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July-August 2020

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PalletCentral • July-August 2020 37 Adele L. Abrams is an attorney and safety professional who represents companies in litigation with OSHA and also provides safety training and consultation. The Law Office of Adele L. Abrams PC has three offices: Beltsville, MD; Denver, CO; and Charleston, WV. She may be reached at www.safety-law.com or 301-595-3520. include medical conditions, lack of physical fitness, previous episodes of heat-related illness, alcohol consumption, drugs, and use of certain medication. Management should commit to preventing heat- related illness for all employees regardless of their heat tolerance levels. Measurement of heart rate, body weight, or body temperature (physiologic monitoring) can provide individualized data to aid decisions about heat controls, and this may be integrated into total worker health programs, but individualized biometric data should be kept confidential. In the interim, in terms of OSHA enforcement, employers cannot get complacent. It is recommended that employers assess their workplaces and factors that might contribute to heat stress. If notified of a worker's in-patient hospitalization or death, OSHA will still conduct on-site investigations and can issue citations for all violative conditions it learns about. Put it in Writing Employers can create a written plan to prevent heat-related illness, using tools at OSHA.gov to help. Elements to consider when creating the heat plan are: n Who will provide oversight on a daily basis? n How will new workers gradually develop heat tolerance? n Temporary workers may be more susceptible to heat and require closer supervision. n Workers returning from extended leave (typically defined as more than two weeks) may also be at increased risk. n How will the employer ensure that first aid is adequate and the protocol for summoning medical assistance in situations beyond first aid is effective? n What engineering controls and work practices will be used to reduce heat stress? n How will heat stress be measured? n How to respond when the National Weather Service issues a heat advisory or heat warning? n How will we determine if the total heat stress is hazardous? n What training will be provided to workers and supervisors? Remember, heat stress prevention is a less costly alternative to fighting OSHA citations!

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