Heat Injury and Illness Prevention

By Beeta B. Lashkari, Eric J. Conn, and Kate M. McMahon

Unsurprisingly, as temperatures rise, activity on OSHA’s Outdoor and Indoor Heat Illness Prevention rulemaking is heating up, too. On May 8, 2024, OSHA announced that it is moving closer to publishing a proposed Heat Illness Rule for U.S. workers in both outdoor and indoor settings. Indeed, timing-wise, Acting Labor Secretary Julie Su told lawmakers at a May 1^st House oversight hearing that OSHA expects to release a Notice of Proposed Rulemaking advancing its long-awaited heat injury and illness prevention standard “later this year.”

Background

The good news is, even before a proposed rule has been issued, we are already seeing the effective work of our employers rulemaking coalition pay off. As a reminder, Conn Maciel Carey has organized and led a diverse coalition of national employers and trade associations representing many industries, from construction and energy, to manufacturing, petroleum refining and chemical manufacturing, retailers and grocers, utilities, warehousing, and many more. We have had a prominent “seat at the table” in this rulemaking from the get-go. During what we called “Phase One” of OSHA’s heat illness rulemaking, in January of 2022, we Continue reading →

By Beeta B. Lashkari and Eric J. Conn

With the winter holidays upon us, heat illness may not be front and center on your minds, but OSHA continues to be push full steam ahead on its rulemaking for a Heat Injury and Illness Prevention Standard in Outdoor and Indoor Work Settings, so we wanted to provide you a quick update.

In September, OSHA had drafted but not yet released a summary document of all of the 1,078 comments the agency had received in response to the ANPRM. That summary document is now publicly available, posted on December 16, 2022 on the National Advisory Committee on Occupational Safety and Health (“NACOSH”) docket for its Heat Injury and Illness Prevention Work Group. Below are some highlights from the summary document.

Notably, our Coalition’s written comments were referenced 14 times in the summary document, including for the following propositions: Continue reading →