OSHA takes important first steps to address growing risks of heat to workers

As climate change intensifies heat-related risks in the workplace, the Occupational Safety and Health Administration (OSHA) is developing regulations that would provide critical protections for workers from heat hazards in indoor and outdoor settings — a process that should incorporate consideration of climate impacts and the firsthand expertise of affected workers.

As an initial step in the rulemaking process, last fall, OSHA announced its intent to propose a rule and requested public comment on how to design a heat standard that will provide effective protection. Environmental Defense Fund and the Institute for Policy Integrity recently submitted joint comments supporting OSHA’s efforts to protect workers and urging that the agency design standards that account for the disproportionate impacts of extreme heat on marginalized communities and the increased heat risk that workers will face due to climate change.

Laboring under high heat can lead to heat exhaustion, stroke, kidney disease, and other maladies. Heat also makes workplace injuries more likely, with studies finding increased rates of accidents like ladder falls and even helicopter crashes. A day of over 100°F is associated with a 10-15% increase in traumatic workplace injuries, compared with a 60°F day. Climate change exacerbates these harms, driving up temperatures, humidity, and the frequency and severity of extreme heat events.

Like many other climate-related perils, workplace heat dangers are distributed unequally, affecting marginalized and vulnerable groups most imminently and severely. Heat exposure harms workers who labor outside, such as agricultural and construction workers, and those in high-heat indoor environments, such as warehouse employees, restaurant workers, and many others. These workers are disproportionately from marginalized communities, including workers of color, workers lacking immigration status, and low-income workers. Furthermore, heat exposure can be particularly dangerous to workers with existing health vulnerabilities.

Currently, the U.S. workforce faces climate-amplified heat risks with little regulatory protection. Despite having clear authority to impose requirements “reasonably necessary or appropriate to provide safe or healthful employment and places of employment,” OSHA has not previously issued rules specifying employers’ obligations to their workers regarding heat protections. Only four states have heat standards in place for workers: California, Minnesota, Oregon, and Washington. These policies vary in stringency and provide valuable data on the effectiveness of different approaches to protecting against workplace heat.

In crafting a nationwide heat standard, federal regulators have the opportunity to incorporate research on existing state standards and to consult with officials, worker representatives, and other stakeholders who can offer firsthand knowledge of these policies, including potential ways to strengthen them at the federal level. State policies have in some cases insufficiently protected workers from heat-related illness, particularly workers in high-risk industries. A study monitoring farmworkers in California, for example, found that half of monitored workers experienced at least one symptom of heat-related illness during the workday, nearly 12% suffered from dehydration, and 8% had core temperatures elevated above safe levels. These concerning results occurred even with a state heat standard in place. There is a clear need for a federal heat standard, consistent with OSHA’s authority and responsibility, and such a standard should incorporate the successes and avoid the failures of existing state standards.

At a minimum, OSHA should consider available quantitative data and published studies on the health impacts of existing state standards, future climatic conditions, and other relevant topics. But this alone is insufficient, and our comments also urge OSHA to listen and be responsive to the lived experiences of the workers who labor under high heat. Those of us who work in air-conditioned offices often lack firsthand insight into what it is like to perform manual work in the heat and how heat standards may translate—or fail to translate—into real-world business operations. Similarly, the policies on paper at a business may not be reflective of what happens in practice. Learning from workers and organizers with on-the-ground experience will enable OSHA to craft a more effective heat standard.

As OSHA weighs the overall costs and benefits of various configurations of a heat standard, we encourage the agency to also consider who is bearing those costs and receiving those benefits. Lower-income people, people lacking immigration status, and people of color disproportionately bear the costs of heat stress. The potential benefits to these communities from strong workplace heat protections are an important distributional consideration that should be fully reflected in the agency’s analysis of potential rules. A rule that has lower net benefits than an alternative, but confers more of those benefits on workers rather than corporations, may better fulfill OSHA’s mandate and better enhance social welfare. OSHA should carefully weigh any desirable distributional consequences of the rule as an important unquantified benefit.

As climate change worsens, extreme temperatures are becoming more frequent and heatwaves are becoming longer and more severe. Heat scenarios that were unlikely yesterday are more likely today, and may be commonplace tomorrow. OSHA has the authority and the responsibility to develop a heat standard that addresses climate-amplified heat risks to American workers.

This post was co-authored by EDF Legal Fellow Jesse Hevia and Bridget Pals, Legal Fellow at the Institute for Policy Integrity at NYU Law School. It is also posted on the Institute for Policy Integrity’s website.

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