June 26, 2022

Volume XII, Number 177

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Beat the Heat and Citations – Review Your California Heat Illness Prevention Plan and Procedures

As we head into the summer months, employers with outdoor worksites in California may wish to review their Heat Illness Prevention Plans (HIPP) and obligations under Cal/OSHA’s outdoor heat illness prevention standard.

Covered Employers

As the name of the standard implies, Cal/OSHA’s outdoor heat illness prevention standard applies to all employers with an outdoor place of employment. Simply put, the standard applies whenever an employee is working outside. For example, a supermarket that assigns employees to gather shopping carts in the parking lot would be covered under this standard, even though the market itself is indoors.

Requirements for Covered Employers

Covered employers must take the following steps to prevent heat illness in the workplace:

  1. Train employees and supervisors on heat illness prevention.

  2. Provide enough “fresh, pure, and suitably cool” water so that each employee can drink at least 1 quart per hour and encourage them to do so.

  3. Ensure that timely access to shade can be provided upon an employee’s request.

  4. Encourage employees to take a preventative cool-down rest in the shade when they feel the need to do so to protect themselves from overheating at all times.

  5. Implement effective emergency response procedures related to heat illness.

  6. Closely observe employees that have been newly assigned to a high heat area for the first 14 days of employment, and all employees during heat waves.

  7. Develop and implement a written Heat Illness Prevention Plan.

The following industries must comply with additional high-heat illness prevention procedures:

  • Agriculture

  • Construction

  • Landscaping

  • Oil and gas extraction

  • Transportation and delivery of agricultural products and construction or other heavy materials, except for employment that consists of operating an air-conditioned vehicle and does not include loading or unloading

Written HIPP

Covered employers must have a written HIPP.  We generally recommend that this be a stand-alone document.  Cal/OSHA provides sample procedures for Heat Illness Prevention for employers to review and tailor to their specific work activities.

Cal/OSHA has many resources for employers to ensure compliance with heat illness prevention requirements, including an Enforcement FAQ.

Jackson Lewis P.C. © 2022National Law Review, Volume XII, Number 140
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About this Author

Associate

Sean Paisan is Of Counsel in the Orange County, California, office of Jackson Lewis P.C. His practice focuses on workplace safety and health (OSHA), data privacy, and traditional employment matters, including litigation and counseling.  

Sean’s first exposure to OSHA regulations occurred during his undergraduate studies while working for a construction company that helped build Disney’s California Adventure. After attending law school and working for the Los Angeles County District Attorney’s Office and the United States...

949-885-5233
Sierra Vierra, Jackson Lewis Law Firm, Sacramento, Labor and Employment Litigation Attorney
Associate

Sierra Vierra is an Associate in the Sacramento, California, office of Jackson Lewis P.C. She represents management in civil litigation and administrative proceedings involving employment law matters, including discrimination, harassment, retaliation, wrongful termination, benefits, and a wide range of wage and hour issues. She litigates in federal and state courts, including class and representative actions, and represents employers in administrative proceedings. She also provides preventive advice and counsel on best practices.

...
916-288-3008
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