Indoor Heat Illness Prevention

Background 

In 2006, California Division of Occupational Safety and Health (Cal OSHA) implemented a heat illness prevention for outdoor workplaces (California Code of Regulations (CCR), Title 8, section 3395).  Less than 10 years later, on June 20, 2024, Cal OSHA approved CCR, Title 8, section 3396 for “Heat Illness Prevention in Indoor Places of Employment” and the new standard became effective on July 23, 2024.  The Indoor Heat Illness Prevention Standard was developed to protect employees at risk for heat illness in indoor work environments in California, such as warehouses and manufacturers, due to record high temperatures in the state.  The new standard applies to workplaces with indoor areas that have temperatures or heat indexes measuring 82°F or higher when employees are present.  Compared to the 2006 standard for outdoor workplaces, this new standard for indoor workplaces includes a requirement for implementing temperature and heat index assessments and control measures.   

According to Centers for Disease Control and Prevention and CCR, Title 8, section 3396, heat illness includes, but is not limited to; heat stroke, heat exhaustion, rhabdomyolysis, heat syncope, heat cramps, and heat rash. Common signs for these illnesses include confusion, light headedness, loss of consciousness, hot or dry skin, profusely sweating, high body temperature, weakness, or muscle aches. 

Indoor Heat Illness Prevention Plan  

Affected employers are expected to prepare an Indoor Heat Illness Prevention Plan (IHIPP).  The plan may be added to the employer’s Injury and Illness Prevention Program or the Outdoor Heat Illness Prevention Plan. The plan must be written in English and the language spoken by the majority of employees. At a minimum, the plan must include procedures for: 

• Providing clean drinking water. 

• Providing cool-down areas. Employers must always have and maintain at least one cool-down area during employee working hours. The designated areas must be less than 82°F. Cool-down areas must be available to be used at all times during working hours. 

• Providing rest periods. Employers must encourage and allow employees to take preventive rest periods in a cool-down area whenever the employee feels the need due to overheating.  

• Assessments and measurements of heat. Employers must measure temperature and heat index measurements and record whichever of the two is higher whenever they reasonably suspect the temperature to be 82°F. 

• Control measures. Employers must use control measures based on the environmental risk factors for heat illness prevention. Control measures can be engineering controls or they can be administrative controls.  

• Emergency response.  

• Acclimatization: New or newly assigned employees to a work area where the temperature or heat index equals to or is greater than 82°F must be closely observed for 14 days of employment by a supervisor or designee and heat illness risks must be assessed. 

• Training: Employees are required to receive effective training on risks of heat illness indoors and outdoors, the contents of the IHIPP, procedures for responding to symptoms and emergency situations. 

 What’s Next? 

Employers are required to develop, implement, and maintain an Indoor Heat Illness Prevention Plan as of July 23, 2024. ALL4 staff are trained and experienced in implementing health and safety regulatory requirements, including developing workplace safety procedures and providing training. If you have any questions or need assistance in preparing an Indoor Heat Illness Prevention Plan, please contact Jessica Malberg at (909)477-7121 or email at jmalberg@all4inc.com or Ayoon Ahmad at aahmad@all4inc.com.