When the weather gets warmer, it’s hard to keep cool—especially when you work in an industry like construction that requires you to wear personal protective equipment while working outside in the heat.
Although workers may be tempted to remove their PPE when they get hot, they can’t work without it. OSHA requires that employers protect employees from workplace hazards that can cause injury or illness. And while engineered solutions and administrative work practices are effective to some degree, PPE is the last line of defense essential to shield workers from on-the-job safety hazards, so it is vital for employers to provide and ensure its proper use.
When it comes to what employers are required to provide (and pay for), you’ll find the list includes items that protect from infectious agent exposure, respirators and chemical-resistant gloves. What you won’t find are items to protect solely from the weather, such as sunscreen, UV protective sunglasses, UV protective clothing (long-sleeved shirts and long pants) and hats. There are exceptions for certain types of work and legal requirements for PPE vary according to site conditions, job duration and hazards determined in risk assessment—check your local laws and regulations to see what applies to your specific worksite.
Here are a few tips on how to include summer-related protection in your safety program.
Educate on sun protection, coach on its use
Mandating things like sunscreen as PPE would be difficult when you think in terms of monitoring the frequency of application, the strength of protection, alternate solution for those that can’t use it, etc. But ask anyone who has worked outdoors and has been diagnosed with a form of skin cancer and they’ll tell you they wished they had heeded the warnings about the dangers ahead of time so they could have been proactive in prevention. Toolbox talks are a great way to educate workers, and implementing a voluntary UV protection program will protect workers from the harmful effects of the sun. Coach people on their complacency of the risk (“I never burn” or “I just need to build up my base-tan” or “I’ll be okay for today”, etc.) and work towards building a proactive cancer-combative culture where it would be more awkward for someone to not wear sunscreen than to wear it.
It’s not just the UV, it’s the heat
It’s not just construction workers who are affected by the sweltering heat. Summer temperatures also cause the temperature to soar inside where heat-generating equipment is present. Heat stress can affect a number of professions, even if they’ve worked in similar conditions before (you’ll often hear from those who have become acclimatized to their worksite). In 2014, 18 workers died from heat stroke or other heat-related causes. There are currently no specific OSHA standards for occupational heat exposure, but it is recommended that plans to prevent heat-related illnesses be established. Because they aren’t governed, be aware that they are often hard to enforce so it takes awareness, commitment, leadership and a strong culture where people are looking out for one another and openly communicating the importance of heat stress.
Some states, like California, have made it law to protect employees from heat illness by governing a heat illness prevention regulation. The four steps required in the regulation to prevent heat are: train all employees and supervisors about heat illness prevention; provide enough fresh water so that each employee can drink at least 1 quart per hour and encourage them to do so; provide access to shade and encourage employees to take a cool-down rest in the shade for at least 5 minutes; and develop and implement written procedures for complying with the Cal/OSHA Heat Illness Prevention Standard.
Hydration is important
Employers should also be required to provide water to employees on a hot day—but often it’s left to workers to hydrate themselves on their breaks. Working in the heat produces sweat and, as a result, you need to drink more water to stay hydrated. Employees who work in the heat for long periods may find themselves suffering from various signs of dehydration. But hydration breaks are easy to overlook if a deadline is looming. And even when cool water is provided to workers on a job site, it’s one of the first things that could be cut out of a program to save money. Three states (California, Minnesota and Washington State) recognized that more strict standards need to be in place and they have developed their own working in heat regulations. In California, the employer must “not only provide water, but guarantee it is free, fresh, pure and suitably cool.”
Provide more frequent breaks
Unless you’re a truck driver, an inspector won’t come on site and ask to see your logbook for breaks. But maybe they should—working in hot conditions requires more frequent breaks than normal to cool down and hydrate. This is a hard pill to swallow for a lot of employers because it seems like the employees are always on break or taking advantage of the situation and the amount of work being produced is affected. This can result in breaks being cut short or pressure for workers to rest less frequently when there are significant tasks to be completed. And on the flip side, employees often just want to get their work done so working through their breaks seems like short-term pain for long-term gain.
This is a typical safety versus production scenario that won’t be resolved by any heat-related policies. A strong culture of safety is needed in order to find the right balance for safe production. If supervisors and workers are aligned with the company’s core values and safety is one of those values, the work will get done safely without supervisors feeling that workers are taking advantage and the workers will want to meet the deadlines on a reasonable timeline—and they will figure out how to do that without compromising each other’s safety.
The most important thing is to remember that the job won’t get done if workers become ill. Allow several smaller breaks (or productive rest periods) to give them the energy to keep going. It’s a good idea for these breaks to be taken in shaded or air-conditioned recovery areas.
Keeping PPE in use
Employees can compromise their PPE compliance in the heat because they’re more likely to take off their equipment when the temperatures soar and may be more reluctant, “forget” or actually forget to put it back on. One of the most frequently cited personal protective equipment violations is the failure to provide and use proper head protective equipment (1926.100(a)) and the heat could play a big part of head protection not being used.
Instead of focusing exclusively on what is required and what’s not, employers should institute voluntary programs or best practices to address summer PPE. These programs should include toolbox talks or pre-shift meetings to address sunscreen, UV protective clothing, fluid intake, and cool-down breaks. Employers can also help by providing relief with additional PPE items like hard hats with vents, sweat liners, cooling bandanas, ventilated gloves, and anti-fogging goggles. The cost up front is minimal compared to the cost of workers needing to leave due to heat stress or other heat-related illnesses if preventive measures are not in place. Taking these steps is also a great way to reinforce a positive safety culture by showing your employees that you care about their well-being.
To help you get started with your program, take advantage of the Providing the best PPE is no guarantee guide and the 15 Tips to Improve Your Toolbox Talks guide—both are free to download and use.