Heat is one of the most dangerous environmental conditions most workers will encounter while on the job. Heat stress can affect concentration and strength, leading to injuries and additional workplace perils. It can also cause secondary dangers such as poor grip on ladders due to sweaty hands, poor visibility due to foggy glasses, and hot equipment that is hard to hold properly. Depending on your facility, the heat may be due to the summer sun (such as for many outside construction crews), or it may be due to hot interior furnaces or poor warehouse ventilation. Everything from having better cooling systems to installing commercial swing gates that prevent falls from heat stress plays a role in mitigating the dangers of high heat.
Currently, the obligation to protect workers from heat-related hazards falls squarely on employers with little federal or state direction. While there are specific state and local mandates, OSHA does not currently have a clear code of actions employers can take to mitigate heat stress or, even more narrowly, minimize the risk of dangerous falls due to heat. They are changing this with the proposed Heat Injury and Illness Prevention Plan (HIIPP) standards published in July 2024. Warehouse safety managers now have the opportunity to read the proposal, prepare comments during the review window, or proactively make changes to internal safety policies based on developing indoor safety and fall protection news.
What Is the Proposed HIIPP Standard From OSHA?
OSHA has been developing a plan for heat-related standards for a few years, and they published their proposal on July 2, 2024. It’s meant to counter the hazards of heat exposure in both indoor and outdoor workspaces without adequate climate control: exterior work areas, loading docks, warehouse spaces, rooftops, and so on. Called the Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings standards, it defines employer obligations for:
- Monitoring temperatures through accepted tools and measures
- Creating a safety plan to control heat hazards and protect workers
- Training workers on recognizing the signs of heat stress and other heat-related illnesses
- Collecting emergency contact information and having an action plan in the event of a heat-related incident
That second obligation, the safety plan, will be multi-faceted and unique to every work facility. Warehouses have several different angles of potential temperature control and safety options. Not only can you implement changes that keep temperatures lower, but you can also install hardware that prevents accidents and falls and minimizes the risk of injury if falls occur.
Temperature Levels You Need to Know About
This set of standards is relatively complex. It covers different regulatory requirements for indoor, outdoor, and indoor/outdoor environments at three different temperature thresholds. We recommend reviewing all three, knowing the typical and maximum temperature conditions in your facility’s work environments, and building a plan tailored to your unique business needs:
- 80° F: This is the threshold at which the new standard applies. If your warehouse temperatures stay below 80° F, the standards won’t apply. But once temperatures exceed 80° F—and there is some degree of on-site physical work—employers must provide appropriate acclimatization windows, cooling options, and safety training.
- 90° F: This is the “high heat trigger.” Once temperatures reach 90° F, as measured by a wet bulb globe or the standard heat index, additional safety steps come into effect.
- 120° F: Any area with a temperature above 120° F will be designated as an “excessively high heat area.” You will need to post warning signs that employees can easily see and understand. A good supplement to this is training so your personnel can immediately recognize the signage and know what to do.
How This Will Impact Your Indoor Warehouse Safety Protocols
With these standards in mind, it’s time to start evaluating the interior conditions of your warehouse space, especially where fall prevention standards apply. While the standard has not yet passed, there are three key steps you can take:
1.) Identify the Hazards
First, measure the temperatures of your warehouse space in different areas: the loading docks, any raised platform or mezzanine areas, and in the storage spaces. By starting now, you can gather data as the seasonal temperatures and humidity levels change.
Next, identify any areas where falls are a potential hazard that heat can exacerbate. These include:
- Elevated walking spaces: Elevated pathways are already dangerous. But heat can make workers dizzy, distracted, or uncoordinated. If they’re carrying heavy loads, navigating a crowded space, or simply feeling unwell, the risk of a fall drastically increases.
- Ladders: Ladders and ladder hatches are dangerous because workers can lose their grip while climbing up and down or transitioning to the raised floor. Distracted or disoriented workers can also step backward into hatches without adequate fall prevention tools like a metal swing gate.
- Staircases: Just like ladders and elevated pathways, staircases are more hazardous for heat-stressed workers who may be suffering from dizziness or muscle weakness.
- Mezzanines: Any raised platform with open edges presents a fall hazard. Workers can trip and fall off the edge or stumble off the edge if it’s not clearly marked and protected with a metal swing gate. Hot air rises, so mezzanine spaces without adequate ventilation may also be much warmer than the spaces below.
- Loading docks near open doors: Warehouses are notoriously hot and stuffy, and a common solution is to keep the loading dock doors open to get a breeze. But this means there’s a wide open, unprotected edge—right in the middle of a lot of activity.
- Areas near or on machinery: Machinery generates heat. Workers near large equipment need additional consideration based on the environment, type of work, and physical hazards in the space.
2.) Introduce Solutions That Eliminate or Reduce the Hazards
Once you identify every hazard, it’s time to install hardware that makes your warehouse compliant with OSHA standards—both the new proposal and established fall prevention standards like OSHA 1926 (for construction tasks) and OSHA 1910 (for most general maintenance and operations). These solutions include:
- Commercial swing gates like horizontal pivot gate systems that solidly block ladder hatches, stairways, and other openings. A metal swing gate needs to generally be around 40 inches high and support sufficient weight so workers can catch themselves.
- Railings that entirely encircle open edges around a mezzanine so there are no gaps for slips and falls.
- Warning lines or barriers in front of loading dock gates that clearly mark and obstruct the open edge while still allowing a breeze.
- More available warehouse fall protection harnesses and safety nets where needed; while these systems don’t prevent falls, they protect against injury in the event of a fall incident.
3.) Train Your Team
Training is always vital when striving for greater compliance with new and old OSHA standards. Introduce recurring training windows on how to use warehouse fall protection gear, best practices for preventing falls and injuries, the importance of not propping horizontal pivot gate systems open, and so on. With the new standards in mind, also introduce training so your personnel can recognize the signs of heat stress and are aware of the temperatures in different parts of the warehouse.
IMPORTANT Next Steps for Warehouse Safety Managers
OSHA’s Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings aren’t finalized. But they represent changes every warehouse will need to make in order to better protect workers—and the company itself. At Fabenco, we design and supply OSHA-compliant commercial swing gates, including horizontal pivot gate options, and additional forms of warehouse fall protection. Reach out today to learn more about our philosophy, or browse our available products to start preparing your warehouse.
