On Jan. 14, TRSA submitted comments to the U.S. Occupational Safety and Health Administration (OSHA) on the proposed standard to control exposure to heat in both indoor and outdoor settings. While acknowledging that exposure to heat represents a hazard, the comments raised an array of concerns and urged OSHA to withdraw the proposal so that it could be substantially revised and reproposed as a performance-oriented standard.
In its comments, TRSA stated that, “TRSA believes the proposed standard would result in OSHA micromanaging workplaces, imposing unreasonable burdens and creating confusion as to what employers would be required to do. Because of these concerns, the TRSA urges OSHA to withdraw this proposed standard so that one can be promulgated focusing on heat injury and illness prevention using a performance orientation that will allow employers to tailor their protections to their geography, environment, workplaces and workers. In doing so, employers will be expected to incorporate widely accepted elements for an effective heat illness and prevention program – training, acclimatization/enhanced supervision for new or returning employees, and the provision of water, rest and shade – but the ways in which they do so should be driven by the goal of protecting workers rather than meeting OSHA’s specifications for each element.”
Among the problems the comments highlighted was that the proposed standard did not consider differences in locations – all parts of the country were treated the same with respect to the heat triggers of a heat index of 80 degrees and then a heat index of 90 degrees for more protective measures.
“Unfortunately, OSHA’s Proposed Heat Standard applies a one-size-fits-all approach, fails to account for regional differences in climate and creates unworkable requirements for small employers and certain industries, while providing little evidence that these burdens will keep workers safer. Indeed, they may increase administration and recordkeeping such that employers and their supervisors have less time to focus on eliminating other hazards in the workplace.”
The proposal also treated all employees the same without considering physical characteristics that can determine what level of tolerance an individual employee has for exposure to heat.
Whether the incoming OSHA moves forward with this rulemaking is uncertain. If it does not, the rulemaking will likely stay on the regulatory agenda until the next Democratic administration takes office and OSHA revives it.
To see the comments, click here.
Sign Up For Our Newsletter
Receive the latest updates on the linen, uniform and facility services industry from TRSA delivered straight to your inbox.