Working safely in the sun

Authors: Tjeerd Hendel-Blackford, Michael Pantelides, Taotao Yue, Riccardo Zorgno, Dawina Isack, Caitlin O’Sullivan, Danyelle Barron, Elise Saade, Tamer Azar and Karolina Wrzecionkowska

Since 2020, the world has seen record-breaking rising temperatures in many places — and not just the usual, obvious ones. This has raised concerns regarding the risk to human health in various ways, one of which is the safety and welfare of employees when working in extreme heat conditions.

Different jurisdictions around the world are addressing the effects of global warming in various ways. In this article we’ll examine what those differences are — including how emerging markets’ and developed countries’ approaches reflect the severity of climate change impacts they’re experiencing.

Working in heat

Heat exposure is a serious health and safety hazard which can lead to various problems, ranging from physical discomfort to life threatening conditions. Every year, thousands of workers suffer from illnesses directly related to occupational heat exposure, with some ending in fatalities. Global warming and climate change, is increasingly becoming an issue in countries more familiar with sedate summertime temperatures, while it’s magnified in already hot countries.

Outdoor work involving hot and humid conditions such as construction, mining, and oil and gas operations are especially prone to heat-related illnesses, particularly when they involve heavy work tasks requiring equipment and protective clothing. However, it’s important to recognize that human health impacts are preventable if the correct precautions are taken. And yet, as is often the case when economic considerations are in play, not every country is imposing sufficient measures to protect employees.

As an EHS site/regional manager or director, it’s important to know whether your employees and the employees of your contractors are protected from the heat, air pollution and other greenhouse gas emissions, and extreme weather events, whatever hemisphere you operate in.

Asia

China

Spread over such a vast area, China is subject to extremes in weather, including higher temperatures and heat waves. Consequently, Chinese facilities are taking extensive and precise measures to reduce working hours for their workers in hot weather. When the maximum temperature reaches 104ºF / 40°C or above, outdoor operations are directly suspended, and between 99ºF / 37°C and 104ºF / 40°C, employees mustn’t work outside for more than six hours, or conduct any outside operations during the hottest three hours of the day. Facilities conducting operations in high temperature environments exceeding 95ºF / 35°C must utilize new technology and equipment to reduce hazards caused by high temperatures, and provide cold beverages and resting places with seats and ventilation/cooling equipment. Employers must ensure pregnant workers or those under the age of 18 don’t work outdoors when the temperature exceeds 95ºF / 35°C. There’s still room for improvement, however, as China could aim to reduce thresholds by also taking humidity levels into account. Moreover, non-compliance could be better identified by an increase in workplace inspections.

Thailand

Since March 2018, companies exposing their employees to occupational heat must carry out a measurement of the level of heat in accordance with the Notification Prescribing Procedures for Measuring and Analyzing Work Environment in Relation to Heat, Light, and Noise of 2018. The Notification clarifies the types of operations subject to the requirements and the duration of exposure on which the measurement must be based.

Under the Notification, employers are required to carry out a measurement of the heat, light, and noise levels at their workplace at least annually. If employers make any changes to their machinery, production process, or any other work processes that may result in a change to the level of heat, light, or noise, they must carry out the same measurement and an analysis specifically for the area where, or for employees whom, changes may affect. This measurement and analysis must be done within 90 days from the time the changes are made. The Notification specifies the measuring equipment to be used.

All employers whose operations may expose their employees to occupational extreme heat hazards are required to assess the level of heat during regular working hours and other periods in which employees may be exposed to the highest level of heat.

If employers can’t identify if the work being performed during that two-hour period is light, medium, or heavy work as prescribed under the Notification, a workload assessment must be carried out, in accordance with the Technical Manual of the US Department of Labor, Occupational Safety and Health Administration (OSHA), or an equivalent standard such as ISO 8996 on Ergonomics of the thermal environment – Determination of metabolic rate.

Indonesia

The Minister of Manpower in Indonesia recently issued Regulation No. 5 of 2018 regarding Safety and Health at Working Environment for workplaces that present a potential hazard from heat stress or workplaces with inadequate ventilation. Annex of the Regulation provides the “working climate” standard using the Wet Bulb Globe Temperature Index (WBGTI). The standard provides working time arrangements according to the employee workload and workplace temperature, divided into light, middle, heavy, and very heavy work. For example, light work under the temperature of 31°C is allowed for six to eight hours a day and heavy work under the temperature of 30.5°C is allowed for a maximum of two hours a day.

Further, the Regulation provides various measures to control exceeded threshold limits/standards, such as: eliminating heat or cold sources from the workplace; substituting working tools, material and working process that generate heat or cold sources; isolating or limiting exposure to heat/cold sources; providing ventilation system; or using other control measures according to the science and technology development.

Comparison: Emerging markets vs. developed countries

The governments of the member states of the Gulf Cooperation Council (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates) aren’t the only countries with legislation to protect workers from extreme weather events.

Non-governmental actors are also bringing attention to the plight of migrant workers repeatedly found in dire work conditions. Migrant workers are especially impacted by companies’ compliance with the midday work ban as they comprise the bulk of the construction workforce in many GCC countries. Saudi Arabia’s National Society for Human Rights (NSHR), for example, conducts initiatives aimed at monitoring the implementation of the Ministry of Labor’s midday work ban during the summer months, where there are approximately nine million migrant workers employed largely in the construction sector. The Society is just one of several organizations to criticize the lack of enforcement actions taken by the Ministry in the past. Previously, the Ministry has responded with intensified inspections and enforcement actions. As the media remains focused on the region, we can expect, and hope for, more positive changes resulting from the weight of public opinion.

Australia

Over the past few years, Australia has experienced record-breaking heat waves so hot that darker shades of red were added to the weather map. Despite the extreme weather and threat to public health, Australia is well prepared for extreme conditions and prioritizes the welfare of its workers.

The 2011 Work Health and Safety Regulation calls for close monitoring of the physical wellbeing of workers exposed to heat. Training provisions are requisite to recognize the early symptoms of heat strain, how to follow safe work procedures, and how to report problems immediately. Most importantly, Australia has very active enforcement agencies that prioritize inspections during the climate crisis.

Greece

Greece is also familiar with heat waves which could compromise human health. Companies can refer to guidance documents published yearly by the Ministry for Health, Social Insurance and Social Solidarity to help prevent heat strain for workers. These documents serve as guidance on how to assess the risk of heat stroke, training, emergency response and first aid during periods of high temperatures. They also explain how to fulfill legal requirements, such as the need to integrate controls into a company’s health and safety action plan to identify whether organizational and technical preventative measures must be taken to reduce heat strain. These controls focus on outdoor work, such as construction, and activities involving heat generation from a production process. The guidance itself isn’t compulsory but can aid employers in protecting employees from heat stroke.

France

In France, companies can consult the April 2018 assessment report of the risks induced by climate change on workers’ health issued by the National Agency for Food, Environmental and Occupational Health Safety (Agence nationale de sécurité sanitaire de l’alimentation, de l’environnement et du travail – ANSES). Research for the report began in 2013. The report highlights that, except for risks related to noise and artificial radiation, all occupational risks are and will be impacted by climate action and environmental changes.

The following three climate and environmental changes can increase occupational risks.

 1. Temperature increases

Exposure to heat directly leads to occupational risks such as dehydration and heat stroke, psycho-social risks due to tense situations, accidental risks related to impairment of awareness, chemical risks related to the inhalation of volatile substances, or modification of the risks related to biological agents like infectious diseases and pollen.

 2. Evolution of the biological and chemical environment

Environmental changes are likely to alter the distribution of some infectious disease vectors, like mosquitoes or ticks, or to foster new vectors. This evolves the risks related to biological agents, notably on people working in a natural environment or in contact with people and animals.

 3. Changes in the frequency and intensity of certain climatic hazards

Changes in the frequency and intensity of certain climatic hazards could increase accidental risks from physical and psychical tiredness.

In the report conclusion, ANSES recommends the introduction of measures, without delay, to:

• promote awareness on the health effects of climate change, through information and training
• encourage the consideration of climate change impacts in risk assessments (identification of the employees likely to be impacted, specific evaluation of each workstation, etc.)
• continue efforts to include the health effects of climate change in risk prevention measures (for example, by adapting work environments and the organization of work)

Poland

In Poland, if temperatures rise above 86ºF / 30°C employers must ensure air-conditioned rest areas, sanitary facilities — dependent on the working place and number of employees — as well as drinking water or beverages are accessible within a maximum of 75 meters from the workplace.

Polish law doesn’t provide a maximum temperature, only a minimum. However, due to harmful effects on human health, special protection is given to young workers, employees and nursing women. Young workers aged over 17, working in a microclimate of up to 26°C thermal load index, can work up to three hours a day, provided that energy expenditure standards are maintained. In addition, the employer must provide young workers with a sufficient number of suitable drinks at their workplace and a ten-minute break for every fifty minutes of work.

Further, it’s prohibited to employ young workers where the air temperature exceeds 30°C, and the humidity index is or exceeds 65 percent. In hot weather, the employer must provide all employees with drinking water or other beverages. The water source cannot be further than 75m from the work station.  Employees who are permanently or periodically in particularly arduous conditions — defined as a work environment in which certain harmful and onerous factors can occur — should be provided with other beverages in addition to water.

In summary, employers provide drinks to employees who work in a hot microclimate:

• during work related to physical effort, causing an effective energy expenditure of the organism above 1500 kcal (6280 kJ) for men and 1000 kcal (4187 kJ) for women
• at work stations in an office environment where the temperature caused by weather conditions exceeds 28°C
• when working in an open-air environment, at an ambient temperature above 25°C, characterized by a thermal load index above 25°C

Italy

A technical guidance document providing methods and equations for assessing the micro-climate comfort at workplaces was published by the National Institute for Insurance against Accidents at Work (INAIL) in 2018. This document doesn’t impose specific obligations on companies, but may be used by employers to carry out a detailed analysis of climate factors at the workplace with the aim of achieving better working conditions and protecting employees’ health.

The guidance focuses on the impact of “non-appropriate” temperatures in the workplace. To promote health and productivity, the guidance provides tools to measure and simulate the climate conditions, as well as quantify its effects.

The Italian rules on climate and temperature at the workplace are set out in Title III, Section I and Annex IV(1.9) of the Health and Safety Code, which establishes that workplace temperatures should be adequate to fit a human body’s needs, taking into account the working activities, working methods used and the physical demands placed on workers.

Further, when assessing the temperature of a workplace, employers must take into account the degree of humidity and airstreams.

United States

The US OSHA hasn’t established a federal standard addressing occupational heat exposure. However, OSHA does provide employers with information on how to prevent heat-related illnesses and measures to take if a worker shows signs of illness. Currently this information is presented alongside the General Duty Clause that requires employers to provide employees with a place of employment free from recognizable hazards causing, or likely to cause, death or serious harm. While heat waves across the US have become more common, it’s unlikely any standard will be established in the next five years. However, OSHA could be in the process of establishing a standard if current weather trends continue and more workers are exposed to heat-related illnesses and/or deaths.

California

California continues to require companies whose employees work in high temperatures to comply with the Heat Illness Prevention regulations. Under the last amendments, effective May 1, 2015, employers must implement high-heat procedures when temperatures reach 80ºF / 26°C.

High heat procedures include:

1. Training: Train all employees and supervisors about heat illness prevention
2. Water: Provide enough fresh water so that each employee can drink at least 1 quart per hour, or four 8 ounce glasses per hour (and encourage them to do so)
3. Shade: Provide access to shade and encourage employees to take a cool-down rest in the shade for at least 5 minutes
4. Planning: Develop and implement written procedures for complying with the Cal/OSHA Heat Illness Prevention Standard. Further, additional procedures must be implemented when the temperature reaches 95ºF

These procedures include observing employees for alertness, such as using a buddy system, reminding employees throughout the shift to drink water, and having pre-shift meetings to review procedures and remind employees of their right to take breaks when necessary.

As early as April 2018, excessive heat warnings have been issued for California. For each warning, OSHA publishes additional warnings and guidance to urge all employers to protect their employees. OSHA’s Heat Illness Prevention Program is aimed at keeping employees safe, and to do so, it provides a variety of information and training on its website. For example, heat prevention training materials and online tools are provided for employers, and pocket guides and fact sheets are provided for employees.

Washington State

Washington State implements the Outdoor Heat Exposure Rule from May 1 to September 30 every year. Washington’s rule is applicable based on the type of clothing employees are required to wear. For instance, the rule is applicable where the temperature is above 77°F / 25 °C for employees wearing double-layer clothes, such as coveralls, jackets, and sweatshirts, and applicable at 89°F / 31°C for employees wearing other clothing. While not as stringent as California’s Heat Illness Prevention Program, employers in Washington State must implement an outdoor heat exposure safety program, ensure a sufficient quantity of drinking water is available at all times, and provide annual employee training.

Not just health and safety, but also an environmental issue

It’s worth noting that although the impact of extreme heat on workers is one clear side effect of a warming climate, another is increased pressure on the environment. Rising temperatures mean there will be more reliance on air-conditioning and other cooling equipment, leading to an increase in the use of coolants, and an upsurge in energy use. Moreso, companies will be subject to increasing regulations and standards around energy efficiency for  buildings and electrical equipment such as air conditioners. This presents a double-edged challenge to companies who must ensure employees are kept cool while also meeting energy-efficiency requirements, including restrictions and prohibitions on greenhouse gases.

It’s clear that regulators and policy-makers are taking the threat of a warming climate seriously. However, a consistent global approach to protect the rights of workers is still lacking, notably in the construction industry. While it’s impossible to eliminate all climate-related illnesses completely, the risk of developing heat stress can be mitigated. Educating both employers and workers is vital for the correct implementation of rules and policies already in place, and in countries where requirements are insufficient, further action is necessary.

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