On July 23, 2024, OSHA (Occupational Safety and Health Standards) approved the Heat Illness Prevention in Indoor Places of Employment (Code of Regulations, Title 8, section 3396), adding another policy for employers to implement, including churches, to remain compliant. As with most workplace policies, the reason “why” for this policy is rooted in improving a situation for employees. As stated in a previous post, “Churches and the California Indoor Heat Illness Prevention Plan” the regulation addresses workplace deaths related to indoor heat exposure. While most would agree that decreasing workplace injuries and deaths is a wonderful idea, the prospect of implementing another policy is overwhelming.
Most small businesses, non-profits, and churches do not have the resources to retain legal counsel or a human resources department to stay current on the never-ending flow of new policies. The lack of resources and the constant emergence of new regulations can quickly put organizations out of compliance without ever recognizing it. But even when a new requirement is known, figuring out what to do can take time and expertise that many churches do not have. Ignoring it is not an option, as James 4:17 clearly states, “So whoever knows the right thing to do and fails to do it, for him it is sin.” (ESV)
What the Heat Illness Prevention in Indoor Places Requires
The State of California Department of Industrial Relations created a thorough webpage explaining the Cal/OSHA Heat Illness Prevention Guidance. The webpage provides a comprehensive overview and standards. Similar to other policies, like AB 503, it comes down to three key elements:
Develop an Indoor Heat Illness Prevention Plan
Most small to mid-sized churches don’t have the resources to produce a custom plan or write a custom policy. If your church falls into that category, take advantage of the free resources the State of California’s Department of Labor Relations provides, which includes a model plan. The plan should include:
- Applicability and Implementation – Define which employees the plan applies to (all indoor work areas where the temperature exceeds 82°F) and which work areas are excluded (for example, remote and teleworkers).
- Definitions – There are a lot of terms used in the plan that may not be familiar, like acclimatization, Heat index, High radiant heat source, etc. The plan must provide clear definitions of these terms to ensure everything is clear.
- Provision of Water – Indoor heat exposure triggers sweating in the body, which depletes the body of water and salt, resulting in dehydration. Employers must provide, free of charge, clean, fresh, cool, drinkable water in work areas.
- Procedures for Access to Cool-Down Areas – When work area temperatures exceed 82°F, the employer must create and provide the location of designated cool-down areas where temperatures remain below 82°F. Supervisors should encourage workers at risk of heat-related illness to use these cool-down areas as a preventative tool.
- Emergency Response – The employer must have a plan to provide emergency services to a stricken worker. Consider logistics, such as who to contact, the location of cool-down rooms, access to water, and overcoming language barriers.
- Acclimatization Procedures – Acclimatizing is the body gradually adapting to the environment through exposure. Supervisors need to be keenly aware of factors such as new hires or heat waves creating conditions causing indoor heat exposure illness.
- Training Procedures – Develop a comprehensive training plan for all employees to learn the Indoor Heat Illness Prevention Plan.
Provide Indoor Heat Illness Prevention Training
With the heavy lifting of the Heat Illness Prevention Plan complete, provide the plan and training to all workers. A plan is only as good as the people working from it; supervisors and workers alike need to know their expectations. Include the California OSHA requirement, review the Heat Illness Prevention Plan, explain risk factors, cool-down areas’ location, and drinking water access.
Complete an Indoor Heat Illness Prevention Assessment Form
Employers must evaluate and provide detailed information regarding potential indoor heat and heat illness hazards. Include assessments of:
- Indoor Heat Risk Factors (Outdoor temperature, building structure or layout, machinery that radiates heat, tasks that require exertion, clothing that inhibits heat removal, areas susceptible to heat waves or high temperatures, humidity, etc.)
- Building/HVAC/Ventilation/Fans/Exhaust
- Water – Readily Available and Close
- Cool-Down Areas and Policy
- Emergency Response Plan
The administrative burden of implementing all these new regulations and requirements can be overwhelming – especially for smaller organizations like most churches. Regardless of your position on more or less regulations on churches, remember that the intent is to create a safe environment for people to work. From that perspective, why would any organization fight that?
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