Heat Injury and Illness Prevention Plan Employers must develop and implement a work site heat injury and illness prevention plan (Plan) with site-specific information, which, among other things, includes the following: 1. A comprehensive list of the types of work activities covered by the plan; 2. All policies and procedures necessary to comply with these requirements; and 3. An identification of the heat index or some other metric the employer will monitor to comply with this regulation. The Plan must be evaluated for its effectiveness and updated either annually or whenever a heat-related illness or injury results in death, days away from work, medical treatment beyond first aid or loss of consciousness, whichever occurs first. It also must be readily available at the work site to all employees and available in a language each employee understands. Roles The employer must designate one or more heat safety coordinators to implement and monitor the Plan. Additionally, the employer must seek the input and involvement of non-managerial employees in the development and implementation of the Plan. Responsibilities The employer must regularly monitor heat conditions in outdoor work areas and, at indoor sites, must identify each work area where there is a reasonable expectation that employees are or may be exposed to heat at or above the initial heat trigger of 80 degrees Fahrenheit. Once the initial heat trigger is reached, the employer must implement controls, such as providing drinking water in specific locations, establishing break areas at outdoor and indoor work sites with adequate shade or air-conditioning, implementing rest breaks, and providing adequate cooling personal protection equipment (PPE). If employees are exposed to a high heat trigger (90 degrees Fahrenheit), then other requirements are necessary. The employer must also establish heat illness and emergency response procedures, which include a list of emergency phone numbers, contact information of designated individuals, descriptions of how to transport employees to places where they can be reached by emergency personnel, clear directions to the work site to be provided to emergency dispatchers, and procedures for responding to an employee experiencing signs and symptoms of heat-related illness. For a more comprehensive understanding of the regulation, scan the QR code to review the official text. https://www.osha.gov/sites/default/files/ Heat-NPRM-Final-Reg-Text.pdf As noted previously, the OSHA proposal is just that — a proposal — so stay tuned. The details previously mentioned could change from those proposed, but some form of a final rule is likely, so you should prepare now. ComplyAuto will continue to monitor this regulation and keep you posted on any significant changes. Remember also that few states (California, Oregon and others on the way) have their own heat-illness-related regulations. California’s requirements are extensive, but ComplyAuto has you covered. Soon, we will offer the following to help you comply with these heat illness prevention regulations: • Heat Illness Prevention Plan. • Supervisor and Non-Supervisor Employee Heat Illness Training. • Temperature Measurement and Recordkeeping. • Cool-Down Area Questionnaires. COMPLYAUTO RESOURCES It is now more important than ever to stay on top of heat‑related issues at your dealership. In addition to the state‑specific resources outlined above, ComplyAuto currently has heat stress and heat-related injury and illness prevention training courses and heat illness prevention plans available to ensure a safe workplace environment. With the summer season upon us, we highly encourage you to enroll your staff in these courses to help them understand the symptoms of heat stress (they are subtle!) and how to safely manage their activities when the heat turns up. QUESTIONS? If you have any questions, please reach out to your dedicated client success manager to learn more or send us an inquiry at info@complyauto.com. It is now more important than ever to stay on top of heat-related issues at your dealership. THE GENERATOR 32
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