Coalition Comments on OSHA Heat Standard Small Business Panel Materials

ARTBA and its coalition partners sent a letter to the Occupational Safety and Health Administration regarding a new potential standard for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings, noting:

• If OSHA Moves Forward with Their Efforts to Regulate Heat Injury and Illness, its Standard Should Be Flexible, Performance-Based, and Emphasize Training.
• The Construction Industry Has Shown that a Flexible Approach to Addressing Heat Injury and Illness is Effective.
• Prescriptive Administrative Controls Are Ineffective and Unworkable.
• OSHA’s Proposed Temperature Triggers Are Impractical and Lack Scientific Support.
• Any Acclimatization Requirements Must be Flexible, Science-Based, and Allow for Self-Managed Acclimatization Periods.
• Any Rest or Break Requirements Must be Flexible.
• Additional Administrative Controls Must Be Flexible.
• Any PPE Requirements Should be Adaptable to the Work Environment.
• The Proposed Recordkeeping and Written Plan Requirements Are Unnecessary and Impose Burdensome Compliance Obligations on Construction Employers.
• Personal Risk Factors Are Outside of an Employer’s Control but Significantly Impact How an Employee Will be Affected by Extreme Heat, and Construction Employers Should Not Be Required to Collect Information About Such Risk Factors.
• A Construction Worksite Is Not Purely An “Indoor” or “Outdoor” Work Environment.