How Indoor Heat Illness Rule Applies to Air Conditioned Workplace

Our indoor office is air conditioned. Does our business need to include the indoor heat illness requirements in our Injury and Illness Prevention Program (IIPP)?

Yes. The indoor heat illness prevention requirements can either be included in the IIPP or maintained as a separate document or amendment to the IIPP.

The requirements are in effect now. On June 20, 2024, the Occupational Safety and Health Standards Board adopted the proposed indoor heat illness prevention standard. It was forwarded to the Office of Administrative Law, approved on July 23, 2024, and, as requested by the Standards Board, became effective immediately.

Power Outage

The Department of Industrial Relations (DIR) news release states that the Heat Illness Prevention in Indoor Places of Employment regulation applies to most indoor workplaces, such as restaurants, warehouses, and manufacturing facilities where temperatures commonly reach and exceed 82 degrees Fahrenheit.

Employers should keep in mind, however, that it is not uncommon for workplaces to lose power, disabling the office air conditioning units. Depending on the length of the power outage, the office temperature could rise to 82 degrees or more. Therefore, there should be included in the IIPP a note to have emergency contingencies for the office staff.

Requirements

Where the indoor heat illness regulation applies, copious amounts of water must be made available—a minimum of one quart per hour per exposed employee.

Moreover, the temperature or heat index, whichever is greater, is to be recorded and maintained. The record should include the time, date, and location of the measurement, and all other environmental risk factors relating to heat illness should be noted.

The regulation also addresses emergency procedures in the event of an incident, emergency contact information, and supervisor protocol if an incident is in progress or there is concern that an employee may be experiencing heat-related problems.

Also, if the temperature reaches 87 degrees, then additional requirements are introduced, such as cooling down the work area, work rest schedules, and other mandates. Training of the supervisors and employees is stressed.

In some situations, the regulation’s requirements do not apply, such as when a worker is exposed to temperatures below 95 degrees for 15 minutes within a 1-hour period or for employees teleworking from a location of the employee's choice not under the control of the employer.

More Information

The complete regulation can be found at the Cal/OSHA website (https://www.dir.ca.gov/dosh/heat-illness/indoor.html) on Indoor Heat Illness Prevention. Information can also be found in the division’s frequently asked questions section (https://www.dir.ca.gov/dosh/heat-illness/indoor-faq.html).

The above article was recently posted on the online CalChamber Alert newsletter and was authored by Mel Davis. Davis joined the CalChamber in 2000 as a workplace safety expert specializing in Cal/OSHA and safety-related matters. He worked for Cal/OSHA for more than 23 years as a principal safety engineer and construction safety engineer. His responsibilities included managing the technical staff responsible for developing and revising California safety and health regulations, evaluating requests for variances from regulations, and conducting complaint and accident investigations at all types of construction sites.

For expert explanations of labor laws and Cal/OSHA regulations, not legal counsel for specific situations, call (800) 348-2262 or submit your question at https://hrcalifornia.calchamber.com/.