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OSHA is Watching as Summer Heat Arrives

Posted on May 12, 2024

This article is updated and revised as of June, 2025. (Please keep in mind that due to the ongoing upheaval in Washington regarding governmental agencies and their scope of activities, one or more of the programs mentioned in this article may change or be eliminated. AIM will let you know as we learn more.)

As the swallows return to Capistrano, dangerous heat-based working conditions will reappear in the summer. In this article we try and bring together as many resources that we can identify on the state and federal level to help you prepare for the summertime’s potentially menacing effects.

Reader challenge: Can you guess the identify the artists and the references to summer related song or movie titles in this article? Answers at the end.

Some like it hot

The summer of 2024 was the fourth hottest summer (June – August) in the history of U.S. weather service record keeping, with record-breaking heat across Massachusetts averaging anywhere from 0 to 4°F above normal.

The Northeast is projected to be anywhere from 3 to 4°F above normal during the summer of 2024. While there is no predicted El Nino or La Nina effect in 2025, weather forecasters are predicting intense heat in July, August, and September this year.

Ongoing OSHA National Emphasis Program (NEP) Initiative

AIM members are always looking for information about how to help their employees cope with the warmth of the sun. Before we discuss some of the issues associated with heat though, we want to be sure you are aware of an ongoing Occupational Safety and Health Administration (OSHA) workplace heat initiative that may impact your company. The initiative began in the summer of 2022 and is scheduled to remain in effect until at least April 2026. More information on the initiative is available here.

A fact sheet on the National Emphasis Program (NEP) initiative is available here.

Here comes the sun

The NEP steers OSHA’s focus on more than 70 high-risk industries in indoor and outdoor work settings when the National Weather Service issued a heat warning or advisory for a local area. On days when the heat index is 80° F or higher, OSHA inspectors and compliance assistance specialists engage in proactive outreach and technical assistance to help stakeholders keep workers safe on the job. Stricter measures occur when it is 90° F. The importance of understanding the difference between the heat index as opposed to the temperature, is explained here. Keep in mind that OSHA inspectors look for and address heat hazards during inspections, regardless of whether the industry is targeted in the NEP.

Is your industry on the list?

The complete directive is available at this link. Once you open the link, please go to Appendix A (page 28) for a list (by 4-digit NAICS) of the industries targeted by the initiative. Unsure what the NAICS means or how to find your company on the list? Please click on this link here for a discussion of the NAICS.

 Summertime

While easily being the most celebrated and anticipated of the four seasons, summer’s heat can present significant health challenges for your workforce. Some of those challenges include:

  • Determining how hot is too hot at work.
  • Determining what an employer should do when it gets too hot for employees at work.
  • Determining what resources are available to help employers assist employees dealing with excessive heat.

Hot stuff

Although Massachusetts has a statute addressing cold in the workplace here and  minimum heat guidance for workplaces in the winter, available here, there is no law defining too hot in the summer although there is this guidance published in the summer of 2023, by the Massachusetts Department of Labor Standards available by clicking here. Many employers are left to determine the proper steps on their own, relying on listening to weather forecasts and speaking with employees regularly to determine what to do during summer’s heat waves.

 Heat wave

To help prepare for the inevitable heat waves of the upcoming summer, we’ve included some tools and resources below to help you plan for and respond to the potential dangers of excessive heat.

  • According to the National Weather Service, heat is the number one weather-related killer of people in the United States. Excessive heat has caused the death of 2,224workers from 2014 to 2023 (last number for which data is available) , an average of almost 222 workers per year. Most years, more people die per year from heat-related illness than from tornadoes, hurricanes, floods and lightning combined. See chart here.
  • Heat waves are usually predicted in advance by the National Weather Service, giving employers an opportunity to prepare. Relying on information from the National Weather Service website (weather.gov)  allows employers and employees to prepare for the impact of sky-high temperatures.

Summer in the City

If a company has a workplace that is open to the weather, such as a loading dock, an outdoor warehouse, a construction site, an outdoor deck or patio for food service or even an outdoor exercise area or an indoor non-air-conditioned site, the company needs to be alert to heat-related disorders.

Heat disorders generally occur when the body is unable to remove heat by sweating, or from excessive sweating. When heat gain exceeds what the body can deal with, or when the body cannot compensate for fluids and salt lost through perspiration, the body’s inner core temperature begins to rise, and heat-related illness may develop.

  • Heat stroke is the most serious form of heat-related illness. It happens when the body is unable to regulate its core temperature. Sweating stops and the body can no longer rid itself of excess heat. Signs include confusion, loss of consciousness, red hot dry skin, and seizures. Heat stroke is a medical emergency that may result in death. If a person exhibits these symptoms, call 911 immediately.

The following additional steps may save a worker’s life:

  • place the worker in a shady, cool area,
  • loosen clothing,
  • remove outer clothing,
  • fan air on worker,
  • place cold packs in armpits,
  • wet worker with cool water,
  • apply ice packs, cool compresses, or ice if available,
  • provide fluids (preferably water) as soon as possible, and
  • stay with the worker until help arrives.
  • Heat exhaustion is the body’s response to loss of water and salt from heavy sweating. Signs include headache, nausea, dizziness, weakness, irritability, thirst, lightheadedness and heavy sweating. In response to heat exhaustion have the worker sit or lie down in a cool, shady area, drink plenty of water or other cool beverages, apply cold compresses/ice packs, take the employee to a clinic or emergency room for medical evaluation or treatment if signs or symptoms worsen or do not improve within 60 minutes and do not have the worker return to work that day.
  • Heat cramps are caused by the loss of body salts and fluid during sweating. Low salt levels in muscles cause painful cramps. Tired muscles, those used for performing work, are usually the ones most affected by cramps. Cramps may occur during or after working hours. In response to heat cramps, have the worker rest in a shady, cool area, and drink water or other cool beverages. Wait a few hours before allowing the worker to return to strenuous work, and have the worker seek medical attention if the cramps don’t go away.
  • Heat rash, also known as prickly heat, is skin irritation caused by sweat that does not evaporate from the skin. Heat rash is the most common problem in hot work environments. If an employee develops heat rash, try to have the worker work in a cooler, less humid environment when possible and keep the affected area dry.

Consider this information a very basic guide for the company and its workers to recognize a heat-related disorder and provide immediate help to a worker in need.

Apps can help

To make it easier to determine the heat impact on your workforce, OSHA has developed an app. It can be easily downloaded to an iphone or android for quick access. Click here to download the app, which contains a lot of information and ideas on dealing with summer heat. The app’s information is also accessible in Spanish by clicking on the en Español link.

The app allows employers to calculate the heat index for their worksites, and, based on the heat index, advise workers what the risk level is.  Then, with a simple click, they can get reminders about the protective measures that should be taken at that risk level to avoid heat-related illness –reminders about drinking enough fluids, scheduling rest breaks, planning for and knowing what to do in an emergency, adjusting work operations, gradually building up the workload for new workers, training on heat illness signs and symptoms, and monitoring others for signs and symptoms of heat-related illness.

OSHA also has a fact sheet on working outdoors in hot conditions which employers may find helpful here.

Additionally, OSHA is partnering with the National Oceanic and Atmospheric Administration to incorporate worker safety precautions when heat alerts are issued across the nation. NOAA also includes worker safety information on its heat watch web page available here. For questions, call OSHA at 1-800-321-OSHA (6742) or visit www.osha.gov to learn more about its resources for dealing with the heat.

What Can an Employer Do to Reduce the Risk of Heat Wave Danger?

Encourage employees to adopt some of the following health tips to manage their possible reaction to the heat.  Education, planning and properly reacting to the conditions will assure safety during the hot events of summer.

  • Workplace schedules – Find ways to allow your employees to slow down. If possible, limit strenuous activities to the coolest time of the day, perhaps first thing in the morning or when the sun is not directly shining on your worksite.  Consider extending break periods or adding a break period to ease the heat risk during certain days. Or if possible, adjust the work schedule to avoid the hot hours of the day.
  • Clothing – Dress appropriately for summer. Lightweight light-colored clothing reflects heat and sunlight, and helps a body maintain its normal temperature.
  • Fluids – Encourage employees to drink plenty of water or other fluids even if they may not feel thirsty – the body needs water to keep cool. Consider providing bottles of water and sports drinks to ensure hydration.
  • Be cool – Allow employees to spend as much time as possible in air-conditioned places. If air conditioning is unavailable, consider using fans to keep air circulating, and encourage employees to work in the shade if possible.
  • Healthy eating – Remind employees that diet matters. The heavier the meal, the more a body works to digest it and the greater the water loss, causing a greater risk of heat related problems.
  • Teamwork – make sure your employees watch out for one another. Train them to recognize the symptoms of a co-worker suffering from heat-related illness, and to seek help from their supervisor, the company safety offices, human resources, or by dialing 911 if the symptoms are severe.

Summertime and living can be easy(ier). “Water. Rest. Shade.” can save lives.

If you have other strategies that have worked at your company and would like to share them with other AIM members, please forward the idea to Tom at tjones@aimHRsolutions.com or Sarah at spiscatelli@aimhrsolutions.com for inclusion in a future HR Edge issue.

As always, if you have questions about this or other HR relations issues, please contact the AIM Hotline at 1-800-470-6277.

Answers:

Summertime written by George and Ira Gershwin, sung by dozens

Hot stuff – Donna Summer

Heat wave – Martha and the Vandellas

Summer in the City – Lovin’ Spoonful

Some like it hot – Robert Palmer

Here comes the Sun – The Beatles – George Harrison

Summertime Blues – Eddie Cochran