OSHA Heat Stress and Prevention National Emphasis Program

It is now late spring and temperatures across the southeast have been fairly mild, but we all know the summer heat and humidity is just around the corner. I wanted to take the opportunity to discuss the topic of Heat Stress and Illness Prevention. In April 2022 OSHA launched its National Emphasis Program (NEP) for Heat-Related Hazards. This Nep is designed to protect at-risk indoor/outdoor workers from the rising threat of heat-related illness. The NEP targets 70 high risk industries which includes agriculture. This article aims to address what the NEP means to employers and how to address and prevent heat-related illness in the workplace.

A National Emphasis Program is not an OSHA Standard but does empower OSHA with enforcement measures to insure employers are providing a workplace free from the effects of heat-related hazards. This NEP applies when employees are exposed to heat above 80 F and humidity above 40% (80 F heat index). Moving forward OSHA inspectors:

  • Will ask about heat-related prevention programs during all on-site inspections.
  • Will open an inspection if heat-related illness is recorded on OSHA 300 logs or there is an employee complaint.
  • Will conduct randomly generated programmed inspections when the National Weather Service has issued a heat warning or advisory in the area.

In the southeast we have not experienced any programmed inspections, however other regions of the cotton belt did receive multiple heat-related programmed inspections in cotton gins last summer. This National Emphasis Program on Heat-Related Hazards is something OSHA is taking serious and something we as an industry should also be taking serious as we prepare and move into the heat of the summer.

Employers have always been aware of the dangers of heat in the workplace and in turn have made adjustments to address the hazards facing employees working indoors/outdoors in hot environments. This may be providing water, shade, frequent breaks, early starts times, etc. all which help to address the ability of employees to avoid the dangers of heat related illnesses. With this program, OSHA has released several fact sheets and guidelines to help employers address the hazards of heat related illness and increase awareness with employees.

OSHA Heat Illness Prevention Campaign: https://www.osha.gov/heat

OSHA Heat-exposure:  https://www.osha.gov/heat-exposure

OSHA Fact Sheet: https://www.osha.gov/sites/default/files/publications/heat_stress.pdf

OSHA posters:  https://www.osha.gov/publications/bytopic/heat-illness-prevention

OSHA Heat Safety Tool: https://www.osha.gov/heat/heat-app

The links above provide great information on the topics of Heat-Related Illness and include information to assist employers with creating, implementing and training employees on heat-related illness prevention programs. Along with the written information in the links there are also many posters that can be downloaded and placed around the workplace to help remind workers about the dangers of heat-related illness. There is also a link above for an app to help employers monitor and predict when heat-related hazards may be present at their locations.

What Factors May Contribute to Heat-Related Illness?

  • High temperature and humidity
  • Low fluid consumption
  • Direct sun exposure or extreme heat
  • Limited air movement
  • Physical exertion
  • Bulky protective clothing

What is Heat-Related Illness?

Heat Stroke: Is the most serious and occurs when the body can no longer regulate temperature and body temperature rises to levels greater than 104°F. This is a medical emergency that may result in death. The symptoms are confusion, loss of consciousness, seizures, and lack of the ability to sweat. Medical help must be called while attempting to cool worker down.

Heat Exhaustion: Is the next most serious and results in headache, nausea, dizziness, weakness, irritability, confusion, thirst, heavy sweating, and body temperature over 104°F. Workers with heat exhaustion should be moved to cooler area and given liquids to drink. The body can be cooled with cold compresses. Workers with signs of heat exhaustion should be taken to a health clinic or ER for treatment. Heat exhaustion can lead to heat stroke if not treated.

Heat Cramps: Are muscle pains caused by the loss of body salts and fluid due to sweating. Workers must replace fluid loss by drinking water or electrolyte replacement liquids .

Heat Rash: is the most common problem with hot work environments and is caused by sweating. It appears as red cluster of pimples on the neck, upper chest, groin, or elbow creases. The best treatment is to provide a cooler, less humid work environment.

One thing to remember with each of these types of heat illness, is that if not observed and treated early a lesser illness could become a more serious illness. Therefore monitoring for and understanding symptoms is very important in protecting workers from heat related illness.

What Is OSHA Looking for from Employers?

  • Written Heat-Related Illness and Prevention Program. This program should address heat hazards, symptoms of heat-related illness, and emergency response plans.
  • Emergency planning and response plans must be in place. What to do if heat illness symptoms occur. Who to call and how to provide emergency care until help arrives
  • Training provided in a language and manner workers understand, including information on health effects, symptoms, and how to prevent and response the heat illness.
  • Designated a person to oversee the heat stress program. This person must be trained in the hazards, physiological responses to heat, and controls. This person will oversee and monitor the program
  • Hazard identification involves recognizing heat hazards and the risk to workers due to high temperature, humidity, sun exposure, etc.
  • Monitoring for heat illness symptoms and establishing a system to report potential issues. Using the buddy system will assist supervisors and workers to monitor and watch for signs of heat illness.
  • Water Rest Shade. Water is made available. Workers ae encouraged to drink water in small amounts frequently. Fully shaded or air-conditioned areas are available for rest and cooling down.
  • Acclimatization is when workers are given time to build tolerance to working in the heat. Workload and exposure are gradually increased while taking frequent water and rest breaks. Acclimatization may take up to 14 days or longer and depends on the individual and the work environment.
  • Modified work schedules may reduce worker exposure to heat. Increasing work/rest cycles, starting work earlier, rescheduling physically demanding work, and stopping work are all methods to modify work schedules to limit or prevent exposure of workers to high heat hazards.

It is important for employers to monitor and be aware of heat related illness in the workplace. Unfortunately we work in a hot humid area of the country and these heat related issues may arise at some point. These topics have been discussed in the past and many of you already have methods in-place to address some of the hazards and issues presented above. With the introduction of the OSHA National Emphasis Program Related to Heat Illness Prevention, this presents a great opportunity to use the guidelines and information provided by OSHA to reevaluate and formalize a Heat-Related Illness Prevention Program at your gin.


Ginners Attend 3-Day Safety Seminar

Nearly 20 ginners gathered at Associated Cotton Growers this week to attend our second Safety Seminar and Powered Industrial Truck Train-the-Trainer course. Ginners from Alabama and Georgia came to Athens, AL and attended a safety course over a three day period. The attendees saw presentations on many topics including engaging employees, hazard and risk recognition, machine guarding, fall protection forklifts, powered industrial trucks and lockout/tagout.

By the end of the course, the attendees were all qualified to train operators of powered industrial trucks (forklifts) and mobile elevated work platforms (scissor lifts and boom lifts). Nearly all of the topics included some classroom and hands on participation.

Our next class is in Greenville, NC May 9-11. More information can be found at https://www.ginpress.org/gin-safety-training-3-day-seminar-train-the-trainer/

Reminder – Safety Seminars

Our 3-Day Safety Seminars are starting to fill up. We still have some slots to fill. Please take a few minutes and to go our seminar registration page and register. These schools are geared toward the front line supervisors and crew leaders that are responsible for the day-to-day supervision and training of employees in the gin and warehouse.

Participants will learn some about OSHA regulation but the bulk is the WHY behind the WHAT. Why is fall protection important and how to do it right is just one example. Lock-out is another. The participants will also walk away with the ability to train employees on the proper use of fork lifts/bale squeezes a mobile elevated platforms such as scissor lifts and boom lifts.

Please Register soon. Space is limited.

DoL Releases New AEWR Rules for H-2A Program

The Department of Labor recently released new rules surrounding the H-2A program’s Adverse Effect Wage Rate. The new rules will change the way employers file job orders and the wages of some employees could be significantly changed. The biggest change is if an employer has a job that does’t fit one of the six classifications that are sampled in the USDA NASS Farm Labor Survey, the job could get a wage other than the traditional AEWR.

Many H-2A users have been shocked in the past two years by HUGE increases in the Adverse Effect Wage Rate. The rate is supposed to make sure that the employers don’t use the program to adversely affect the wages for similar jobs in the local area. The government didn’t want to depress wages by using ‘cheap foreign labor’. To determine this they have used various means but in recent years, they have been using the USDA National Ag Statistics Service Farm Labor Survey results as a floor. Overly simple logic says that any wages below the average will pull it down and ‘adversely’ affect those receiving that average.

The new rule seeks to make sure the H-2A program not only doesn’t adversely affect those field and livestock workers but also other occupations that are done on the farm but are not field and tractor type work. There are six classifications that are sampled in the FLS. The vast majority of jobs that H-2A employers have are going to be in those jobs but there are some such as Truck Drivers, Crew Leader/manager etc. that would be outside and will have to have a different wage. For these jobs, the DoL is looking to the Bureau of Labor Statistics Occupational Employment Wage Survey. The OEWS samples a lot fewer employers to get its data and doesn’t differentiate regions as much as the FLS does. This could translate into a ginner in S. GA having to pay truck driver rates that employers in ATL pay. It could also mean that those jobs would need a separate contract. We’re still working to understand the new rule and its implications.

The National Council of Ag Employers is an organization that has the H-2A program as one of its main issues. They are planning on contesting this new rule in court but in the mean time, they will be holding a webinar next Tuesday March 21, at 3 PM EDT on this new rule. If you’re interested, you may want to attend. I am attaching below some background material and you can find a link to the actual rule here.

This will not be the last we will write on the new AEWR rules. Please work with your provider (agent, lawyer, FLC etc. ) to see how this new rule could change the way you file and pay your workers. Register for the NCAE Webinar HERE.

Gin School Registration Open

The 2023 Ginners Schools open for registration. The three schools are going as planned without the restrictions on attendance they had last year. The Schools are set for March 27-29 in Lubbock, May 2-4 in Las Cruces, NM, and June 6-8 in Stoneville, MS.

Please see the PDF below for more information and how to register. We hope you’ll be able to make one of the schools this year.

2023 Safety Three-Day Safety Seminars (Train-the-Trainer) Scheduled

The 2023 Train-the-Trainer Safety Seminars have been scheduled. We have scheduled TWO Seminars this year. These seminars are targeted to the individuals doing the actual training and/or day-to-day supervision in the gin. Participants will get approximately a day and a half of classroom time and as much hands on time as necessary to demonstrate proficiency to the instructors.

There are a couple reasons to consider this seminar beside the general safety information provided. The first is a lot of practical knowledge surrounding OSHA rules and regulations. The instructors have many years (decades) of experience dealing with OSHA in Agriculture and General Industry. Another is that the participants will leave the seminars with all the materials and knowledge necessary to train other employees on Powered Industrial Trucks (Fork lifts and Bale Squeezes) and Mobile Elevated Work Platforms (Scissor Lifts and Boom Lifts).

April 25-27 we will hold the school at Associated Cotton Growers Gin. This gin will host the group for all three days of classroom and hands on training. May 9-11 we will be holding the classroom time at the Holiday Inn in Greenville, NC and the hands-on at the Pitt County Gin in Bethel, NC.

Please see our SEMINAR PAGE for more information, Registration and Draft Syllabus for the seminars. Space is Limited to 25 per Session.