Indoor & Outdoor Heat Stress Standards: What Are Your State’s Compliance Requirements?

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Heat illness can be defined as a serious medical condition that occurs when the body can no longer manage heat. It can be caused by environmental conditions or through over-exertion and can develop quickly as well as become life-threatening. Heat illness can range from minor symptoms to more severe ones. Three forms of heat illness include the following:

  1. Heat cramps – This is the mildest form of heat illness. This condition may be characterized by painful muscle cramps and spasms, usually in the legs and abdomen. Other symptoms may include heavy sweating and flushed, moist skin.

  2. Heat exhaustion – This is a more severe form of heat illness that results from the body losing too much water and salt. Symptoms may include heavy sweating, muscle weakness, cool, pale, clammy skin, fast or weak pulse, muscle cramps, dizziness, nausea or vomiting, headache, and fainting.

  3. Heat stroke – This is the most severe form of heat illness and can be life-threatening.

It is important to note that heat illness can also be considered an occupational illness if it is experienced by an employee while performing their job. Therefore, employers are legally required to protect their employees accordingly. The most vulnerable employees to heat illness are those who work outside, work around hot equipment or machinery, and perform manual labor. Some examples of industries that may be at particular risk of employees succumbing to heat illness include but are not limited to manufacturing, foundries, construction, and lawn care.

OSHA’s Proposed National Heat Stress Standard

On July 2, 2024, the Occupational Safety and Health Administration (OSHA) announced its long-awaited proposed rule Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. OSHA’s proposed heat stress rule would require employers to develop Heat Injury and Illness Prevention Plans for indoor and outdoor heat hazards, regularly monitor work site temperatures, and implement control measures at two proposed national heat index thresholds that would factor in temperature and humidity. Once published in the Federal Register, it will be open for public comment.

Until this Rule is passed, heat illness prevention will fall under the OSHA General Duty Clause, which is a “catch-all” requiring employers to provide a work environment that is free from hazards that can cause serious injury or death. Therefore, protecting employees from the various forms of heat illness can still be argued as a current requirement of Federal OSHA.

Heat Stress Standards by State

As of July 2024, five states have permanent occupational heat stress standards for the workplace: California, Colorado, Minnesota, Oregon, and Washington. These state mandates require proactive measures to be taken in some shape or form to protect workers from heat injury and illness. Below is an overview of the existing standards broken down by state.

California

Indoor Heat Illness Prevention Standard

On June 20, 2024, the Cal/OSHA approved the Heat Illness Prevention in Indoor Places of Employment standard. It applies to most workplaces where the indoor temperature reaches 82 degrees Fahrenheit (F) and requires safety measures for indoor workplaces to prevent worker overexposure to the risk of heat illness.

The new indoor heat illness prevention standard in California states:

  • Employers will be required to provide access to potable water that is fresh, suitably cool, and free of charge, as well as strategically located near work and cool-down areas less than 82°F.  

  • Employers will have to measure the temperature and heat index and record whichever is greater whenever the temperature or heat index reaches 87°F (or temperature reaches 82°F for workers working in clothing that restricts heat removal or high-radiant-heat areas). Control measures, beginning with engineering controls, will then have to be implemented to keep workers safe.

  • When indoor workplaces are affected by outdoor temperatures, supervisors will have to be trained on how to check weather reports and how to respond to hot weather advisories as well.

  • Lastly and arguably most importantly, employers will have to establish, implement, and maintain an effective written Indoor Heat Illness Prevention Plan. This Plan will include procedures for providing drinking water, cool-down areas, preventative rest periods, close observation during acclimatization, assessment, and measurement of heat, training, prompt emergency response, and feasible control measures.

Outdoor Heat Illness Prevention Standard

Cal/OSHA's Heat Illness Prevention for Outdoor Places of Employment regulation applies to all outdoor places of employment including the agriculture, construction, and landscaping industries.

The existing outdoor heat illness requirements in California include:

  • Providing access to potable water that is fresh, suitably cool, and free of charge, as well as strategically located near work areas. 

  • Have and implement procedures to deal with heat when the temperature equals or exceeds 95°Fahrenheit. These procedures include, but may not be limited to, observing and communicating effectively with workers and reminding workers to drink water and take cool-down rest breaks.

  • Monitoring outdoor temperature and ensuring that once the temperature exceeds 80°Fahrenheit, shade structures are opened and made available to the workers.

  • When it is at least 95°F, implement high-heat procedures.

  • Training supervisors on how to check weather reports and how to respond to weather advisories.

  • Establishing, implementing, and maintaining an effective written Outdoor Heat Illness Prevention Plan that includes procedures for providing drinking water, shade, preventative rest periods, close observation during acclimatization, high-heat procedures, training, and prompt emergency response.

  • Shade must be present when temperatures are greater than 80°F. When temperatures are less than 80°Fahrenheit, shade must be available upon request.

Common Indoor & Outdoor Heat Illness Prevention Requirements

Cal/OSHA provides a clear comparison table of California’s Indoor and Outdoor Heat Illness Prevention Standards, including many shared requirements.

Requirements for both indoor and outdoor workplaces in California include:

  • Having shade and cool-down areas blocked from direct sunlight and large enough to accommodate the workers on rest breaks so they can sit comfortably without touching each other.

  • Encouraging workers to take preventative cool-down rest periods.

  • Granting permission to workers who ask for a cool-down rest period to take one.

  • Monitoring workers who are taking rest periods for symptoms of heat-related illness.

  • Providing first aid or emergency response to any workers showing signs or symptoms of heat illness, including contacting emergency medical services.

  • Observing new workers and newly assigned workers working in hot areas during a 14-day acclimatization period, as well as all workers working during a heat wave.

  • Providing heat illness awareness training to both workers and supervisors.

Colorado

Heat Illness and Injury Protection Standard

Colorado's Heat Illness and Injury Protection Standard requires employers to provide employees with potable water to prevent heat illness. Employers must provide at least 32 ounces of water per hour that is kept at or below 60°F to employees. The water must be from a sanitary source, such as a tap, fountain, or individual cup, and be located as close to the worksite as possible. Also, ample time must be allowed for employees to drink water and use restrooms throughout their shifts.

Minnesota

Heat Stress Standard

The Minnesota Heat Stress Standard emphasizes ventilation, heat stress, and air temperature when considering heat illness. The standard states that:

  • The air shall be provided and distributed in all workplaces as required unless prohibited by process requirements.

  • The outside air shall be provided to all workplaces at the rate of 15 cubic feet per minute per person.

  • The air circulated in any workroom shall be supplied through air inlets arranged, located, and equipped so that the workers shall not be subjected to air velocities exceeding 200 feet per minute except under special circumstances.

  • Employees shall not be exposed to indoor environmental heat conditions exceeding the following temperatures listed in Table 1. The values in Table 1 apply to fully clothed, acclimatized workers.

Table 1

Work Activity

Temperature

Heavy Work

 77° Fahrenheit

Moderate Work

 80° Fahrenheit

Light Work

 86° Fahrenheit
 

  • All workers exposed to heat shall be provided with the necessary awareness training.

  • Workplace temperatures shall be maintained as follows:

    • The minimum air temperature of 60° Fahrenheit shall be maintained in all rooms where work of a strenuous nature is performed unless prohibited by process requirements.

    • The minimum air temperature of 65° Fahrenheit shall be maintained in all other workplaces unless prohibited by process requirements.

  • Recirculated air from any exhaust system handling materials listed in the Code of Federal Regulations, title 29, subpart Z, shall not be recirculated without written permission from the Department of Labor and Industry.

Oregon

Heat Illness Prevention Requirements

Oregon's heat illness prevention requirements apply to workplaces when the heat index is 80° F or higher. Such requirements include the following:

  • Employers must provide access to a shared shaded area that can accommodate workers while on break and that doesn't expose them to unsafe conditions. If shade is not practical, employers must provide other cooling measures that offer the same level of protection.

  • Employees must be permitted access to cold or cool drinking water (35–77°F) at no cost and be given opportunities to drink up to 32 ounces per hour.

  • Employers must develop and implement a written acclimatization and heat illness prevention plan, as well as an emergency medical plan.

  • Employers must provide awareness training on heat illness prevention.

Washington

Outdoor Heat Illness Requirements

Washington State's heat illness requirements are specific to outdoor workers only, and state:

  • Workers must be allowed to take paid, preventative cool-down breaks in the shade or other effective ways to reduce body temperature.

    • If 90° Fahrenheit or hotter, a 10-minute break is mandated every 2 hours.

    • At 100°Fahrenheit or hotter, a 15-minute break must occur every hour.

    • Longer and more frequent breaks are required when temperatures continue to increase.

  • Employers must also closely observe workers for signs and symptoms of heat-related illness for a duration of 14 days.

  • Employers must train employees and supervisors about heat exposure, including acclimatization, cool-down rest periods, and gradual increase of work duration in the heat.

  • Also, prior to any outdoor work with elevated temperatures, training must be provided in a language the employee or supervisor understands and at least annually thereafter.

  • Lastly, employers must have emergency procedures to respond appropriately to any employee with symptoms of heat-related illness.

KERAMIDA can assist corporations large and small in developing the appropriate preventative measures and plans for reducing the risk of heat illness. Whether it be at the Federal or State level, KERAMIDA can apply the necessary controls at your facility to maintain regulatory compliance and, more importantly, keep your employees safe. Our Certified Safety Professionals have upwards of 30 years of experience in managing every area of safety in all spheres of business. If you have questions or concerns about your state’s current heat stress standard or what is yet to come, please contact us so we can get you to where you need to be. Fill out our quick response form or call (800) 508-8034 to speak with one of our experienced professionals today. 

Contact

Dan Engling, MS, CIH, CSP
Vice President, Safety and Industrial Health Services
KERAMIDA Inc.

Contact Dan at dengling@keramida.com.

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