MIOSHA
Michigan Occupational Safety and Health Administration
Department of Licensing and Regulatory Affairs
DOCUMENT IDENTIFIER:
MIOSHA-MEMO-COM-12-1R1
SUBJECT: Heat-Related Illness Inspections
I.
Purpose:
II.
Scope:
III.
References:
AGENCY
MEMORANDUM
DATE: July 15, 2013
The purpose of this memorandum is to describe the enforcement
aspect of the Michigan Occupational Safety and Health
Administration (MIOSHA) heat-related illness campaign to raise
awareness among workers and employers of the risks associated with
working in hot environments.
This memorandum applies to compliance inspections conducted by
the Construction Safety and Health Division (CSHD), the General
Industry Safety and Health Division (GISHD) and consultative
activities by the Consultation, Education and Training (CET)
Division.
A. Centers for Disease Control and Prevention, Morbidity and
Mortality Weekly Report (MMWR), Vol. 57: No. 24:647-653,
June 20, 2008, Heat-Related Deaths Among Crop Workers --United States, 1992—2006.
B. Occupational Safety and Health Administration (OSHA), TED
01-00-015 [TED 1-0.15A], January 20, 1999, OSHA Technical
Manual.
IV.
Distribution:
V.
Contact:
VI.
Cancellations:
VII.
History:
MIOSHA Staff; OSHA Lansing Area Office; S-Drive Public Folder
Accessible; MIOSHA Weekly; and Internet Accessible.
Patricia Meyer, Director, Construction Safety and Health Division
(CSHD), Adrian Rocskay, Director, General Industry Safety and
Health Division (GISHD), and Nella Davis-Ray, Director,
Consultation, Education and Training (CET) Division
This memorandum cancels all previous versions of this agency
memorandum.
History of previous versions include:
MIOSHA-MEMO-COM-12-1, January 6, 2012
VIII. Originator:
/Martha B. Yoder for/
Barton G. Pickelman, Deputy Director
Michigan Occupational Safety and Health Administration
Significant Changes
Integrated Management Information System (IMIS) code for heat inspections in agriculture was
added.
Added note to Appendix C.
Added more detailed references for historical weather data in Appendix G.
Added new Appendix H, General Duty Violation Conditions.
MIOSHA-MEMO-COM-12-1R1
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Heat-Related Illness Inspections
The purpose of this memorandum is to describe the enforcement aspect of the MIOSHA heat-related
illness campaign to raise awareness among workers and employers of the risks associated with
working in hot environments. The U.S. Centers for Disease Control and Prevention reported 423
heat-related deaths among workers in agricultural and non-agricultural worksites over a period from
1992-2006. The goal of the MIOSHA campaign is to raise employers' and workers' awareness and
to prevent heat-related illnesses and deaths. The campaign focuses mainly on consultation and
training of outdoor workers in the construction and agricultural industries. However, the
enforcement component outlined in this memorandum sets forth the duty of employers to prevent
heat-related illnesses and deaths in both indoor and outdoor workplaces.
Heat-related illnesses generally occur when body heat generated by physical work is exacerbated by
ambient heat and humidity. Heat-related illnesses range from a mild form of heat cramps to heat
stroke, which can lead to death.
Typical indoor worksites where heat-related illnesses may occur include foundries, brick-firing and
ceramic plants, glass production facilities, rubber products factories, electrical utilities (particularly
boiler rooms), bakeries, confectioneries, commercial kitchens, laundries, food canneries, chemical
plants, mining sites, and smelters. Outdoor operations conducted in hot weather, such as agriculture,
landscaping, construction operations, refining (gas and oil well operations), asbestos removal, and
hazardous waste site activities, especially those that require wearing protective clothing, also may
cause heat-related illnesses among exposed workers.
During inspection activity, safety officers and industrial hygienists (SO/IHs) should address heatrelated illnesses at both indoor and outdoor worksites where potential heat-related hazards may exist,
and inspections should include a review of the employers' plans to address heat exposure.
MIOSHA’s consultation program will use the same guidance as the enforcement divisions when
addressing heat-related illnesses at both indoor and outdoor worksites where potential heat-related
hazards may exist.
This memorandum outlines inspection guidance taken from the OSHA Technical Manual, Section
III, Chapter 4. In addition, the following documents are attached:
Appendix A:
Appendix B:
Appendix C:
(NOAA)
Appendix D:
Appendix E:
Appendix F:
Appendix G:
Appendix H:
Heat-Related Illness Inspection Guidance
Sample General Duty Clause Citations for Exposure to Heat Hazard
Heat Index Chart from National Oceanic and Atmospheric Administration
Employer Questionnaire
Employee Questionnaire
Sample Safety/Health Recommendation
Heat-Related Information Links
General Duty Violation Conditions
SO/IHs should use the attached information as a guide along with the OSHA Technical Manual
when conducting heat-related investigations.
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APPENDIX A
Heat-Related Illness Inspection Guidance
Purpose: To provide guidance to industrial hygienists (IHs) investigating workplace conditions that
pose a risk of heat-related illness. MIOSHA does not have a regulation relating to working in hot
environments. Any proposed citations for heat-related illnesses will be addressed by the general
duty clause, section 11(a) of the Michigan Occupational Safety and Health Act (Act 154 of 1974, as
amended). Heat-related illness violations will be issued for both indoor and outdoor work activities,
but must only be issued when all elements of a general duty clause violation are documented and
IHs can establish a link between the workplace exposure and the potential for heat-related
illness(es). The Safety/Health Recommendation form may be used when all the general duty clause
elements are not present. MIOSHA has regulations that may be applicable to work in hot
environments including, but not limited to: personal protective equipment (PPE), sanitation, medical
services and first aid, and recordkeeping.
Heat-Related Illnesses: During the course of any heat-related investigation, Safety Officers (SOs)
/IHs may encounter a variety of heat-related illnesses such as the following:






Heat Stroke
Heat Exhaustion
Heat Cramps
Heat Collapse
Heat Rashes
Heat Fatigue
Case File Documentation:

In order for the agency to track its inspection activity on heat-related illnesses, it is essential
to gather data related to this hazard. All inspections involving heat-related illnesses must be
coded on the MIOSHA-1, in the box 42, Type: N, ID: 2, Value as either "HEATCON"
(construction), "HEATGI" (general industry), or “HEATAG” (agriculture).

Review MIOSHA 300 Logs for any entries indicating heat-related illness. Interview workers
for reports of headache, dizziness, fainting, dehydration, or other symptoms that may indicate
heat-related illnesses.

Review injury and illness reports and obtain any records of emergency room visits and/or
ambulance transport even if hospitalizations did not occur.

Document the information listed in the attached questionnaires (Appendices D and E).

Conduct a walk-around inspection and perform temperature measurements, including wet
bulb globe temperature (WBGT) tests. Additionally, identify all potential sources of heatrelated illnesses. The information obtained from employer and employee interviews should
also be verified during the walk-around inspection. Consult the OSHA Technical Manual Section III, Chapter 4 - Heat Stress for additional inspection procedures and documentation
guidance.
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
Document the heat index and any National Weather Service heat advisory or alert for the day
of the inspection and/or the days employees became ill. (weather conditions, heat index,
NOAA-advisory, wind speed/direction, relative humidity indoor/outdoor, direct sun)

Document whether first aid or prompt medical attention are readily available.
A Section 11(a) citation shall be proposed for cases involving both indoor and outdoor workplace
exposures when all the elements outlined in the Field Operation Manual (FOM) have been
established and there is evidence of a serious heat-related hazard. Refer to the FOM, Chapter 6,
Section II, for enforcement guidance on the application of the general duty clause.
Sampling Procedures:

Conduct workload assessments. Information on performing workplace assessments can be
obtained from the OSHA Technical Manual, Section III, Chapter 4.

Conduct environmental sampling including wet-bulb globe temperature (WBGT) readings,
which combine air temperature and humidity. Refer to the OSHA Technical Manual, Section
III, Chapter 4, for information on conducting WBGT sampling.
Other Applicable Regulations:

Both the occupational health PPE regulation, Part 433, Rule 5(1), and the general industry
safety PPE regulation, Part 33, Rule 3308, require an employer to assess the workplace to
determine if hazards are present, or likely to be present, that necessitate the use of PPE. The
construction PPE regulation, Part 6, requires an employer to provide PPE.

The administrative recordkeeping regulation, Part 11, requires that employers record certain
work-related injuries and illnesses. If a worker requires medical treatment beyond first aid,
the worker's illness or injury must be recorded.

Both the construction sanitation regulation, Part 1, Rule 128(a), and the occupational health
sanitation regulation, Part 474, Rule 420(2)(a)(i), require employers to provide potable water.

The occupational health medical services and first aid regulation, Part 474, Rule
325.47201(2), requires that in the absence of an infirmary, clinic, or hospital in near
proximity to the workplace which is used for the treatment of all injured employees, the
employer shall ensure that a person or persons shall be adequately trained to render first aid.
The construction medical services and first aid regulation, Part 1, Rule 132(3), requires a
person who has a valid certificate in first aid training shall be present at the worksite to
render first aid.
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Appendix B
Sample General Duty Clause Citations for Exposure to Heat Hazard
The general layout for a citation of the general duty clause is described in agency instruction
MIOSHA-COM-07-1, “Procedures for Writing SAVEs and Citations,” as amended. For employee
exposure to excessive ambient heat, the following layout may be used:
MICHIGAN OCCUPATIONAL SAFETY AND HEALTH ACT, ACT 154, P.A. 1974, AS
AMENDED, SECTION 11(a):
The employer did not furnish to each employee, employment and a place of employment,
which was free from recognized hazards that were causing, or were likely to cause, death or
serious physical harm to the employee. Employees were exposed to the hazard of excessive
ambient heat from [specify the environmental or process sources generating the heat and any
heat measurements taken] during the performance of their duties, which included [describe
duties]. Such exposures may lead to the development of serious heat-related illnesses such as
[describe heat-related illness(es) workers were at risk of developing; if there was an actual
heat-related illness, then describe it]. [Describe any actions the employer took or failed to
take that contributed to the risk of heat-related illness.]
Feasible and acceptable methods to abate this hazard include, but are not limited to:
1. Providing adequate amounts of cool, potable water and electrolyte replacements (specific
recommendations should be made by medical consultation) in the work area and require
employees to drink frequently.
2. Providing a work/rest regimen.
3. Training employees about the effects of heat-related illness, how to report and recognize
heat-related illness symptoms and how to prevent heat-related illnesses.
4. Including a heat acclimatization program for new employees or employees returning to
work from absences of three or more days.
5. Providing a cool, climate-controlled area where heat-affected employees may take their
breaks and/or recover when signs and symptoms of heat-related illnesses are recognized.
6. Providing shaded areas where heat-affected employees may take their breaks and/or
recover on worksites that do not have access to climate-controlled areas.
7. Providing specific procedures to be followed for heat-related emergency situations and
procedures for first aid to be administered immediately to employees displaying
symptoms of heat-related illness.
8. Using dermal patches for monitoring core temperature to better identify when workers
need to be removed from the work area.
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Sample No. 1:
MICHIGAN OCCUPATIONAL SAFETY AND HEALTH ACT, ACT 154, P.A. 1974, AS
AMENDED, SECTION 11(a):
The employer did not furnish to each employee, employment and a place of employment,
which was free from recognized hazards that were causing, or were likely to cause, death or
serious physical harm to the employee. Employees who worked in the autoclave area were
exposed to an indoor wet bulb globe temperature of 99.5 degrees Fahrenheit. Such exposures
may lead to the development of serious heat-related illnesses such as heat cramps and heat
exhaustion.
Feasible and acceptable methods of correcting this violation may include, but are not limited
to, the following:
1. Develop a heat stress training program to inform employees about the effects of heat
stress and how to recognize heat-related symptoms and prevent heat-induced illnesses.
2. Use cooling rooms, which can be used to offer a recovery area near hot jobs, and
portable blowers with built-in air chillers, which can offer relief at the workstation.
3. Train employees to stay hydrated by drinking 5 to 7 ounces of water every 15 to 20
minutes throughout the work day and to avoid drinks with caffeine, alcohol, and large
amounts of sugar.
4. Instruct employees to wear light-colored, loose-fitting, breathable clothing, such as
cotton.
5. Implement a screening program to determine any causal factors that may affect the
employee's heat illness susceptibility.
6. Establish a work/rest regimen so that exposure time to high temperatures and/or the work
rate is decreased.
7. Utilize an acclimation program for new employees or employees returning to work from
absences of three or more days.
8. Specify procedures to be followed for heat-related emergency situations.
9. Make provisions so that first-aid can be administered immediately to employees
displaying symptoms of heat-related illness.
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Sample No. 2:
MICHIGAN OCCUPATIONAL SAFETY AND HEALTH ACT, ACT 154, P.A. 1974, AS
AMENDED, SECTION 11(a):
The employer did not furnish to each employee, employment and a place of employment,
which was free from recognized hazards that were causing, or were likely to cause, death or
serious physical harm to the employee. Each employee potentially exposed to the hazards of
extreme heat was not fully trained in accordance with the employer's heat stress program.
Feasible abatement methods include, but are not limited to:
1. Providing employees training in appropriate languages (including annual training and
training upon rehire) about the effects of heat stress and how to prevent, recognize, and
report heat-related illness and implementing a record-keeping system to ensure that new
employees receive such training, regardless of start date, prior to starting work.
2. Conducting daily pre-shift tailgate meetings on days involving extreme heat, during
which employees will be reminded of the effects of heat stress, how to prevent heatinduced illness (such as, but not limited to, taking breaks to drink fluids, rest and protect
from overheating, identifying places to cool off and the availability of cool, potable water
and delivery of electrolyte replacement supplies at the worksite) and how to recognize,
report, and respond to heat-induced illness.
3. Making air conditioned trucks available onsite or by calling production managers.
4. Ensuring that crew leaders are sufficiently trained to remind and monitor employees of
the effects of heat stress, how to prevent heat-induced illness, and how to recognize,
report, and respond to heat-induced illness.
5. Providing each employee with a portable card that sets forth the signs and symptoms of
heat-induced illness and the elements of appropriate first aid in the event of a heatinduced illness.
6. Performing wellness checks, at 85 degrees Fahrenheit and above, by crew leaders in
person and via radio.
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Sample No. 3:
MICHIGAN OCCUPATIONAL SAFETY AND HEALTH ACT, ACT 154, P.A. 1974, AS
AMENDED, SECTION 11(a):
The employer did not furnish to each employee, employment and a place of employment,
which was free from recognized hazards that were causing, or were likely to cause, death or
serious physical harm to the employee. Employees working in forging area were exposed to
excessive heat during the workshift and the employer failed to protect employees from the
hazards associated with heat stress.
A feasible and acceptable method to correct this hazard is to develop and implement an
effective heat stress program that includes, but is not limited to the following:
1. Adequate amounts of cool, potable water and electrolyte replacements in the work area
and requiring employees to drink frequently.
2. Work/rest regimen so that exposure time to high temperatures and the work rate is
decreased and/or rest periods are increased in length and frequency.
3. A training program informing employees about the effects of heat stress, how to report,
recognize heat-related illness symptoms, and how to prevent heat-induced illness.
4. A heat acclimation program for new employees or employees returning to work from
extended absences.
5. A cool, climate-controlled area where heat-affected employees may take their breaks
and/or recover when signs and symptoms of heat-related illnesses are recognized.
6. Cold air showers in work areas where employees are continuously exposed to heat.
7. Specific procedures to be followed for heat-related emergency situations.
8. Provisions requiring first aid to be administered immediately to employees displaying
symptoms of heat-related illness.
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Appendix C
Heat Index Chart from NOAA
To find the heat index, look at the heat index chart below. As an example, if the air temperature is
96°F (found on the top of the table) and the relative humidity is 65% (found on the left of the table),
the heat index--how hot it feels--is 121°F. The National Weather Service will initiate alert
procedures when the heat index is expected to exceed 105°- 110°F (depending on local climate) for
at least two (2) consecutive days.
http://www.nws.noaa.gov/om/heat/index.shtml#heatindex
Heat Index1 (bold numbers in table)
IMPORTANT: Since heat index values were devised for shady, light wind conditions, exposure to
full sunshine can increase heat index values by up to 15◦F. Also, strong winds, particularly with very
hot, dry air, can be extremely hazardous.
1
Adapted from the National Weather Service (NWS) of the National Oceanic Atmospheric Administration (NOAA) at
http://www.nws.noaa.gov/om/heat/index.shtml#heatindex.
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Please note that the heat index DOES NOT account for impermeable clothing; workers in
impermeable clothing will be at risk at lower temperatures.
Appendix D
EMPLOYER QUESTIONNAIRE
Company Name _____________________ Inspection Number _______________
Date ____________________
SO/IH: _________________________
What are the potential sources of heat?
What actions were implemented to prevent heat-related illnesses?
Is there an acclimatization program in place for new employees or employees having been away for
extended time (e.g., vacation)?
Are the employees acclimatized to the work environment?
Have employees complained of the heat?
What is the protocol should employees suffer heat-related illnesses?
Have your employees received training for working in hot environments?
Are work areas monitored routinely for work conditions related to heat stress?
What ventilation is provided at the workplace?
Are employees required to wear protective clothing or equipment?
Do employees wear loose-fitting cotton clothing?
Do employees drink fluids while working?
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Are water and drinks provided to employees?
At what activity level to employees perform job tasks?
Do employees receive breaks?
Are employee breaks according to an established work/rest schedule?
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Appendix E
EMPLOYEE QUESTIONNAIRE
Company Name: _______________________
Inspection Number: _______________
Date:
SO/IH: _________________________
_______________________
Employee Name: _______________________
Job Description:
How long have you worked at this task or work assignment?
How strenuous is your work activity?
What are the potential sources of heat?
Is there a Work/Rest Cycle in place? YES /NO
Is a shaded or climate-controlled area available for rest periods? YES / NO
If applicable, describe the work/rest cycle (e.g., how many breaks do you take, when/where do you
take breaks, how long is a typical break, etc.):
If a shaded or climate-controlled area is available for rest periods, describe:
What ventilation is provided?
Is additional ventilation provided during hot conditions?
What types of personal protective equipment are you required to wear?
Do you wear loose-fitting cotton clothing?
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Is drinking water available? YES /NO
If yes, describe drinking water source and proximity to workers:
Are you required to drink water or any other beverages when working under hot conditions?
YES /NO
If so, is there a specific amount?
Is it enforced?
Have you experienced any health effects related to working in excessive heat?
If yes, describe:
Are other workers experiencing similar symptoms?
Have you received any training on the effects of heat and heat-related illnesses?
YES /NO
If yes, what information was provided?
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Appendix F
SAFETY/HEALTH RECOMMENDATION
Michigan Department of Licensing and Regulatory Affairs
MIOSHA
__ General Industry Safety & Health Div.
7150 Harris Dr., P.O. Box 30644
Lansing, MI 48909-8144
Phone: (517) 322-1831
FAX: (517) 322-6353
__ Construction Safety & Health Div.
7150 Harris Dr., P.O. Box 30645
Lansing, MI 48909-8145
Phone: (517) 322-1856
FAX: (517) 322-6354
Est. Name:
Insp#:
__ Construction Safety & Health Div.
Asbestos Program
7150 Harris Dr., P.O. Box 30671
Lansing, MI 48909-8171
Phone: (517) 322-1320
FAX: (517) 322-1731
SO/IH:
List Site Address if Location of Inspection is Different Than Mailing Address:
An inspection/investigation of your worksite revealed the following
condition(s) which may constitute a safety or health hazard to your
employee(s).
ACTION TAKEN
(To be completed by the
employer.)
An inspection of your workplace and evaluation of your OSHA
recordkeeping logs at [location] on [date] disclosed the following
workplace condition(s) which have been associated with the
development of heat-related illnesses in workers:
In the interest of workplace safety and health, I recommend that you
voluntarily take the necessary steps to materially reduce or eliminate your
workers' exposure to the conditions listed above, including, but not limited
to, the following:
Heat reduction – shield employees from radiant heat sources. Cooling
garments (vests, bandanas) can be worn to reduce the heat exposure to
employees and portable air chillers can be used. During the investigation
it was noted that employees were exposed to radiant heat during (describe
conditions):
EMPLOYER'S NOTE: Please give these potential hazards your immediate attention. When you have taken action, please indicate the action
taken, sign, and return to the appropriate division. Work Safe… Be Safe!
Employer's Signature:
The Department of Licensing and Regulatory Affairs will not
discriminate against any individual or group because of race, sex,
religion, age, national origin, color, marital status, handicap or political
beliefs.
Date:
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Ventilation – provide general air movement through use of supply and
exhaust ventilation. During the investigation it was noted that (describe
conditions):
Administrative controls – set acceptable exposure times to heat, allow
sufficient recovery for employees exposed to heat, and limit physiological
strain by reducing heavy activity. As metabolic rate increases from work
demand, an employee’s exposure to heat stress can result in an excessive
heart rate and elevated body core temperature by not allowing for proper
recovery from heat exposure for the body. Schedule hot jobs for cooler
parts of the work day. During the investigation it was noted that breaks
(were or were not) taken by employees according to the ACGIH®
recommendations for frequency found in Table 2 of the Heat Stress section
of the Threshold Limit Values (TLV) booklet. Employees (were or were
not) allowed sufficient recovery time for heat exposure. (Describe break
conditions):
Training – train employees and supervisors by providing accurate verbal
and written instructions about heat stress, including self-determination of
exposures, first-aid procedures, and reporting of hazards to the employer.
Employees should be aware of the signs and symptoms of heat stress and
should be encouraged to detect these signs in themselves and in
coworkers. Employees should also be permitted to practice self-limitation
of heat exposure based on these signs. During the investigation it was
noted that employees (were or were not) trained on the signs of symptoms
of heat stress.
Heat stress hygiene practices – encourage fluid replacement and the use
of proper clothing. Employees should drink small volumes
(approximately 1 cup) of cool water every 20 minutes. Free movement of
cool, dry air over the skin’s surface maximizes heat removal through
evaporation of sweat from the skin; water-vapor-impermeable or thermally
insulated clothing restricts heat removal. Cooling vest and watercooled/dampened garments may be effective under high temperature and
low humidity conditions. During the investigation it was noted that most
employees (did or did not) drink water. Additionally, employees (did or
did not) wear loose fitting, cotton clothing.
EMPLOYER'S NOTE: Please give these potential hazards your immediate attention. When you have taken action, please indicate the action
taken, sign, and return to the appropriate division. Work Safe… Be Safe!
Employer's Signature:
The Department of Licensing and Regulatory Affairs will not
discriminate against any individual or group because of race, sex,
religion, age, national origin, color, marital status, handicap or political
beliefs.
Date:
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Medical surveillance – allow pre-placement screening to identify those
employees susceptible to systemic heat injury. Employees who take
medications that may compromise normal cardiovascular, blood pressure,
body temperature regulation, renal or sweat gland functions; and those
employees who abuse alcohol may have an increased susceptibility to heat
stress. The employer is not entitled to know whether employees have
those conditions, but only whether employees have any health conditions
that limit their ability to perform job duties. Employers can also
encourage healthy life styles and ideal body weight. The investigation
revealed the employer (did or did not) screen employees to identify those
employees more susceptible to heat.
Acclimatization – this gradual physiological adaptation improves an
individual’s ability to tolerate heat stress. Full-heat acclimatization
requires up to three weeks of continued physical activity under heat-stress
conditions similar to those anticipated for the work, with a loss occurring
after four days. Employers can develop a plan to expose employees to
heat at a gradually increasing rate over a five-day period. During the
investigation it was noted the employees (were or were not) acclimated to
the heat exposure.
EMPLOYER'S NOTE: Please give these potential hazards your immediate attention. When you have taken action, please indi cate the action
taken, sign, and return to the appropriate division. Work Safe… Be Safe!
Employer's Signature:
The Department of Licensing and Regulatory Affairs will not
discriminate against any individual or group because of race, sex,
religion, age, national origin, color, marital status, handicap or political
beliefs.
Date:
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Appendix G
Heat-Related Information Links
1. OSHA's Campaign to Prevent Heat Illness: http://www.osha.goviSLTC/heatillness/index.html
2. OSHA's Safety and Health Topics: Heat Stress: http://www.osha.gov/SLTC/index.html
3. OSHA Technical Manual, Section 111: Health Hazards, Chapter 4, Heat Stress:
https://www.osha.gov/dtsiostalotm/otm iiilotm-iii-4.html
4. OSHA's Field Operations Manual (FOM):
https://www.osha.gov/OshDoc/Directive pdf/CPLp02-00-148.pdf
5. NIOSH Workplace Safety and Health Topics: http://www.cdc.~ovlnioshltopicsiheatstress/
6. The National Oceanic and Atmospheric Administration (NOAA), National Weather Service:
http://www.nws.noaa.gov/om/heat~index.shtml
7. Current weather conditions, including the three-day weather history at National Weather Service
website for the locality.
8. At www.noaa.gov, information from prior dates can also be requested, including at 3-hour
intervals, dry bulb, wet bulb, dew point, and relative humidity. These data are found under Local
Climatological Data. Certified copies can be purchased as evidence in a court of law.
9. NIOSH Publication 86-1 12: Working in Hot Environments:
http://www.cdc.goviNIOSH/docsL36-1121
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Appendix H
General Duty Violation Conditions
A violation of the general duty clause may exist in conditions when workers have been working
outdoors and their employer is aware of heat-related danger but has not taken protective action to
provide worker with, at a minimum, water, rest, and shade. To establish evidence necessary to cite a
general duty clause violation, the following types of information should be documented. Expediting
heat-related inspections, and issuing citations as soon as possible, will result in swift abatement and
reduce heat-related injuries and deaths.
NOTE: These examples represent some types of evidence that could establish each of the factors;
they are not the only types that would satisfy OSHA’s burden:
1. The employer failed to keep the workplace free of a hazard to which its employees were
exposed:
- Workers were exposed to a heat index (HI) at or above the Danger zone (see Appendix
C); or
- Workers were working outside for most of the day or during the heat of the day when
there was a NOAA heat advisory.
2. The hazard was recognized:
- NOAA issued a heat advisory because of a HI at or above the Danger zone (see Appendix
C) and employer was or should have been made aware of the advisory;
- Employees made complaints regarding heat;
- Employees showed signs or symptoms of heat exposure;
- Employer indicated that is was aware of the heat hazard (e.g., by providing water but not
rest and shade); or
- The employer’s industry has issued guidance or information about heat hazards.
3. The hazard was causing or likely to cause death or serious physical harm:
- Heat exhaustion;
- Heat stroke; or
- Fatality.
4. There was a feasible and useful method to correct the hazard:
- Providing workers with immediate access to water, rest, and shade, and allowing them to
use that relief;
- Implementing an acclimatization program for new employees and for those returning
from extended time away (e.g., vacation);
- Implementing a work/rest schedule; or
- Providing a climate-controlled area to cool down.
If all four factors for a general duty clause violation are NOT present, Safety/Health
Recommendations shall be issued to the employer as soon as possible. The Recommendations shall
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MIOSHA-MEMO-COM-12-1R1
July 15, 2013
Heat-Related Illness Inspections
list specific steps the employer can take to protect workers from the heat hazard. A sample
Recommendation can be found in Appendix F.
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