Cal/OSHA chief clarifies requirements of heat standard

Issue Date: August 20, 2008
Christine Souza

To reduce the risk of heat-related illnesses among employees, Cal/OSHA Chief Len Welsh recommends employers review the state's Heat Illness Prevention Standard that sets requirements for water, shade, written procedures and training for outdoor employees.

"Measures have to be taken to ensure that employees are not going to be overworked and become overheated when the temperature suddenly changes," Welsh said. "That means they have to work less, work less strenuously, and they have to be getting more breaks throughout the period of work if you want to be sure that you are protecting them from heat illness."

The standard states that each employee must be provided with one quart of cool drinking water for every hour of the employee's shift.

"There can be lots of logistical problems associated with making sure that water is always available and always easily accessible by employees," Welsh said. "Make the facilities clean, make them close and make them inviting. Make it easy and quick for employees to get to the water, get their water and get back to work."

The heat standard does not specify where to place drinking water for outdoor farm employees, as it merely requires that they have access to water meeting the requirements of the Cal/OSHA field-sanitation standard. That standard, in turn, simply says that water must be in readily accessible locations. So, the field-sanitation requirement that toilet and hand-washing facilities be within a quarter of a mile or a five-minute walk—whichever is shorter­—is regarded as a baseline for water placement.

"When it turns really hot, you need to be thinking in terms of much shorter distances. For the average working day, the five-minute rule probably works fine, but for extreme weather, we are going to be looking at the exact circumstances and holding people to a much shorter distance," Welsh said.

In addition to the proximity of water, there has been some confusion about whether employees may use their own personal water containers. Welsh stated that as long as an employer provides water dispensed by either a fountain or single-use cups as required by the field-sanitation standard, it's not a violation for the employer to let employees use their own personal water containers.

Welsh acknowledged that questions continue to be asked about what is adequate shade and how much shade is enough.

"The bottom line is there must always be enough shade to accommodate those employees who seek it to cool off as required by the standard. This does not mean that there must be enough shade to accommodate all employees on the shift at the same time, but employers should anticipate that the hotter the weather gets, the more employees will seek shade during their breaks," Welsh said.

The point of the standard is the shade needs to be adequate to provide cooling. Trees can be a source of high-quality shade. While the presence of little flecks of sunlight here and there doesn't rule it out as adequate, Welsh said shade from trees must be substantial and cover a large enough area so the employee can get completely out of the sun and assume a comfortable posture.

Shade must actually be present, so merely having a canopy or umbrella available for erection if an employee asks for a shade break does not comply with the standard.

Cal/OSHA will accept any reasonable strategy to assure that employees are not deprived of shade when they need it, he added, and employers should think through their strategy and explain it clearly in their written procedures.

Under the standard, the employer's procedures for complying with it must be in writing and address how the employer will respond to symptoms of possible heat illness, including how emergency medical services will be summoned should they become necessary.

In addition, the employer must ensure that clear and precise directions to the work site can and will be provided as needed to emergency responders. This is a big issue considering that many work locations are remote and giving adequate directions to responders may require some thought.

"Employers need to have worked out in advance what is going to happen when somebody feels overcome by the heat and is showing signs of heat illness," Welsh said.

The standard states that training must be provided to all supervisory and non-supervisory employees. Among the topics that must be covered: the importance of frequent consumption of small quantities of water; different types of heat illness and the common signs and symptoms of heat illness; the importance of employees' immediately reporting to the employer symptoms or signs of heat illness in themselves or in co-workers; and the employer's emergency procedures.

Training for supervisors is a critical component that is often overlooked. They are the ones who must implement the employer's program and make sure it is followed, Welsh said.

To learn more about the heat illness regulations and symptoms of heat stress, go to the California Division of Occupational Safety and Health Web site at, or visit the California Farm Bureau Rural Health and Safety program at

Heat-illness training sessions

Training specialists from Cal/OSHA will be providing the following heat-illness training sessions for farm labor contractors:

  • Aug. 23: Santa Maria, Spanish 8 a.m. and English 10 a.m. at the Santa Maria Terrace, 1405 Main St.
  • Aug. 25: Woodland, Spanish 1 p.m. and English 3 p.m. at the Yolo County Farm Bureau, 69 W. Kentucky Ave.
  • Aug. 30: Delano, Spanish 8 a.m. and English 10 a.m. at the American Legion Hall, 729 Kensington St.
  • Sept. 6: Lodi, Spanish 10 a.m. and English at noon at the Oak Ridge Winery, 6100 E. Highway 12.

(Christine Souza is a reporter for Ag Alert. She may be contacted at

Permission for use is granted, however, credit must be made to the California Farm Bureau Federation when reprinting this item.