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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6/9/21  11:26 pm
Commenter: Robert V Poignant, Jr.

State neeeds occupational health heat protections for workers in absence of federal rules

Just two weeks ago, a met a former roofer who is now in the tree removal business because of the greater hazards he experienced in his former job as a roofer.

The extreme heat - even on merely "warm" days like 75 degrees Fahrenheit - is hazard to roofers in several ways:

1 .Loss of water (dehydration) from sweating.

2 .Heat induced loss of concentration and balance causing fall injury/death from an elevated structure that may have surface temperatures  in excess of 135 degrees and

3. Burn hazards when removing old roofing.

The following suggestions apply to all those working in high temperature/humidity occupations and would include persons putting down asphalt, foundry workers and drivers of delivery trucks.

Rules should require:

1. Employer monitoring of workers for heat stress;

2 .Employer provided liquids having necessary salts tore-hydrate workers based upon monitoring;

3A. Limit working hours to periods when the heat index (which considers BOTH temperature and humidity) on the job site is below a medically hazardous limit.

3B. Hazardous/dangerous heat-humidity charts (heat  indices) are readily available and should be posted on the job site along with how to reach the regulatory authority and the nearest medical facility.

4. Where feasible (e.g.,cabs of delivery truck drivers) rules should require air conditioning;

5. When not feasible, (foundry work, asphalt laying etc.) requiring a cooled job site enclosure (portable if outdoors) and provide cooled liquids that would replace salts and liquids of he worker.

6. The worker's physician should provide, based upon the heat conditions of the job and medical condition (any heart, diabetes?) of the worker , a certificate to allow the worker to  work on that position.

This is by no means a comprehensive listing, but a start.

CommentID: 99076