California JPIA provides insight on Cal/OSHA’s new Indoor Heat Illness Prevention Standard

On June 20, 2024, the Occupational Safety and Health Standards Board approved California Code of Regulations, Title 8, Section 3396, Heat Illness Prevention in Indoor Places of Employment. This standard applies to most workplaces where the indoor temperature reaches 82°F and establishes required safety measures to prevent worker exposure to the risk of heat illness. It went into effect on July 23, 2024.

Indoor places of employment are spaces under a ceiling or overhead covering that restricts airflow and are enclosed along the entire perimeter by walls, doors, windows, dividers, or other physical barriers that restrict airflow, whether open or closed. Generally, any workplace with a roof and enclosed sides is considered an indoor workplace.

While this standard was designed for indoor workers performing manual labor, such as manufacturing, shipping, and construction, it may apply if a facility’s air conditioning systems malfunction during extreme heat or in other indoor workplaces, including but not limited to fleet garages, public works warehouses, park ranger stations, modular trailers, wastewater treatment plants, and storage facilities.

Work areas not indoors are considered outdoors and covered by California Code of Regulations Title 8, Section 3395, Heat Illness Prevention in Outdoor Places of Employment. Indoor place of employment does not refer to a shaded area that is used exclusively as a source of shade and cooling for workers working in hot outdoor environments. Partial structures such as lean-tos and structures with one or more open sides are outdoor workplaces.

The indoor heat illness prevention standard does not apply to:

Prisons, local detention facilities, and juvenile facilities.
Places of employment where workers are teleworking that are not under the employer’s control.
Emergency operations that are directly involved in protecting life or property.
Incidental heat exposures where a worker is exposed to temperatures at or above 82 degrees Fahrenheit and below 95 degrees Fahrenheit for less than 15 minutes in any 60-minute period. This exception does not apply to:
- Vehicles without effective and functioning air conditioning.
- Shipping or intermodal containers during loading, unloading, or related work.

Requirements of the indoor heat illness prevention standard include:

Provide Clean Drinking Water
Provide access to potable water that is fresh, suitably cool, free of charge, and located as close as possible to work areas and cool-down areas.

Access to Cool-Down Areas
For indoor workplaces, provide access to at least one cool-down area that must be kept at a temperature below 82°F. Cool-down areas must be blocked from direct sunlight, large enough to accommodate the number of workers on rest breaks so they can sit comfortably without touching each other, and as close as possible to the work areas. For indoor workplaces, the cool-down areas must be kept at less than 82°F and shielded from other high-radiant heat sources.

Cool-Down Rest Periods
Encourage workers to take preventative cool-down rest periods. Allow workers who ask for a cool-down rest period to take one. Monitor workers taking such rest periods for symptoms of heat-related illness.

Assessment and Control Measures
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). Implement control measures to keep workers safe. Feasible engineering controls must be implemented first.

Monitoring the Weather
For indoor workplaces that are affected by outdoor temperatures, train supervisors on how to check weather reports and how to respond to hot weather advisories.

Emergency Response Procedures
Provide first aid or emergency response to workers showing signs or symptoms of heat illness, including contacting emergency medical services.

Acclimatization
Closely observe new workers and newly assigned workers working in hot areas during a 14-day acclimatization period and all workers working during a heat wave.

Training
Employers must provide training to both workers and supervisors.

Heat Illness Prevention Plan
Establish, implement, and maintain an effective written Indoor Heat Illness Prevention Plan that includes 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.

Educational materials and resources are available on the Cal/OSHA Heat Illness Prevention Guidance and Resources webpage. New webpages, educational materials, and resources include:

Updated webpages, educational materials, and resources include:

Providing innovative risk management solutions for its public agency partners for more than 45 years, the California Joint Powers Insurance Authority (California JPIA) is one of the largest municipal self-insurance pools in the state, with more than 125 member cities and other governmental agencies. Members actively participate in shaping the organization to provide important coverage for their operations. The California JPIA provides innovative risk management solutions through a comprehensive portfolio of programs and services, including liability, workers’ compensation, pollution, property, and earthquake coverage, as well as extensive training and loss control services. For more information, please visit the California JPIA’s website at cjpia.org.