
National Advisory Committee on Occupational Safety & Health (NACOSH) Heat Injury and Illness Prevention Work Group 
April 27, 2023
Time Begun/Adjourned: 2:00 PM - 3:53 PM 

OSHA/SOL Staff: 
Lisa Long, Christie Garner, Zoe Petropoulos, Eduardo Hernandez, Andrew Levinson, Inanje Mintz, Helena Brijbasi, Pamela Barclay, Jennifer Levin (SOL), Jean Gleason, Joo-Hyung Shin, Amy Wangdahl, Carla Marcellus, Dana Voinier, Jason Hammer

Work Group Members: 
Rebecca Reindel, Kathleen Dobson, Cynthia Lewis, Kirk Sander, Jay Withrow, Gavin West, Christopher Long, Mirella Deniz-Zaragoza, Neza Xiuhtecutli, Enjoli DeGrasse, June Spector, Dominque Damian, Nicole Hernandez-Hammer, David DeGroot, Robert Matuga


Meeting Notes: 

Lisa Long, Deputy Director of OSHA's Directorate of Standards and Guidance (DSG) and Alternate Designated Federal Official for NACOSH, welcomed meeting attendees to the NACOSH Heat Injury and Illness Prevention Work Group meeting. Attendance was taken and Ms. Long then invited the work group members to provide brief introductions.  

Ms. Long provided a review of the charge given to the work group. Task #1 was to evaluate and provide input and recommendations on OSHA's heat illness prevention guidance materials. Ms. Long noted that the work group presented their report on Task #1 at the NACOSH meeting in January. Task #2 asks the work group to "Critically evaluate stakeholder input to the Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings Advance Notice of Proposed Rulemaking (ANPRM), and develop key recommendations of potential elements of a heat injury and illness prevention rulemaking that OSHA should consider."

Rebecca Reindel, Work Group Co-Chair, stated that the primary focus of this meeting will be on Task #2`s regulatory aspect of the charge, specifically to identify potential elements for a proposed heat standard.  She provided a brief overview of the work group's efforts to date on Task #2. The work group focused on what the critical elements of a heat standard would be and reviewed a variety of sources to develop best practices. Ms. Reindel shared two documents to accompany the discussion.  One document was an Excel workbook containing a compilation of state heat standards and laws, including both those that have been adopted and proposed. The other document was a Task #2 draft report, including findings and recommendations for NACOSH. 

Ms. Reindel discussed the core elements the work group identified that could be considered for a heat illness rulemaking. These core elements, discussed in detail in the draft report, include: heat illness prevention plan; training; environmental monitoring; workplace control measures; acclimatization; worker participation; and emergency response.  

Ms. Reindel then opened up discussion to the work group.  Mirella Deniz-Zaragoza mentioned how appreciative she was of the inclusion of worker participation and the acknowledgement of how workload plays a role in heat illness issues in the workplace.  Gavin West reiterated the importance of worker participation and expressed appreciation that the consensus recommendations include workers being involved in the risk assessment process and implementation of controls.

Enjoli DeGrasse noted that environmental monitoring is of importance to the Teamsters Union. She mentioned that while it is important to have monitoring on location locally in the buildings and facilities, there needs to be a way to monitor drivers while they are in their vehicles. 

Jay Withrow mentioned that this is a very unique regulation that OSHA is trying to adopt because of having to deal with both interior and exterior hazards. He noted that having a standard that can provide some flexibility, along with one that employers can understand easily so that they can implement it in the least burdensome way, is very important but challenging.  Mr. Withrow suggested that under the written exposure control plan section of the report, the language "the plan must" should be removed, to avoid the perception that the work group is specifying language that would go into a standard.

Rob Matuga noted that during the work group discussions, there was talk about the challenges employers and workers may face in reducing heat injury and illness in work environments. He stated that the challenge for OSHA is going to be determining which of the elements will be really effective at reducing or eliminating the heat hazard. He also mentioned that OSHA will have to analyze the economic impact, especially on small employers. 

Lieutenant Colonel David DeGroot highlighted the importance of recommended language requiring local planning in workplaces where combined levels of heat and worker exertion create a risk of heat stroke.  Employers should be adequately prepared when these circumstances are present.

Nicole Hernandez-Hammer mentioned the importance of the workplace engineering controls that are reflected in the draft report. 

Cynthia Lewis commended the work group for all their hard work on Task #2. She offered some suggestions to the work group for possible additions to the recommendations. First, she suggested that the work group consider including a recommendation regarding regionality. Next, she noted that the addition of definitions of heat wave and high and extreme heat could be useful. Ms. Lewis suggested that instead of referring to "water," consider using the term "fluids."  Lastly, she suggested training materials should be considered as part of Task #1 instead of the Task #2. 

After the discussion, Ms. Reindel asked for the work group to comment on potential edits to the report. With regard to changing the "must" to "should" in some of the recommendations, the work group is in consensus to that change. For the change to "fluids," Lieutenant Colonel DeGroot agreed with Ms. Lewis's recommendation and suggested adding "to include" something like water, sports drink, etc. to add more flexibility. Some work group members felt that a disclaimer should be added regarding the use of high-sugar or energy drinks. Ms. Reindel suggested changing "water" to "water and other fluids." Gavin West agreed and noted that going into detail about beverages that are helpful versus those to avoid is something that would be better addressed in guidance than in a proposed rule. Ms. Reindel suggested tying the water and other fluids issue into the Task #1 report. 

Regarding the suggestion to add language around regionality (variability) and climate across the county, Mr. West noted that a way to address it would be to do risk assessments that are focused on workers,  the task and the jobsite in the specific work environment.  Ms. Reindel agreed and suggested including language regarding variability in the Task #2 report's discussion of risk assessments. She also suggested adding to the report the publication mentioned by June Spector regarding a regional approach to thinking about extreme temperatures.

Ms. Reindel called for a vote to make the changes to the report and also moving forward with sending the report to NACOSH. The NACOSH full committee meeting is scheduled for May 31 and Ms. Reindel will be providing a report on the Task #2 progress. Before moving to a vote, Mr. Withrow suggested that the report should be consistent with the terminology used with regards to variability.  Ms. Reindel noted that the terminology will be updated. All work group members voted "yes" to send the recommendations to the NACOSH full committee. 

Before concluding the NACOSH Heat Injury and Illness Prevention Work Group meeting, Ms. Reindel noted that she will present the Task #2 report to the NACOSH full committee on May 31, and include in the discussion the different methods, the sources of information, and the challenges. Kathi Dobson, Work Group Co-Chair, asked, and confirmed, that all the information presented at the work group meeting will go into the docket and there will be a transcript of the work group meeting that will be useful for the full NACOSH committee to review. 
























