All Employers covered by OSHA
April 12, 2022
Contact HR On-Call
On April 12, 2022, OSHA released a National Emphasis Program (NEP) on heat illness and injuries for both indoor and outdoor employees. OSHA NEPs are temporary programs that concentrate OSHA resources on specific workplace injuries and illnesses. This new NEP is effective until April 8, 2025, cancellation, or extension by OSHA.
When a new NEP is issued, employers should expect greater scrutiny on their workplace practices that combat the injury or illness on which the NEP is focused. The current NEP is designed to prevent heat-related injuries and illnesses, such as heat stroke, heat exhaustion, and falls or cuts that occur during or after heat exposure. Employers with outdoor workspaces in particularly hot areas of the country and employers with indoor workspaces near radiant heat sources, such as iron and steal mills, should expect to receive most of OSHA’s focus while the NEP is in place.
The NEP states how employers will be selected for inspections, including:
- Using NAICS codes of non-construction employers, found in Appendix A of the NEP.
- Conducting additional heat-related inspections while OSHA is conducting unrelated inspections, if the health official observes hazardous heat conditions or sees heat-related injuries or illnesses in an employer’s OSHA 300 or 301 reports.
- Expanding inspections where the heat index during the inspection is 80 degrees or higher.
- Coordinating with the Department of Labor’s Wage and Hour Division.
- Following-up after a prior OSHA inspection if an employer was given an other-than-serious recordkeeping violation for failing to record heat-related injuries or illnesses.
While the NEP explains OSHA’s new focus on heat-related injuries and illnesses, it unfortunately does not issue any standards employers must meet. To comply, employers must continue to meet OSHA’s General Duty Clause, which requires employers to provide a work environment free from recognized hazards.
- Review existing OSHA logs for heat-related injuries or illnesses.
- Create a prevention program that addresses heat-related injuries and illnesses.
- Assign appropriate personnel at each worksite to observe employees for heat-related injuries or illnesses.
- Inspect job sites and review job duties or positions that could expose employees to extreme heat.
- Subscribers can call our HR On-Call Hotline at (888) 378-2456 for further assistance.
Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2022 ManagEase