Summer Heat OSHA Guidance

More than six inches of snow fell at our location in May, but heat summer heat is around the corner. If not already here in my places around the country. In preparation for the coming heat, OSHA released a National Emphasis Program on managing heat stress in workers. It must first be noted that (federal) OSHA does not have a specific standard to address heat stress, so heat stress hazards are cited under the “General Duty” clause of the OSHAct (Some “State Plan” states such as California do have heat stress specific standards with more specific requirements). 

The NEP includes a list of targeted non-construction and construction related industries in which workers are more likely to be exposed to heat hazards as Appendix A. If your industry is among those listed below, it would be good to review the OSHA resources on the control of heat stress. Among these resources is the NIOSH Heat Safety App for smart phones. 

You can access the list of past OSHA citations for heat stress at in the last decade here.

The data indicate that there have been no citations issued for heat stress by (federal) OSHA since 2014. With this most recent NEP, that is likely to change.  It should be noted that the OSHA database is not instantaneously updated, so records of additional inspections for heat stress may not appear for some months. 

 The “non-construction” list includes the following:

1121 Cattle Ranching and Farming 

1151 Support Activities for Crop Production 

2131 Support Activities for Mining 

3118 Bakeries and Tortilla Manufacturing 

3211 Sawmills and Wood Preservation 

3241 Petroleum and Coal Products Manufacturing 

3251 Basic Chemical Manufacturing 

3272 Glass and Glass Product Manufacturing 

3311 Iron and Steel Mills and Ferroalloy Manufacturing 

3314 Nonferrous Metal (except Aluminum) Production and Processing 

3315 Foundries 

3323 Architectural and Structural Metals Manufacturing 

3329 Other Fabricated Metal Product Manufacturing 

3361 Motor Vehicle Manufacturing 

3362 Motor Vehicle Body and Trailer Manufacturing 

3363 Motor Vehicle Parts Manufacturing 

3364 Aerospace Product and Parts Manufacturing 

3365 Railroad Rolling Stock Manufacturing Appendix 

366 Ship and Boat Building 

3369 Other Transportation Equipment Manufacturing 

3371 Household and Institutional Furniture and Kitchen Cabinet Manufacturing 

4239 Miscellaneous Durable Goods Merchant Wholesalers 

4241 Paper and Paper Product Merchant Wholesalers 

4242 Drugs and Druggists’ Sundries Merchant Wholesalers 

4243 Apparel, Piece Goods, and Notions Merchant Wholesalers 

4244 Grocery and Related Product Merchant Wholesalers 

4245 Farm Product Raw Material Merchant Wholesalers 

4246 Chemical and Allied Products Merchant Wholesalers 

4247 Petroleum and Petroleum Products Merchant Wholesalers 

4248 Beer, Wine, and Distilled Alcoholic Beverage Merchant Wholesalers 

4249 Miscellaneous Nondurable Goods Merchant Wholesalers 

4413 Automotive Parts, Accessories, and Tire Stores 

4442 Lawn and Garden Equipment and Supplies Stores 

4881 Support Activities for Air Transportation 

4882 Support Activities for Rail Transportation 

4883 Support Activities for Water Transportation 

4884 Support Activities for Road Transportation 

4889 Other Support Activities for Transportation 

4921 Couriers and Express Delivery Services 

4922 Local Messengers and Local Delivery 

4931 Warehousing and Storage 

5311 Lessors of Real Estate 

5617 Services to Buildings and Dwellings (includes landscaping services, tree removal and tree trimming services) 

5621 Waste Collection 

5622 Waste Treatment and Disposal 

5629 Remediation and Other Waste Management Services 

6231 Nursing Care Facilities (Skilled Nursing Facilities) 

7211 Traveler Accommodation 

8111 Automotive Repair and Maintenance 

8113 Commercial and Industrial Machinery and Equipment (except Automotive and Electronic) Repair and Maintenance 

8114 Personal and Household Goods Repair and Maintenance

1112 Vegetable and Melon Farming 

1113 Fruit and Tree Nut Farming 

2213 Water, Sewage and Other Systems (may be State or local jurisdiction) 

4411 Automobile Dealers 

4412 Other Motor Vehicle Dealers 

4821 Rail Transportation (may be Federal jurisdiction) 

4885 Freight Transportation Arrangement 

4911 Postal Service 

5611 Office Administrative Services 

5612 Facilities Support Services 

5613 Employment Services 

5614 Business Support Services 

5616 Investigation and Security Services 

5619 Other Support Services 

6117 Educational Support Services 

8112 Electronic and Precision Equipment Repair and Maintenance 

9281 National Security and International Affairs (includes Customs and Border Patrol, and Transportation Security Administration)

Construction industries noted in the NEP as likely to have heat-related hazards include the following:

2361 Residential Building Construction 

2362 Nonresidential Building Construction 

2371 Utility System Construction 

2372 Land Subdivision 

2373 Highway, Street, and Bridge Construction 

2379 Other Heavy and Civil Engineering Construction 

2381 Foundation, Structure, and Building Exterior Contractors 

2382 Building Equipment Contractors 

2383 Building Finishing Contractors 

2389 Other Specialty Trade Contractors