CELLY SERVICES INC.
ENVIRONMENTAL, HEALTH & SAFETY SERVICES

THE HEAT IS ON

May 15, 2006

Background: As summer approaches, and the mercury rises, the probability of an employee illness due to heat stroke/stress rises as well. We write this memo to make you aware of these issues so you can minimize or rather eliminate loss time and other losses due to heat illnesses.

A New Law: In the state of California, CAL/OSHA has proposed regulations that would require employers to take affirmative steps for outdoor places of employment (Title 8, Chapter 4, Section 3995). The temporary standard is in effect till August 2006 and may well become permanent thereafter. A workplace with a roof and enclosed sides is considered an indoor place. We note, that for an automobile dealership, outdoor places of employment would be construed as follows:

  • Sales Staff: When a sales employee walks through the lot with a potential customer, the walk-through the lot would be considered outdoors and hence
    the standard would apply.
  • Parts Truck Drivers: As the parts truck driver works outside the dealership driving around town, the place of work would be considered outdoors as well.

However, in both these instances, an air conditioned (or cooler) showroom where the sales person returns after his/her brief activity outside would alleviate the symptoms related to heat stress. Also, an air-conditioned driver cabin for the parts driver would minimize the incidents of heat related illnesses. Nevertheless, inside shops with marginal ventilation, metal roofs and/or hot engines idling may increase the ambient temperatures and heat stress can become an issue. In summary, even though the standard does not apply to a facility for a technicality such as outdoor or indoor, heat stress is of concern under certain circumstances.

Other States: In other states where a specific heat illness standard may not exist, the employer’s responsibility for addressing heat related illness’ does not cease. General duty clause of OSHA requires that an employer provide a safe workplace and abate hazardous conditions. In summary, training employees on Heat Stress makes sense.

Provide Water: One salient requirement of the California Code is that the employer provide one quart of water per hour per employee during the work shift. For automobile dealerships, such would be a non issue but next time when you see a truck on the freeway with a water cooler bolted on the side you can smile and know exactly where all this comes from!!!!

Monthly Mailer: In the monthly mailer to your dealership, a training memo on heat stress is enclosed. Please review it with all the employees and seek acknowledgement. Training requirements under the California Code are listed below.

HEAT STRESS TRAINING REQUIREMENTS IN CALIFORNIA

Training requirement under the temporary standards is also listed in the memo and supervisors should pay special attention. For better understanding on this issue, a Heat Advisory from the state is attached as a PDF file. Please print it and use it as appropriate.

Employee Training is required for employees as follows:

  1. The environmental and personal risk factors for heat illness.
  2. The employer’s procedures for complying with the requirements of this standard.
  3. The importance of frequent consumption of small quantities of water, up to 4 cups per hour under extreme conditions of work and heat.
  4. The importance of acclimatization.
  5. The different types of heat illness and the common signs and symptoms of heat illness.
  6. The importance of immediately reporting to the employer, directly or through the employee’s supervisor, symptoms or signs of heat illness in themselves, or in co-workers.
  7. The employer’s procedures for responding to symptoms of possible heat illness, including how emergency medical services will be provided should they become necessary
  8. Procedures for contacting emergency medical services, and if necessary, for transporting employees to a point where they can be reached by an emergency medical service provider.
  9. How to provide clear and precise directions to the work site.

Supervisor Training is as follows:

  1. The information required to be provided by section above.
  2. The procedures the supervisor is to follow to implement the applicable provisions in this section.
  3. The procedures the supervisor is to follow when an employee exhibits symptoms consistent with possible heat illness, including emergency response procedures.

The article was authored by Sam Celly of Celly Services, Inc. Sam has been helping automobile dealers comply with EPA & OSHA regulations in California, Nevada, Arizona, Hawaii & Idaho since 1987. Sam received his BS & MS in Chemical Engineering followed by a JD from Southwestern University. Sam is a Certified Safety Professional & a Registered Environmental Assessor (CA). Your comments/questions are always welcome. Please send them to sam@cellyservices.com.

 
444 W. Ocean Blvd., Suite 1402, Long Beach, CA 90802 ~ Ph (562) 704-4000 Fax (562) 704-5000
www.cellyservices.com