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  8:48 pm
Commenter: Susie Cambria

In support of the development of strong heat stress standards to protect workers

I am writing to urge you to develop strong heat stress standards to protect workers who work in excessively hot conditions.


As a resident of the Northern Neck, I am concerned about the health and well-being of workers who, for a variety of reasons, often work in a number of high-risk fields including agriculture, construction, landscaping, golf course maintenance and support, and other outdoor work, such as at sawmills and using heavy equipment.


In agriculture in particular, time matters and may lead individual workers, a collective of workers, and/or management to push workers, limit breaks and self-care, and otherwise ignore the detrimental and often deadly effects of heat.


As hot as it has been over the years, climate change will likely make the temperature even more challenging in the future. The time is now for the Commonwealth to take proactive and aggressive measures to protect the safety and well-being of workers. As the board detailed in the Notice of Intended Regulatory Action (NOIRA) Agency Background Document, “Neither the Virginia Occupational Safety and Health (VOSH) program nor OSHA (Occupational Safety and Health Administration) has a comprehensive heat illness prevention regulation.” (p. 2)


In the background document, the board lists items for possible inclusion. All are appropriate. I would, however, encourage the board to:

  • Modify the notion to “Written heat illness prevention plan” to include language accessibility, meaning that the document must be translated into languages in which workers are fluent. (p. 5)
  • Strengthen the notion “Employee and supervisory training on heat illness hazards and preventative measures in a language the employee and supervisor understands” to require trainings take place in languages in which workers/supervisors are fluent. (p. 6)
  • Incorporate a “feels like” provision rather than something like “High heat procedures when the temperature equals or exceeds 95°F” as California does. (p. 10) [1]
  • Include a provision for working in direct sunlight. The National Weather Service writes, for example, “IMPORTANT: Heat index values were devised for shady, light wind conditions. Exposure to full sunshine can increase values by up to 15 degrees! Also, strong winds, particularly with very hot, dry air, can be extremely hazardous.” (


Again, I urge you to do with heat stress standards what you did with COVID-19 regs. I look forward to participating in the process as it moves forward.



[1]  "'It's not the heat, it's the humidity'. That's a partly valid phrase you may have heard in the summer, but it's actually both. The heat index, also known as the apparent temperature, is what the temperature feels like to the human body when relative humidity is combined with the air temperature. This has important considerations for the human body's comfort. When the body gets too hot, it begins to perspire or sweat to cool itself off. If the perspiration is not able to evaporate, the body cannot regulate its temperature. Evaporation is a cooling process. When perspiration is evaporated off the body, it effectively reduces the body's temperature. When the atmospheric moisture content (i.e. relative humidity) is high, the rate of evaporation from the body decreases. In other words, the human body feels warmer in humid conditions. The opposite is true when the relative humidity decreases because the rate of perspiration increases. The body actually feels cooler in arid conditions. There is direct relationship between the air temperature and relative humidity and the heat index, meaning as the air temperature and relative humidity increase (decrease), the heat index increases (decreases)."(

CommentID: 99057