I. Purpose & Scope
To ensure that all employees of MGE Underground, Inc. are protected from heat illness while working on job tasks where environmental risk factors for heat illness are present and to establish the minimum requirements for working in this environment.
II. Definitions
Acclimatization – a temporary adaptation of the body to work in the heat that occurs gradually when a person is exposed to it. Acclimatization peaks in most people within four to fourteen days of regular work for about two hours per day in the heat.
Environmental risk factors for heat illness – working conditions that create the possibility that heat illness could occur, including air temperature, relative humidity, radiant heat from the sun and other sources, conductive heat sources such as the ground, air movement, workload severity and duration, protective clothing and personnel protective equipment worn by employees.
Heat Illness – a serious medical condition resulting from the body’s inability to cope with a particular heat load, and includes heat cramps, heat exhaustion, heat syncope, and heatstroke.
Personal risk factors for heat illness – factors such as an individual’s age, degree of acclimatization, health, water consumption, alcohol consumption, caffeine consumption, and use of prescription medications that affect the body’s water retention or other physiological responses to heat.
Preventative recovery period – a period of time to recover from the heat in order to prevent heat illness.
Shade – blockage of direct sunlight. Canopies, umbrellas, and other temporary structures or devices may be used to provide shade. One indicator that blockage is sufficient is when objects do not cast a shadow in the area of blocked sunlight. The shade is not adequate when the heat in the area of shade defeats the purpose of shade, which is to allow the body to cool. For example, a car sitting in the sun does not provide acceptable shade to a person inside it, unless the car is running with air conditioning.
Temperature – the dry bulb temperature in degrees Fahrenheit obtainable by using a thermometer to measure the outdoor temperature in an area where there is no shade. While the temperature measurement must be taken in an area with full sunlight, the bulb or sensor of the thermometer should be shielded while taking the measurement, e.g., with the hand or some other object, from direct contact by sunlight.
III. Policy
A. Responsibilities
- The RSO or designated representative is responsible for assisting with providing training to all potentially impacted employees and their supervisors on the risks and prevention of heat illness, including how to recognize symptoms and respond when they appear.
- Directors, Managers and Supervisors are responsible for identifying all employees who are required to work outdoors where potential heat illness could occur and identifying the supervisor of the employees. These procedures shall include but are not limited to:
- Effective communication by voice, observation or electronic means
- Observation of employees for alertness and signs/symptoms of heat illness
- Reminding employees to drink water throughout the shift
- Closely supervising employees for their first 14 days of employment unless the employee indicates at the time of hire that he or she has been doing similar outdoor work for at least 10 of the past 30 days for 4 or more hours per day.
- Assuring that adequate water and shade are available at a job site when the environmental risk factors for heat illness are present.
- At or below 80 degrees Fahrenheit every employee shall have timely access to shade upon request. For temperatures at or above 80 degrees Fahrenheit, one or more areas with shade shall be provided at all times while employees are present.
- Ensuring that all affected employees have received proper training on heat illness prevention.
- Ensuring that the requirements in this document are followed.
- Contacting EMS to request emergency medical services in the event medical assistance is required.
- Fleet shall ensure that all vehicles have effective and functioning air conditioning.
B. Provision of water
- Employees shall have access to potable drinking water as applicable, including but not limited to the requirements that it be fresh, pure, suitably cool, and provided to employees free of charge. The water shall be located as close as practicable to the areas where employees are working.
- Where a continuous, plumbed water supply is not available, potable drinking water in the form of bottled water, is provided on pallets in the shop and be provided free of charge to the employee. Employees are instructed to get, at a minimum, 1- 36pk. case of water, per two-man crew, for an 8-hr. shift (32oz./1qt. of water per hour, per employee for the entire shift.) and shall be available at the beginning of the shift, and at all times for each employee for the duration of the entire shift while working.
- An ice machine will be provided in the mechanic shop, and all employees are encouraged to refill their water coolers, daily, so they will have continuous cool potable water throughout the day. Supervisors shall remind employees to drink frequently and this topic will be addressed at tailgate meetings.
- For field employees, water coolers will be stored under shade structures in locations where temperatures are at or above 85 degrees. Water coolers will be stored in shade in a location closest to the work as possible. Water bottles will be distributed to each employee to be held near their worksite. Multi-colored dots will be placed on caps to identify each owner of the bottle to eliminate the possibility of drinking from a co-worker’s container or bottle.
C. Access to Shade
- Employees shall be provided with, at a minimum, a 10×10’ canopy structure, that they will set up and have access to a shaded area to prevent or recover from heat illness symptoms and where they can take their rest breaks in temperatures greater than 80 degrees Fahrenheit. Shaded area will be provided as close as practical to the areas where the employees are working. Shade canopy will be available for prompt set up and access upon employee request in temperatures below 80 degrees Fahrenheit.
- Canopies/Shade structures will be secured, anchored, weighted down and/or staked down to prevent unexpected movement caused by breezes, wind, or whirlwinds.
- Employees will be allowed and encouraged to take a cool-down rest period in the shade for a period of no less than five minutes at a time when they feel the need to do so to protect themselves from overheating. Such access to shade shall be permitted at all times.
- Shade shall be enough to accommodate employees so that they can sit in a normal posture fully in the shade without having to be in physical contact with each other.
- The importance of taking rest breaks and recognizing when a preventative recovery period is needed allowing employees to cool shall be addressed at tailgate meetings.
- The interior of a vehicle may not be used to provide shade unless the vehicle is air-conditioned, and the air conditioner is on as long as a canopy is set up in addition and only a maximum of two people in a vehicle, unless vehicle is designed to hold more.
- In the event an employee feels discomfort from the heat, a preventative recovery period will be allowed for the employee to cool down and prevent the onset of heat illness. An employee who takes a preventative cool-down rest will be monitored and asked if they are experiencing symptoms of heat illness. In no case will the employee be ordered back to work until signs or symptoms of heat illness have been abated.
- Supervisors and employees shall carry radios, cell phones or other means of communication to ensure that emergency services can be called. Verification that the radios or other means of communication are functional at the worksite shall be carried out prior to each shift.
D. High Heat Procedures
- For purposes of this section only, “heatwave” means any day in which the predicted high temperature for the day will be at least 95 degrees Fahrenheit.
- Supervisors and employees shall carry radios, cell phones or other means of communication to ensure that emergency services can be called. Verification that the radios or other means of communication are functional at the worksite shall be carried out prior to each shift.
- Employees will be provided with an increased number of water and rest breaks and observed closely for signs and symptoms of heat illness.
- Each employee will be assigned a “buddy” to be on the lookout for signs and symptoms of heat illness and to ensure that emergency procedures are initiated when someone displays possible signs of symptoms of heat illness. During periods of heatwave, employees shall not be permitted to work alone.
- High heat procedures will be, encouragement of drinking water and recognizing when a preventative recovery period is needed allowing employees to cool shall be addressed at tailgate meetings.
E. Contributing Factors
- Environmental Factors will be identified prior to each work day. Contributing environmental factors could be temperature, humidity, radiant heat sources and air circulation. Employees and Supervisors will ensure that engineering practices such as, access to shade and/or air conditioning, provision of water, increased number of breaks or other methods shall be utilized as applicable to control the effects of environmental factors.
- Physical Factors will be identified prior to work each day. Contributing physical factors could be type of work, level of physical activity, duration of activity, clothing color, weight and breathability. Employees and Supervisors will ensure engineering practices such as, use of mechanical equipment to reduce manual labor, rotation of job functions, use of cooling neck wraps or other methods shall be utilized as applicable to control the effects of physical factors.
- Personal Factors will be identified prior to work each day. Contributing personal factors could be age, weight/fitness, drug/alcohol use, prior heat-related illness and others. Employees and Supervisors will ensure that the right individual is placed in the work scope and activity that is best suited for the employee’s personal factors. Employees will be given time to acclimate to hot weather work conditions and are responsible to report to their supervisor if they feel the work scope does not fit their physical capabilities.
F. Acclimatization
- Weather will be monitored daily. The supervisor will be on the lookout for heatwaves, heat spikes or temperatures to which employees haven’t been exposed for several weeks or longer.
- An employee who has been newly assigned to a high heat area shall be closely observed by a supervisor or designee for the first 14 days of the employee’s employment.
- Employees and Supervisors will be trained on the importance of acclimatization, how it is developed and how the company procedures will address it.
G. Emergency Response
- When a crew is assigned to a particular worksite, the employees and foreman will utilize the findERnow app, google maps or EAP magnet to locate the nearest hospital, directions and distance.
- Before start of shift Foreman will assign designee to call and meet emergency medical services.
- Supervisors and employees shall carry radios, cell phones or other means of communication to ensure that emergency services can be called. Verification that the radios or other means of communication are functional at the worksite shall be carried out prior to each shift.
- During a heat wave, heat spike, or hot temperatures, employees will be reminded and encouraged to immediately report to their supervisor any signs or symptoms they are experiencing.
- Before assigning crew to the job site, the supervisor will ensure a trained first aid employee or supervisor will be on the job site. When an employee displays possible signs or symptoms of heat illness, a trained first aid employee or supervisor will evaluate the sick employee and determine whether resting in the shade and drinking cool water will suffice or if emergency service providers will need to be called, symptoms to call include, but are not limited to a decreased level of consciousness, staggering, vomiting, disorientation, irrational behavior or convulsions. A sick employee will not be left alone or sent home and will be constantly monitored and/or treated as needed.
H. Training
- Training shall be provided for employees working on job tasks where environmental risk factors for heat illness are present and training for their respective supervisors.
- All employees working on job tasks where environmental risk factors for heat illness are present shall receive instruction before being assigned to work tasks. Training topics shall include the following:
- The environmental and personal risk factors for heat illness, as well as the added burden of heat load on the body caused by exertion, clothing, and personal protective equipment.
- Procedures for complying with the requirements of this standard, including, but not limited to, the employer’s responsibility to provide water, shade, cool-down rests, and access to first aid as well as the employee’s right to exercise their rights under this standard without retaliation.
- The importance of frequent consumption of small quantities of water, up to 4 cups per hour, when the work environment is hot and employees are likely to be sweating more than usual in the performance of their duties.
- The concept, importance, and methods of acclimatization pursuant to the employer’s procedures.
- The different types of heat illness, the common signs and symptoms of heat illness, and appropriate first aid and/or emergency responses to the different types of heat illness, and in addition, that heat illness may progress quickly form mild symptoms and signs to serious and life-threatening illness.
- The importance to employees of immediate reporting to the employer, directly or through the employee’s supervisor, symptoms or signs of heat illness in themselves, or in coworkers.
- The employer’s procedures for responding to signs or symptoms of possible heat illness, including how emergency medical services will be provided should they become necessary.
- The employer’s procedures for contacting emergency medical services, and if necessary, for transporting employees to a point where they can be reached by an emergency medical service provider.
- The employer’s procedures for ensuring that, in the event of an emergency, clear and precise directions to the worksite can and will be provided as needed to emergency responders. These procedures shall include designating a person to be available to ensure that emergency procedures are invoked when appropriate.
- Supervisor Training. Prior to supervising employees performing work that should reasonably be anticipated to result in exposure to the risk of heat illness effective training on the following topics shall be provided to the supervisor:
- The information required to be provided to employees
- The procedures the supervisor is to follow to implement the applicable provisions in this section.
- The procedures the supervisor is to follow when an employee exhibits signs or reports symptoms consistent with possible heat illness, including emergency response procedures.
- How to monitor weather reports and how to respond to hot weather advisories.
I. Indoor Heat Illness Prevention
High Heat Controls
- Engineering Controls. Engineering controls shall be used to reduce and maintain both the temperature and heat index to below 87 degrees Fahrenheit when employees are present, or to reduce the temperature to below 82 degrees Fahrenheit where employees wear clothing that restricts heat removal or work in high radiant heat areas, except to the extent that the employer demonstrates such controls are infeasible. When such controls are infeasible to meet the temperature and heat index thresholds the employer shall:
- Use engineering controls to reduce the temperature, heat index, or both, whichever applies, to the lowest feasible level, except to the extent that the employer demonstrates such controls are infeasible; and
- Use engineering controls to otherwise minimize the risk of heat illness, except to the extent that the employer demonstrates such controls are infeasible.
- Administrative controls. Where feasible engineering controls are not sufficient to reduce and maintain the temperature and heat index to below 87 degrees Fahrenheit when employees are present or the temperature to below 82 degrees Fahrenheit where employees wear clothing that restricts heat removal or work in high radiant heat areas, administrative controls shall be used to minimize the risk of heat illness, except to the extent that the employer demonstrates such controls are infeasible.
- Personal Heat-Protective Equipment. Where feasible engineering controls are not sufficient to reduce and maintain the temperature and heat index to below 87 degrees Fahrenheit when employees are present or the temperature to below 82 degrees Fahrenheit where employees wear clothing that restricts heat removal or work in high radiant heat areas and feasible administrative controls do not minimize the risk of heat illness, personal heat-protective equipment shall be used to minimize the risk of heat illness, except to the extent that the employer demonstrates that use of such equipment is infeasible.
- Emergency Response Procedures. The employer shall implement effective emergency response procedures including:
- Ensuring that effective communication by voice, observation, or electronic means is maintained so that employees at the worksite can contract a supervisor or emergency medical services when necessary. An electronic device, such as a cell phone or text messaging device may be used for this purpose only if reception in the area is reliable. If an electronic device will not furnish reliable communication in the work area, the employer will ensure a means of summoning emergency medical services.
- Responding to signs and symptoms of possible heat illness, including but not limited to first aid measures and how emergency medical services will be provided.
- If a supervisor observes, or any employee reports, any signs or symptoms of heat illness in any employee, the supervisor shall take immediate action commensurate with the severity of the illness.
- If the signs or symptoms are indicators of severe heat illness (such as, but not limited to, decreased level of consciousness, staggering, vomiting, disorientation, irrational behavior or convulsions), the employer must implement emergency response procedures.
- An employee exhibited signs or symptoms of heat illness shall be monitored and shall not be left alone or sent home without being offered onsite first aid and/or being provided with emergency medical services in accordance with the employer’s emergency response procedures including contacting emergency medical services.
- Contacting emergency medical services and, if necessary, transporting employees to a place where they can be reached by an emergency responder.
- Ensuring that, in the event of an emergency, clear and precise directions to the worksite can and will be provided as needed to emergency responders.
- Acclimatization. Where no effective engineering controls are in use to control the effect of outdoor heat on indoor temperature, all employees shall be closely observed by a supervisor or designee during a heat wave.
- An employee who has been newly assigned to any of the following shall be closely observed by a supervisor or designee for the first 14 days of employment:
- In a work area where the temperature or heat index, whichever is greater, equals or exceeds 87 degrees Fahrenheit; or
- In a work area where the temperature equals or exceeds 82 degrees Fahrenheit for employees who wear clothing that restricts heat removal; or
- In a high radiant heat area where the temperature equals or exceeds 82 degrees Fahrenheit.
- Training. Effective training in the following topics shall be provided to each supervisory and non-supervisory employee before the employee begins work that should reasonably be anticipated to result in exposure to the risk of heat illness:
- The environmental and personal risk factors for heat illness, as well as the added burden of heat load on the body caused by exertion, clothing, and personal protective equipment.
- The employer’s procedures for complying with the requirements of this section, including, but not limited to, the employer’s responsibility to provide water, cool-down areas, cool-down rests, control measures, and access to first aid as well as the employee’s right to exercise their rights under this section without retaliation.
- The importance of frequent consumption of small quantities of water, up to four cups per hour, when the work environment is hot and employees are likely to be sweating more than usual in the performance of their duties.
- The concept, importance, and methods of acclimatization pursuant to the employer’s procedures.
- The different types of heat illness, the common signs and symptoms of heat illness, and appropriate first aid and/or emergency responses to the different types of heat illness, and in addition, that heat illness may progress quickly from mild symptoms and signs to serious and life-threatening illness.
- The importance of employees immediately reporting to the employer, directly or through the employee’s supervisor, symptoms or signs of heat illness in themselves or in co-workers.
- The employer’s procedures for responding to signs or symptoms of possible heat illness, including how emergency medical services will be provided should they become necessary.
- The employer’s procedures for contacting emergency medical services, and if necessary, for transporting employees to a point where they can be reached by an emergency responder.
- The employer’s procedures for ensuring that, in the event of an emergency, clear and precise directions to the worksite can and will be provided as needed to emergency responders. These procedures shall include designating a person to be available to ensure that emergency procedures are invoked when appropriate.
- Supervisor Training. Prior to supervising employees performing work that should reasonably be anticipated to result in exposure to the risk of heat illness, effective training on the following topics shall be provided to the supervisor:
- The information required to be provided to the employee for training.
- The procedures the supervisor is to follow to implement the applicable provisions in this section.
- The procedures the supervisor is to follow when an employee exhibits signs or reports symptoms consistent with possible heat illness, including emergency response procedures.
- Where the work area is affected by outdoor temperatures, how to monitor weather reports and how to respond to hot weather advisories.
Uncontrolled High Heat
- In the event that one or more of the following conditions is present in indoor environments, this section of the policy shall be enacted.
- Temperatures equals or exceeds 87 degrees Fahrenheit when employees are present or;
- The heat index equals or exceeds 87 degrees Fahrenheit when employees are present or;
- Employees wear clothing that restricts heat removal and the temperature equals or exceeds 82 degrees Fahrenheit; or
- Employees work in a high radiant heat area and the temperature equals or exceeds 82 degrees Fahrenheit.
- Provision of Water. Employees shall have access to potable drinking water, as applicable, including but not limited to the requirements that it be fresh, pure, suitably cool, and provided to employees free of charge. The water shall be located as close as practicable to the areas where employees are working and in indoor cool-down areas. Where drinking water is not plumbed or otherwise continuously supplied, it shall be provided in sufficient quantity at the beginning of the work shift to provide one quart per employee per hour for drinking for the entire shift. Employers may being the shift with smaller quantities of water if they have effective procedures for replenishment during the shift as needed to allow employees to drink one quart or more per hour. The frequent consumption of water shall be encouraged.
- Access to Cool-Down Areas. The employer shall have and maintain one or more cool-down areas at all times while employees are present. The cool-down area shall be at least large enough to accommodate the number of employees on recovery rest periods, so that they can sit in a normal posture fully in the cool-down areas without having to be in physical contact with each other. The cool-down area shall be located as close as practicable to the areas where employees are working. The size of the cool-down area during meal periods shall be at least large enough to accommodate the number of employees on the meal period who remain on site. The temperature in indoor cool-down areas shall be maintained at less than 82 degrees Fahrenheit, unless the employer demonstrates it is infeasible.
- Cool Down Area Use. Employers shall allow and encourage employees to take a preventative cool-down rest in a cool-down area when employees feel the need to do so to protect themselves from overheating. Such access to cool-down areas shall be permitted at all times. An individual employee who takes a preventative cool-down rest:
- Shall be monitored and asked if they are experiencing symptoms of heat illness;
- Shall be encouraged to remain in the cool-down area; and
- Shall not be ordered back to work until any signs or symptoms of heat illness have abated, and in no even less than five minutes in addition to the time needed to access the cool-down area.
- Heat Illness Signs. If an employee exhibits signs or reports symptoms of heat illness while taking a preventative cool-down rest or during a preventative cool-down rest period, the employer shall provide appropriate first aid or emergency response according to subsection.
- Assessment and Control Measures. The employer shall measure the temperature and heat index, and record whichever is greater. The employer shall also identify and evaluate all other environmental risk factors for heat illness. The employer shall establish and maintain accurate records of either the temperature or heat index measurements, whichever value is greater and record the date, time, and specific location of all measurements.
- Temperature and Heat Index Measurements. Temperature and heat index measurements shall be taken as follows:
- Initial measurements shall be taken when it is reasonable to suspect that the conditions that enact this policy are present where employees work and at times during the work shift when employee exposures are expected to be the greatest.
- Measurements shall be taken again when they are reasonably expected to be 10 degrees or more above the previous measurements where employees work and at times during the work shift when employee exposures are expected to be the greatest.
- Records shall be retained for 12 months or until the next measurements are taken, whichever is later. The records shall be made available to employees, designated representatives and representatives of the Division at the worksite and upon request.
- Instruments. Instruments used to measure the temperature or heat index shall be used and maintained according to the manufacturers’ recommendations. Instruments used to measure the heat index shall provide the same results as those in the NWS heat index chart.