NAHB Seeking Member Input on Proposed OSHA Heat Standard

On Aug. 30, OSHA published a proposed rule to establish the first federal standard for preventing heat-related injuries and illnesses for both indoor and outdoor work settings. NAHB has prepared an advocacy video (see below) and summary of the proposal with information on employer requirements.

If finalized, the standard would apply to all employers conducting outdoor and indoor work in all general industry, construction, maritime and agriculture sectors, with some exceptions.

Notably, the standard would require employers to develop a Heat Injury and Illness Prevention Plan (HIIPP) with site-specific information for identifying and controlling heat hazards.

Elements of the HIIPP include:

• The HIIPP must identify heat safety coordinators — managerial or non-managerial employees tasked with ensuring workers comply with the standard on the jobsite.
• For employers with more than 10 employees, the HIIPP must be written in a language (or languages) that everyone on the worksite can understand and be easily accessible for employees. Employers with 10 or fewer employees do not need written plans.
• Employers must seek the input of non-managerial employees in the development of the HIIPP.

The standard also sets specific requirements on a jobsite when certain heat triggers are met. When the heat index on a jobsite reaches 80°F — called the “initial heat trigger” — employers must provide “suitably cool” drinking water to all employees, shaded or air-conditioned break areas, and other requirements.

When the heat index reaches 90°F on jobsites, “high heat trigger” requirements kick in, including paid rest breaks for a minimum 15 minutes every two hours, observation for signs and symptoms of heat-related illness (such as supervisor observation or an employees “buddy system”), and more.

OSHA is allowing the public to submit feedback in response to the proposal until Jan. 14, 2025. NAHB is reviewing the proposed rule to analyze its full impact on residential construction and will submit comments in response.

Because the proposed standard could have a huge impact on the jobsite operations of home builders, NAHB is asking members for feedback on how the new rules could affect their business. We are particularly interested in hearing from members working in states with existing heat standards.

Please read the summary of the proposal for more details. If you have any questions or would like to provide feedback on the proposed standard, email [email protected].

In the meantime, use NAHB's safety resources for dealing with high heat on worksites to keep your workers safe.