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26 PalletCentral • July-August 2022 palletcentral.com worker is placed on restricted duty, by a physician or the employer, an OSHA log entry would be mandated. However, if the worker is only instructed to drink fluids for relief of heat stress, the case is not recordable as that constitutes "first aid" treatment. Also remember that OSHA's Severe Injury Reporting Rule, 29 CFR 1904.39, requires employers to report to OSHA all work-related fatalities within eight hours, and all work-related inpatient hospitalizations within 24 hours, including occupational heat-related events such as heat illness, heat stroke, kidney injury, and rhabdomyolysis that can result in death or inpatient hospitalization. • Sanitation: 29 CFR 1910.141, which require employers to provide potable water. • Medical Services and First Aid: 29 CFR 1910.151, which requires that persons on-site be adequately trained to render first aid, in the absence of medical facilities within close proximity (5 minutes/3 miles) Several state-run OSHA programs already require heat stress prevention programs, either as part of an Injury & Illness Prevention Program (IIPP), or as a state-specific standard (California, Minnesota, Oregon and Washington State). State OSHA standards may be more stringent than any federal rule but must offer at least equivalent protections. In September 2021, OSHA released new guidance on heat stress prevention and while this cannot be used directly for enforcement under the General Duty Clause, if an employer has notice of this, it can serve to impute knowledge of feasibility of controls of heat hazards. OSHA notes that methods of Experts stress that heat illness causes many times more workplace injuries than official records capture due to related injuries from falls, being struck by vehicles, and mishandling machinery due to heat stroke/stress and related difficulties in concentration or fainting.

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