Virginia Regulatory Town Hall
Department of Labor and Industry
Safety and Health Codes Board
Heat Illness Prevention Standard [16 VAC 25 ‑ 210]
Action NOIRA on Heat Illness Prevention
Comment Period Ended on 6/9/2021
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6/8/21  1:38 pm
Commenter: Cora Roelofs, University of Massachusetts Lowell

Heat Stress Standard

It is essential that Virginia adopt a heat illness protection standard to save the lives of diverse workers in the Commonwealth. My research has shown that in the absence of a standard, employers maybe unaware or insufficiently concerned about the risk to their employees from the heat, resulting in completely preventable deaths. My article: "Without Warning: Worker Deaths from Heat 2014-2016" ( analyzed OSHA records to determine salient features of these deaths in order to identify critical preventive action. I found that deaths occurred at lower temperatures than would be predicted, to younger workers, and that several deaths took place during training exercises or on the first day of work. These deaths included emergency responders and other public servants. "Acclimatization" is more than a physiological response -- it is also a behavioral adaptation that includes knowing that it is ok to express to an employer that the heat is getting to you without fearing reprisal, having co-workers who know and care about your well-being, and knowing where water and shade are. This type of "acclimatization" comes from employer commitment to protecting workers from heat and their awareness that their employees may have different underlying conditions, such as chronic disease, overweight, lack of sleep, and use of prescription medications and/or energy drinks that make them more vulnerable to heat. Many of these important factors are also described in NIOSH's Criteria for a Recommended Standard: Occupational Exposure to Hot Environments ( While it may or may not be feasible for Virginia to adopt NIOSH's Heat-Rest algorithm, and may instead model your standard after California's  "action temperature" model (, employers can undertake feasible and  effective solutions that can have dramatic life-saving impacts. Thank you for your attention to this critical issue.

Cora Roelofs, ScD



CommentID: 98977