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  6:10 pm
Commenter: Ronda McCarthy, MD, MPH, FACOEM

Research in support of Virginia's Heat Stress Standard

My name is Ronda McCarthy, MD, MPH. As an occupational medicine physician,  I have treated too many workers for heat-related illnesses, which are completely preventable, and  I would like to share my professional experience in support of a Virginia Heat Stress Standard to protect workers against excessive heat.

 I believe a Heat Stress Standard will protect the health and lives of countless workers. Moreover, employers will benefit from decreased costs from injuries and illness and will experience increased productivity from their workers.

I worked as the medical director of a employee health clinic, where I treated municipal workers, many with outdoor heat exposure.  Ironically, since the municipality did not fall under OSHA, I was allowed to implement a heat stress awareness program for their outdoor workers.

I used information from OSHA’s Technical Manual and NIOSH’s Criteria for a Standard: Occupational Exposure to Heat and Hot Environments to create their Heat Stress Awareness Program (HSAP). This program included supervisor and worker training, first aid and emergency response procedures, acclimatization plan and medical monitoring to determine fitness for duty prior to work in heat. 

I worked with two faculty members from University of Pennsylvania Health System, Dr. Judith Green-McKenzie, and Dr. Fran Shofer to retrospectively analyzed the data collected from the Heat Stress Awareness Program. The data was analyzed in support of NIOSH’s newly released 2016 revisions. The study data revealed two salient points relevant recommendations for a Heat Stress Standard: workers’ compensation costs went down by 50% per heat-related illness, and the total number of heat-related cases decreased after implementation of the Heat Stress Awareness Program.

There are two possible reasons for this reduction in workers’ compensation cost. Both an increased awareness of the signs and symptoms of heat-related illness, as well as an understanding of when to seek medical attention may have allowed for earlier intervention, leading to lower workers’ compensation costs.  Decreased costs reflect the reality of less severe health effects from this harmful and potentially fatal illness. Over the course of the Heat Stress Awareness Program, the frequency of heat-related illnesses decreased per year, and by the last two years, there were no reported heat-related illnesses during the hot season for the exposed municipal workers. Please refer to Figure 1.

This heat-related illness prevention program, consisting of simple and inexpensive measures, appears effective and potentially lifesaving.

In light of this research, and as an occupational medicine physician with over 20 years of experience supervising workers exposed to hot environments, it is my expert opinion that enacting a Virginia Heat Stress Standard that includes employee and supervisor training, acclimatization program,  emergency response procedures, and medical monitoring will protect the lives and health of workers and benefit employers by increasing worker productivity and decreasing accident, injury and illness costs.


Reference: McCarthy R, Shofer F, Green-McKenzie J, Outcomes of a Heat Stress Awareness Program on Heat-Related Illness in Outdoor Municipal Workers. Journal of Occupational and Environmental Medicine: 61(9):724-728, September 2019  doi: 10.1097/JOM.0000000000001639






















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