Science Policy

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Adopting Evidence-Based Heat Stress Management Strategies in the Workplace to Enhance Climate Equity

04.01.24 | 7 min read | Text by Margaret Morrissey-Basler & Douglas J. Casa

Millions of workers are subjected to the dangers of extreme heat that increase their risk of heat-related illnesses and fatalities. Due to personal, social, and workplace vulnerabilities, workers are at even greater risk, particularly women, people who are Black or Brown, those who facing low-income challenges, and those employed by small businesses. With no mandated federal heat stress standard, there is no federal mechanism to ensure the adoption of appropriate heat stress prevention strategies and emergency procedures to protect vulnerable workers. 

Now is an opportune time to introduce a federal program to champion climate equity and justice in the workplace by assisting employers’ implementation of evidence-based heat stress management strategies and heat illness emergency procedures, particularly targeting underserved working populations who labor in the heat. This program should be supported by the Occupational Safety and Health Administration (OSHA), along with university and nonprofit partners, and funded through a private or public partnership. This effort will act on the principles of employer social responsibility, best practice recognition, increased resource allocation to vulnerable working groups, third-party auditing, and a non-retaliation reporting mechanism. This policy action, across multiple stakeholders, will proactively address the challenges posed by extreme heat and work toward creating safer, more equitable working environments for all.

Challenge and Opportunity

The average global surface temperature in 2023 was 2.12ºF above the 20^th century average, resulting in Earth’s warmest year on record. Extreme temperatures will continue to rise as the frequency, intensity, and duration of heat waves increase due to climate change. Climate change is a major public health priority that places workers who perform physical labor in the heat at higher risk, due to frequent prolonged, heavy physical exertion, layers of personal protective clothing, and exposure to environmental heat stress. This combination of factors exacerbates the level of heat stress placed on the body, leading to heat-related injuries, illnesses, and fatalities. While the Biden Administration has initiated federal action to establish a mandated heat standard, the bureaucratic process is slow, averaging around eight years. Congress is also working on addressing this issue through the consideration of a bill for the adoption of an emergency temporary standard. Although it offers a quicker solution, it has a limited life span of approximately six months. Moreover, in anticipation of mandating a federal heat stress standard, there is limited infrastructure to support the adoption of evidence-based heat stress management strategies to protect workers in high-temperature environments. The current enforcement solution, OSHA’s National Emphasis Program on outdoor and indoor heat hazards, has several limitations, include such as a vague definition of noncompliant following heat hazard inspection, and uses assessment tools such as Heat Index, which is not considered “best practice.” 

To address these limitations, key stakeholders from academic settings, large research institutes, and nonprofit organizations have developed evidence-based best practices to protect vulnerable workers from extreme heat. Unfortunately, there is no system in place to determine how well companies are prepared for extreme heat. The urgency of adopting evidence-based heat stress management strategies across industries cannot be overstated, as heat-related injuries and fatalities are entirely preventable with the implementation of appropriate prevention strategies and emergency procedures.

There is a critical opportunity to champion climate equity and justice to safeguard laborers from the dangers of extreme heat. Laborers from vulnerable demographics who engage in physical work in the heat are disproportionately affected and are often not protected under evidence-based heat stress management practices by their employers. Workers with personal (e.g., age, race/ethnicity, disease status) and social (e.g., employment type, income status) vulnerabilities are exploited by working in hot environments with limited heat stress prevention strategies available to them. This form of labor exploitation during periods of high heat exposure leaves millions of U.S. workers more vulnerable to preventable heat-related injuries and fatalities. 

Small businesses and other companies with limited resources are also less equipped to protect their workforce or have the means to ensure their employees are working in safe environments in the heat. To fortify workplace resilience against extreme heat and climate change, it is imperative to equitably distribute resources for enforcing evidence-based heat policies in workplaces. Organizations with employees exposed to high temperatures must be held accountable for the effective implementation of these policies. Additionally, vulnerable workers frequently refrain from reporting unsafe conditions due to the fear of employer retaliation. Advocacy efforts become even more challenging as language barriers, food insecurity, and poverty exacerbate already dire working conditions.

The present moment presents an opportune time to introduce a program supported by occupational health and safety federal agencies. As evidence-based best practices have been developed to protect workers from extreme heat, there is no system in place to protect vulnerable working populations, allocate resources, and keep companies accountable by assessing their current heat stress management practices. OSHA and the National Institute for Occupational Safety and Health (NIOSH) are key stakeholder organizations to initiate a federal response to address the lack of adoption of heat stress management policies. However, these entities often prioritize multiple projects simultaneously, are understaffed, and benefit from partnerships with universities and nonprofits. Therefore, a cooperative approach with governing like OSHA and universities/nonprofit organizations is the appropriate strategy to create a program that promotes the enforcement of evidence-based heat protection strategies (i.e., education, hydration, heat acclimatization, environmental monitoring, physiological monitoring) at the organizational level. This approach also provides under-resourced businesses with access to basic heat protection equipment and establishes a mechanism for employees to report unsafe working conditions without fear of retaliation. This program draws inspiration from the success of the Fair Food Program, a Corporate Social Responsibility model that promotes accountability among growers, buyers, and retailers. 

This comprehensive program will support all organizations that employ workers who perform physical work in the heat, such as construction, utilities, agriculture, oil, and gas. This program will facilitate employer accountability, social responsibility, increased resource allocation, third-party auditing, and a non-retaliation reporting system. 

Plan of Action

The development and implementation of this federal program, the Occupational Heat Resiliency Program (OHRP), will require a public-private partnership between OSHA, universities, and nonprofit partners. This partnership model draws inspiration from the successful collaborative partnerships between OSHA and other partners to protect the workforce against other occupational hazards. The OHRP will promote the adoption of evidence-based heat stress management practices by targeting employers with workplaces that experience high heat exposure and/or have a large population of laborers working in the heat who are classified as vulnerable workers. The establishment of OHRP will require funding through cooperative agreements, such as the OSHA Strategic Partnership Program (OSPP). To achieve the program’s objectives, both OSHA and its partners will commit their knowledge and resources to support the program.

The program will rely on the following principles to achieve this objective:

1. Employer accountability and best practice recognition:

• Employers engaging with the proposed federal program will formalize their commitment to safeguarding workers from extreme heat through evidence-based practices derived from original research from research institutes and academic organizations. These original research sources have informed governing body recommendations from institutes such as NIOSH. 
• These commitments can be publicized, creating transparency and ensuring that products are manufactured by adequately protected workers.
• The program aims to promote the adoption of evidence-based heat practices that enhance safety, health, and productivity for the U.S. workforce.
• Recognition of best practices will facilitate widespread adoption, empowering employers, safety professionals, and workers to implement strategies and emergency procedures that effectively mitigate the risk of heat-related illnesses and injuries.

2. Climate equity through increased resource allocation:

• Recognizing the disproportionate impact of climate change on vulnerable populations, the program will allocate resources to workplaces with high percentages (>50%) of at-risk workers. This includes small businesses and workplaces with a high percentage of women, people of Color, and low-income workers. Workplace needs will be performed through existing efforts related to other occupational hazards or community projects and by targeting industries associated with increased employment of vulnerable workers. 
• Support may include assistance in creating heat stress management educational materials and emergency action plans/procedures, implementing written heat stress management plans, and providing essential resources such as hydration, shade, and cooling products.

3. Safer work environments through third-party auditing and a non-retaliation reporting system:

• Third-party audits, led by university or non-profit partners, will determine feasible evidence-based practices and resource allocations.
• Audits will employ a tier system (I, II, II) to show the level of protection that the workplace has implemented based on the presented recommendations. To ensure compliance, a non-retaliation reporting system will allow workers to report incidences where their work environment was unsafe due to extreme heat. 
• A non-retaliation reporting system will be implemented to empower workers to report unsafe conditions due to extreme heat, ensuring employer compliance and accountability. This information within the report will not be shared with employers directly, but rather through the third-party auditing entity. 

The program will be led by teams composed of OSHA representatives and university/nonprofit partners that will meet virtually regularly to ensure the goals of each principle are being met and to address any partnership issues that may arise.

Conclusion

The escalating challenges to the U.S. workforce posed by extreme heat demand proactive measures, necessitating collaboration among key government entities like OSHA alongside universities and nonprofit organizations. Currently, there is a glaring absence of mechanisms to safeguard workers who engage in physical work in the heat, particularly those from vulnerable demographics. 

To tackle this issue head-on, the establishment of OHRP funded through a private or public partnership is imperative. This initiative would champion climate equity in the workplace by expediting the adoption of evidence-based heat stress management strategies and emergency procedures. The program’s framework includes commitments from employers, recognition of best practices, increased resource allocation to vulnerable working groups, third-party auditing, and a non-retaliation mechanism. OHRP will have an immediate impact at both the federal and state level. Without the implementation of such a program, a significant portion of the U.S. workforce remains at risk of entirely preventable heat-related injuries, illnesses, and fatalities.

This idea of merit originated from our Extreme Heat Ideas Challenge. Scientific and technical experts across disciplines worked with FAS to develop potential solutions in various realms: infrastructure and the built environment, workforce safety and development, public health, food security and resilience, emergency planning and response, and data indices. Review ideas to combat extreme heat here.