removed from worker safety, endangering lives of thousands of workers, especially on outdoor worksites in the blistering summer heat.

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