California regulators are about to adopt a far-reaching heat illness standard for indoor work areas that will be triggered when the temperature reaches 82 degrees Fahrenheit. If adopted in its current form, it will present numerous challenges for California employers – but especially for warehouses, distribution centers and manufacturing plants where the indoor temperature cannot be readily controlled. What are the three things you need to know about this impending new obligation?

  1. Proposed Rule Has Rigid Compliance Framework:
  • Employers will be required to establish a written Indoor Heat Illness Prevention Program when the temperature reaches 82 degrees Fahrenheit.
  • The program must include procedures for accessing water, cool-down areas, and emergency response measures.
  • Training on heat illness topics must be provided to employees and supervisors.
  • Cool-down areas must be maintained at a temperature below 82 degrees, shielded from direct sunlight, and protected from high radiant heat sources.
  • Additional rest periods for cool-down must be allowed and encouraged, with monitoring for heat-related illness symptoms.
  • New employees must be closely observed during a 14-day acclimation period, and during heatwaves with no effective engineering controls.
  1. Challenges for Employers:
  • Measuring Heat: Employers must measure the temperature and heat index when it reaches 87 degrees Fahrenheit (or 82 degrees Fahrenheit with specific conditions). Measurements should also be taken when the temperature is expected to rise by 10 degrees or more.
  • Control Measures: Employers must implement a hierarchy of control measures, starting with engineering controls (e.g., air conditioning), followed by administrative controls (e.g., shift adjustments), and personal heat-protective equipment if needed.
  1. Recent Revisions Provide Modest Clarity and Relief:
  • Exceptions: Brief indoor presence, compliance solely with indoor rule for indoor-outdoor workers, and recognition of vehicles with effective air conditioning.
  • Definition Clarifications: “Clothing that restricts heat removal” is clarified.
  • Feasibility Exception: Cool-down areas that can’t be shielded from sunlight and radiant heat sources have a feasibility exception.
  • Premium Pay: Premium pay is available for cool-down rest period violations.
  • Integrated Training: Integrated training is recognized under both outdoor and indoor heat illness standards.

This new rule aims to protect indoor workers from heat-related illnesses, but it also poses challenges for employers to ensure compliance, especially in industries where temperature control is difficult. The recent revisions provide some relief and clarification for employers. It’s important for employers to stay updated with the latest information from regulatory authorities and ensure that their workplaces adhere to the new regulations.

For specific questions or further assistance on this topic or other HR matters, you can contact JorgensenHR at or 661-600-2070.


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