Heat stress can hit workers hard when they're working on rooftops at 80° F or higher. If they overexert themselves, they could easily fatigue themselves or develop other heat-related conditions, including exhaustion and heat stroke. Even without these risks, hot temperatures can make their hands sweaty and slippery, fog up their OSHA-mandated safety glasses, and make objects uncomfortable to hold. Together, these potential hazards indicate one thing: That facilities managers and safety coordinators need to build safety protocols built for hot environments.
In July 2024, OSHA proposed a "Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings" rule that would go into effect when employees must work in the heat. Even as the end of summer has arrived in many areas, employers should prioritize developing practices and purchasing safety equipment that allows them to easily comply with the new measure. Take a closer look at what your team can do to minimize heat injury and illness on rooftops as the proposed rule goes through the steps to becoming an official part of OSHA's standards. We also explore the value of OSHA warning line systems and fall protection systems in the status quo.
OSHA's July 2, 2024, proposal for "Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings" standards is not yet law. Instead, it's a proposal that comprehensively covers the prevention of heat-related illness and injury at any workplace where employees are expected to work at least 15 minutes out of every 60 in temperatures at least 80° F—with additional requirements for environments with a heat index of 90° F or more—and it applies to indoor and outdoor settings.
Under the provisions of the proposal, employers would need to create a written HIIPP plan that lists all their work activities to which the OSHA standard applies. Then they will need to write out how they will monitor temperatures, how they will comply with the OSHA standard, and who on their team is the heat safety coordinator(s) mandated with ensuring compliance. The HIIPP would contain a list of emergency contacts and procedures.
Since it's not yet mandated, this new OSHA proposal might easily slip to the bottom of your to-do list. But proactive employers who start examining it now can:
Participate in the 120-day comments window if the standard is unclear or hard to implement
Use it as a guide to create safe work break policies
Start training employees about the risks of heat stress and the signs of heat stress in their coworkers
Audit their facilities and outdoor work units to determine what equipment and changes would make them compliant
Anticipating future enforcement puts your company in the best position to protect your employees now and more easily transition to full compliance in the future.
Heat-related injuries and illness can be very broad, ranging from muscle weakness that makes workers lose their grip on a ladder to dizziness that makes them stumble into a stairwell. Directly reducing the risk through breaks, water access, fans, and educational training is important, but it can't fully address the increased risks of falls that heat stress can cause. Instead, employers need to also make their flat roof fall protection and construction fall protection plans more robust.
There are two main strategies every employer can use for comprehensive rooftop safety: warning lines and guardrails.
1.) OSHA Warning Lines to Make Boundaries and Uneven Ground Clearly Visible
Warning lines are visible signals to workers. They mark the boundary between safe and unsafe walking or working areas. In an indoor facility, warning lines might stand in front of an open dock door when trucks aren't present, as dock doors are often used for ventilation. In construction areas, OSHA-compliant warning lines might lay out safe paths between different workstations or cordon off the unfinished edge of a building.
These are vital tools when conditions are hot. Even when workers are distracted or disoriented, they can use these clear warning lines to get back to a safe area.
2.) Guardrails as a Physical Barrier and Visible Warning
Guardrails are even more robust, and it's important to choose installations that meet OSHA guardrail requirements. While they can act as a visual warning, they are also sturdy and strong enough to lean against or bodily block a fall. Facilities should have OSHA-compliant guardrails around open mezzanine floors, for example, so the edges of the floor are readily apparent and someone who trips into the railings can catch their footing. Under most circumstances, guardrails must be approximately waist-high and capable of supporting 200 pounds.
Disoriented workers can trip onto them and still be safer from the open edge of the floor or stairway. Workers with sweaty or slippery hands can also use guardrails and machine enclosures as an extra railing system if they lose contact.
Ideally, your company or safety operations team won't need to wait until OSHA's HIIPP proposal is fully approved and added to the official body of standards. Instead, considering how heat affects workers and work conditions, especially as it applies to fall protection, should only entrench currently accepted best practices.
The new proposed rules focus primarily on heat acclimatization, breaks, education about heat stress, and temperature monitoring—your fall prevention and mitigation obligations remain the same. Heat may significantly increase the risk of trips and falls, so your team must pay close attention to rules that either stop the incidents before they happen (with OSHA warning line and guard rail systems) or minimize the risk of injury if they do occur (with fall protection hardware like harnesses).
Even without the increased safety and documentation burden of the new rules, facilities should regularly conduct safety audits to create the safest possible work conditions in cold, temperate, and hot conditions. You can do so by focusing your compliance efforts on these standards:
29 CFR 1910: These general workplace safety standards govern fall prevention during standard operations and maintenance. Follow OSHA guardrail requirements for permanent structures, clearly mark unsafe edges or uneven flooring, and install guardrails and barriers for permanent flat roof fall protection. Flat roofs must have clearly marked edges and most permanent equipment on the roof will need OSHA-compliant machine enclosures.
29 CFR 1926: This set of standards covers construction sites. Construction fall protection is more detailed and complex, as there are more hazards, and those hazards change from day to day. Heat concerns are also often higher at construction sites, as outdoor temperatures in some regions can easily climb into the triple digits.
OSHA's HIIPP proposal will require a lot of changes for employers, especially if you work outside of the five states that currently already have progressive heat safety standards. But they won't change how important it is to have construction fall protection, flat roof fall protection, OSHA warning line solutions, and interior guardrails across virtually every industry.
If you want to improve your facility's or work site's fall prevention practices, invest in OSHA-compliant or CCOHS-compliant hardware and permanent installations that are built to provide ongoing safety through better visibility, clear markings, fall prevention, and meet OSHA guardrail requirements.
Stay on tractel.com to learn more about developing fall prevention news or to find fall safety products to protect your workers.
