ASSP recently submitted technical comments, informed by input from our members, on OSHA’s proposed heat injury and illness prevention standard.

The comments were informed by input from our members, who identified several themes and concerns. Overall, ASSP supports OSHA’s efforts to enhance workplace safety but recommends revising the proposal to address implementation challenges, align more closely with the robust ANSI/ASSP A10.50-2024 standard and incorporate performance-based elements. The agency's acknowledgment of A10.50 is a step forward, but ASSP encourages further integration of its detailed guidance to strengthen the final rule. 

 Opportunities and Challenges 

1. Potential to address heat-related hazards. Our members recognize the importance of this proposed rule in reducing heat-related hazards and exposures. The clarity it provides regarding employer responsibilities is welcomed. 
2. Implementation challenges. Members noted significant implementation challenges related to the proposed rule, particularly for smaller organizations with limited resources and technical expertise. 
3. Alignment with voluntary standards. ASSP members appreciated OSHA’s recognition of ANSI/ASSP A10.50-2024, which reflects the value of leveraging voluntary national consensus standards in regulatory efforts. 

Key Concerns and Recommendations

The Society's comments note six areas of specific concern:

1. Heat safety training. More detail on training requirements is essential. ASSP suggests that training based on ANSI/ASSP A10.50 be recognized as compliant supplemental training.
2. Heat-related factors. OSHA’s standard should address critical variables such as physical condition, weather factors, clothing, activity level and medication effects that can impact heat-related risks.
3. Recordkeeping and reporting. OSHA needs to clarify recordkeeping requirements before issuing a final rule. ASSP recommends a comparative chart aligning the new requirements with existing OSHA standards (29 CFR 1904).
4. Heat triggers and metrics. OSHA’s proposed threshold of 80°F aligns with ANSI/ASSP A10.50 but could be burdensome in regions where this temperature is common year-round. The Wet Bulb Globe Temperature (WBGT) index used in A10.50 is more comprehensive than the heat index metric in OSHA’s proposal.
5. Heat safety coordinator role. Members expressed concerns about OSHA’s proposal to introduce a heat safety coordinator role. ASSP recommends using OSHA’s existing definitions of “competent person” and “qualified person” instead of creating new roles that could cause duplication and confusion.
6. Paid rest breaks. While supportive of rest breaks, ASSP members noted challenges for workers paid by piece-rate and cautioned OSHA against wading into wage-related issues. 

Heat Injury and Illness Prevention Programs 

ASSP also recommends that the proposed rule contain more performance-based elements similar to those in OSHA’s Process Safety Management standard. ASSP also noted its appreciation that OSHA offered a comparison between its proposed rule and ANSI/ASSP A10.50 and applauded the agency for citing the standard as a reference.

However, the Society asserts that ANSI/ASSP A10.50 is a much more comprehensive and impactful standard than the OSHA proposed rule overall and should be explicitly referenced as a model for program creation.

In its comments, the Society points to two key differences between A10.50 and the OSHA proposal:

1. Use of metrics. A10.50 relies on WBGT, which accounts for factors like sunlight, air movement and local radiant heat, providing a more accurate measure of heat risk. The heat index metric used in OSHA's proposed rule does not account for these factors.
2. Stop work authority and competent persons. A10.50 requires stop work authority and explicitly defines the role of a competent person, both of which are absent in the OSHA proposal. 

Read ASSP’s full comments