Extreme heat is growing in intensity worldwide, including in Virginia, as a consequence of climatic changes.  Workplace heat exposure is one of the most significant threats to workers' health across professions that include, but are not limited to transportation, agriculture, construction, education, and more. The lack of an existing heat standard leaves a regulatory gap that compounds the risk of working in extreme heat. The Heat Illness Prevention Standard can help address this gap with a more coherent and effective framework to protect workers. 

A growing body of evidence from global governance organizations like the International Labor Organization, World Health Organization, and World Meteorological Association emphasize the need for regulatory frameworks to offer more specific and effective legal protections to address this need. Preventative measures are relatively well known and can be articulated into relatively clear and enforceable legal requirements. 

The DOLI should consult a recent report titled, "Climate change and Workers’ Health" published by the European Trade Union Institute that advances a series of recommendations that governments across the world may consider. This includes a review of commonly used assessments like Wet Bulb Globe Temperature (WBGT), Universal Thermal Climate Index (UTCI), and Heat Index. In their estimation, workplaces should be governed by a Worker Heat Stress (WHS) indicator of some form, like the WBGT, and that this indicator include varying safety thresholds based on the intensity of work (p. 31). To my mind, these should also be developed in consultation with workers in the positions to whom the heat standard is concerned. Other basic workplace heat stress protections from the report include things like:

• Hydration strategies and sufficient sanitation facilities, especially for female workers.
• Rest breaks and modified work schedules to avoid exposure to excessive heat. Workers should also be empowered to self-pace, with some sort of legal provision available to make the ability to self-pace a right for workers.
• The provision of PPE from employers to workers to protect workers from heat stress
• Heat acclimatization measures for workers, including the provision of cool, shaded, and ventilated spaces
• Education and awareness on heat stress and related illness
• Identification of and targeted strategies for worker groups at high risk 
• As I have suggested, participatory risk assessment of excessive heat
• Regular medical check-ups and health monitoring. 

I urge the state of Virginia to consider these elements as metrics and strategies to evaluate heat stress and better safeguard the lives and livelihoods of workers in Virginia and, by extension, the communities in which they work. With the absence of federal regulations on this issue beyond the General Duty Clause of the Occupational Safety and Health Act of 1970, Virginia can lead the way in making workplaces safer and more secure for its residents.