Science Policy

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Protecting Workers from Extreme Heat through an Energy-efficient Workplace Cooling Transformation

04.03.24 | 9 min read | Text by June Spector

Extreme heat is a growing threat to the health and productivity of U.S. workers and businesses. There is a high-impact opportunity to pioneer innovations in energy-efficient worker-centric cooling to protect workers from the growing heat while reducing the costs to businesses to install protections. With the impending Occupational Safety and Health Administration (OSHA) standard, the federal government should ensure that businesses have the necessary support to establish and maintain the infrastructure needed for existing and upcoming worker heat protection requirements while realizing economic, disaster resilience, and climate co-benefits. To achieve this goal, an Executive Order should form a multiagency working group that coordinates federal government and nongovernment partners to define a new building design approach that integrates both worker health and energy-efficiency considerations. The working group should establish roles and a process for coordinating and identifying leaders and funding approaches to advance a policy roadmap to accelerate, scale up, and evaluate equitable deployment and maintenance of energy-efficient worker-centric cooling. This plan presents a unique and timely opportunity to build upon existing national clean energy, climate, and infrastructure commitments and goals to ensure a healthier, more productive, resilient, and sustainable workforce.

Challenge and Opportunity

U.S. workers and businesses face a growing threat of illness, death, and reduced work productivity from extreme heat exposure. There were 436 work-related heat deaths recorded in the U.S. from 2011 to 2021. Workplace heat exposure is linked to heat illnesses, traumatic injuries, and reduced work productivity among otherwise healthy workers, costing the nation an estimated $100 billion each year in lost economic activity. Workers exposed to high heat include those in outdoor occupations in agriculture and construction and those working in hot manufacturing, transportation and warehousing, and food services environments. Spikes in worker heat illness have occurred during recent extreme heat events, such as the “heat dome” event of 2021, which are more likely to occur with climate change. Disproportionately exposed workers and small businesses often do not have the resources or capacity to implement, improve, or maintain existing workplace cooling infrastructure, thus increasing heat exposure inequities.

An energy-efficient workplace cooling transformation is needed to ensure businesses have the support required to comply with existing state heat rules and upcoming federal workplace heat prevention requirements. Several states—California, Colorado, Oregon, Minnesota, and Washington—have already adopted occupational indoor and/or outdoor heat exposure rules to protect workers from heat stress. OSHA is in the process of developing a national workplace heat standard. In addition to requirements for worker rest breaks, training, and hydration, OSHA is considering requirements for employers to implement protections when the measured heat index is 80°F or higher, including engineering controls such as air-conditioned cool-down areas. 

Using energy-efficient active or passive cooling systems and building designs in workplaces has numerous benefits. Cooling the environment is one of the most effective methods for reducing the risk of heat illness. Energy-efficient cooling reduces electricity consumption and greenhouse gas emissions compared to conventional systems. Energy-efficient buildings cost less to operate, allowing greater productivity at lower cost and reduced fossil fuel use and community air pollution. Energy-efficient cooling also decreases the amount of electricity on the grid at one time, reducing the chances of blackouts during extreme weather events. 

We must develop a new approach to building standards – energy-efficient, worker-centric cooling – that integrates both worker health and energy-efficiency considerations. Existing building-centric approaches that blanket-cool entire buildings to the same fixed temperature are energy inefficient and can lead to overcooling of unoccupied areas and increased costs. The urgent need for energy-efficient worker-centric cooling standards is highlighted, for example, by the 300–900 million ft² per quarter rate of U.S. warehouse space under construction, and a growing warehouse workforce, in recent years.

There is a gap in standards that address both civilian worker health and energy-efficient cooling simultaneously. The U.S. Green Building Council (USGBC) has incorporated a worker-centric approach in its Leadership in Energy and Environmental Design (LEED) certification program. This approach includes pilot credits for Prevention through Design (PtD), which aims to minimize risks to workers by integrating safety measures into building design and redesign. One such example is ensuring roof features, such as vegetated roofs and solar panel installations, are arranged to minimize hazards like falls for maintenance personnel. However, there are no specific PtD standards or LEED credits for energy-efficient cooling approaches that address worker heat hazards. For example, there are no specific standards that incorporate the proximity of indoor cool-down areas to hot work areas, targeted cooling of certain work areas, or mobile outdoor cooling stations that leverage solar and electrochemical technology.

Although there are several potential mechanisms of support for energy-efficient cooling infrastructure for commercial buildings and small businesses, there is no program to assist employers and small businesses in integrating these technologies into worker-centric cooling infrastructure designs. Under the Inflation Reduction Act of 2022 (IRA), tax deductions are available through Internal Revenue Code (IRC) 179D for building owners to install or retrofit equipment aimed at improving energy efficiency, including HVAC systems such as heat pumps and building envelope improvements to “heat-proof” or weatherize structures. However, tax credits may be difficult to access and may not provide a sufficient degree of immediate support for small business owners struggling with inflation costs. While the Biden-Harris Administration has also launched a $14 billion National Clean Investment Fund that will provide Environmental Protection Agency (EPA) grants to small businesses for deploying clean technology projects, there are no earmarked funds for workplace solutions focused on energy-efficient cooling or resilience to extreme heat events that integrate worker health considerations. Current U.S. Small Business Administration efforts focus primarily on supporting small businesses with disaster recovery rather than resilience.

Effective cross-agency coordination is needed to accomplish an energy-efficient cooling transformation in U.S. workplaces, support small businesses, and contribute to the Healthy People 2030 goal of reducing workplace deaths. Coordination among existing agencies and external partners to address gaps in energy-efficient cooling technology, worker-centric designs, and heat-specific PtD building approaches will support a healthier, more productive, and sustainable U.S. workforce.

Plan of Action

Transforming workplace infrastructure to support a healthy, productive, and sustainable U.S. workforce against extreme heat requires coordination across multiple federal agencies. This plan offers the first steps in developing a structure for coordination, defining the approach, developing a roadmap for future actions, and ultimately catalyzing and piloting innovations and implementing and evaluating solutions.

This plan is guided by the following principles:

• Workplace deaths, illnesses, and injuries from heat exposure are preventable.
• Work equity should be incorporated into decision-making, in alignment with the Justice40 Initiative, to ensure benefit for workers who are most likely to be exposed to dangerous workplace heat and who live and work in communities overburdened by pollution from energy inefficient infrastructure.
• Demand for solutions will be supported by co-benefits of energy-efficient workplace cooling (e.g., reduced workplace costs; increased productivity; reduced greenhouse gas emissions, in alignment with National Climate Task Force Goals and the Department of Energy (DOE) Better Buildings® Better Climate Challenge; and sustainable workplaces that are resilient to extreme events, in alignment with the Biden Administration’s Bipartisan Infrastructure Law).
• High-level sponsorship and clarity of roles are critical to catalyzing the necessary coordination across federal agencies and with public and private partners.

Following an executive order from the President, the Office of Management and Budget should convene a multiagency working group to develop a plan for coordination and to outline a roadmap toward an energy-efficient workplace cooling transformation for a healthy, productive, and sustainable workforce. The working group should:

Recommendation 1. Be chaired by an agency that has experience in convening multisectoral collaborations and advocating for equitable health outcomes, such as the Department of Health and Human Services (HHS) Office of Climate Change and Health Equity. The inclusion of representatives from the following agencies and offices should be considered:

• DOE (e.g., Office of Energy Efficiency and Renewable Energy, Office of State and Community Energy Programs, Office of Small and Disadvantaged Business Utilization)
• Centers for Disease Control (CDC) and its National Institute for Occupational Safety and Health (NIOSH) (e.g., Small Business Assistance Program, National Personal Protective Tech Lab, Division of Science Integration)
• EPA (e.g., Office of Research and Development, Office of Environmental Justice and External Civil Rights)
• U.S. Small Business Administration (SBA) (e.g., Small Business Innovation Research Program, Office of Disaster Recovery and Resilience)
• OSHA (e.g., Directorate of Standards and Guidance)
• National Oceanic and Atmospheric Administration (NOAA) (e.g., Climate Program Office)
• Internal Revenue Service (IRS)
• Bureau of Labor Statistics (BLS) (e.g., Office of Compensation and Working Conditions)
• White House Climate Policy Office

Recommendation 2. Define roles and develop a plan to enhance coordination with public and private partners in developing and evaluating evidence-based worker-centric cooling infrastructure technologies and building designs. Partners should include those that develop or promote voluntary standards and guidelines for:

• buildings (e.g., USGBC LEED Program PtD initiative; American Society of Heating, Refrigerating and Air-Conditioning Engineers [ASHRAE] energy efficiency standard 90.1, 2022 and thermal environment standard 55, 2023; and EnergyStar)
• worker health (e.g., American Conference of Governmental Industrial Hygienist (ACGIH) heat stress and American Industrial Hygiene Association thermal stress working groups) 
• and business and labor representatives identified by the working group.

Recommendation 3. Establish a consensus definition of energy-efficient worker-centric cooling using a combination of established metrics, including:

• metrics for energy efficiency and
• metrics for human effects of heat that account for work characteristics such as ambient heat exposure, workload, and clothing. 

Recommendation 4. Outline existing pathways to support an energy-efficient workplace cooling transformation, including: 

• IRA tax deductions for building owner energy-efficient installation or retrofitting (IRA 13303; IRC 179D)
• National Clean Investment Fund grants through EPA to small businesses deploying clean technology projects
• SBA Office of Disaster Recovery & Resilience business loans, 
• and assess gaps, alternative incentive mechanisms for businesses, and the landscape of private and foundation funders to inform Step 5.

Recommendation 5. Articulate follow-on initiatives and identify leaders and potential funding approaches to advance the roadmap of policies to accelerate, scale up, and evaluate equitable deployment, maintenance, and evaluation of worker-centric energy-efficient cooling infrastructure. Policies considerations include:

• Grant funding mechanisms for research, development, and pilot implementation and evaluation of worker-centric building designs and cooling technologies, such as those through the EPA’s National Clean Investment Fund, SBA/SBIR, or NIOSH’s crowdsourcing mechanisms similar to the Respirator Fit Challenge mechanism. Matching of federal and private and foundation funding should be considered to support rapid development, prototyping, and evaluation of promising worker-centric cooling infrastructure technology and building designs.
• Funding for ASHRAE, LEED, and DOE initiatives focused on incorporating worker considerations into standard development and energy code validation processes that ultimately inform local building codes.
• Funding for the IRS to develop and implement alternative incentive mechanisms that reduce barriers and address gaps in support for businesses interested in implementing energy-efficient workplace cooling infrastructure.
• Funding for DOE to:
  • develop a centralized clearinghouse to disseminate information on federal programs, incentives, and mechanisms for financing energy-efficient cooling retrofits and upgrades for businesses, including small businesses (similar to H.R. 4092; 113th Congress for schools)
  • support coordination of state energy offices with health and labor departments to conduct coordinated outreach on implementation of energy-efficient worker-centric cooling approaches and initiatives, with a focus on small businesses and those with disproportionately exposed workers

Funding for agencies to work together to develop and implement approaches to track progress toward an energy-efficient workplace cooling transformation by combining data sources.

Conclusion

Given the growing threat to U.S. workers and businesses posed by illness, death, and reduced work productivity from increasing heat exposure, it is imperative to catalyze an energy-efficient workplace cooling transformation. There is currently a unique and timely opportunity to build upon national clean energy, climate, and infrastructure commitments and goals to address gaps in energy-efficient worker-centric cooling technology and PtD building standards. The proposed plan will incorporate high-level support, provide infrastructure for coordination among government agencies and nongovernmental partners, define the approach, and lay the groundwork for stimulating innovations in promising worker-centric cooling technologies and designs. This plan will produce a roadmap for an energy-efficient workplace cooling transformation that will support businesses in establishing the infrastructure needed for existing and upcoming workplace heat prevention requirements. The approach will build upon existing occupational health equity initiatives to reduce the risk of heat health effects for workers disproportionately affected by heat and small businesses. This initiative will ensure a healthier, more productive, and sustainable workforce with minimal cost and a substantial potential return on investment.

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.