The United Steelworkers (USW) strongly supports Virginia’s efforts to establish a comprehensive Heat Illness Prevention Standard protecting workers from both indoor and outdoor heat hazards.

Heat exposure is a serious workplace hazard that can cause illness, injury, and death. USW members work in industries such as paper, steel, chemicals, manufacturing, rubber, plastics, energy, and other sectors where workers can face extreme temperatures, strenuous work, and heat generated by industrial processes.

We urge Virginia to develop a strong standard that prioritizes prevention and gives workers and their representatives a meaningful voice in protecting themselves and their coworkers.

The standard must:

• Require workers and their representatives to have meaningful participation in developing and reviewing heat illness prevention plans.
• Protect workers and their representatives from retaliation when they report heat hazards or exercise their safety rights.
• Require training and information in a language and at a literacy level workers can understand.
• Require training to utilize an instructor/trainer for employees to interact with who has the knowledge, skills, and abilities to teach the subject matter being presented as it relates to the workplace or site that the training will address. The training must also provide an opportunity for interactive questions and answers with the instructor/trainer as far too many workplaces rely on computer-based training.
• Training must cover employee rights and clarify that the employer shall not discharge or in any way discriminate against an employee or their representative for protected activity, including: exercising rights under the standard for themselves or others, requesting information, raising a concern or suggestion, reporting an injury/illness, requesting medical attention, taking heat-related breaks, and stopping a heat-related job/task/process that is unsafe or unhealthy or as they experience signs of heat-related illness.
• Include Stop Work Authority (SWA), allowing workers to stop unsafe work when heat exposure presents a serious hazard.
• Address both indoor and outdoor heat exposure, including heat generated by industrial processes, equipment, maintenance, upset conditions, and outages.
• Require employers to use the hierarchy of controls to eliminate/reduce heat hazards at their source.
• Provide at no cost, adequate water, electrolytes, cool-down areas, paid rest and recovery periods, acclimatization, and emergency procedures.

Workers should not have to become sick before an employer takes action. A heat illness prevention standard must focus on identifying, eliminating, and controlling hazards before they result in serious injury, illness, or death

Virginia has an opportunity to establish meaningful protections for working people. USW encourages the Regulatory Advisory Panel and the Safety and Health Codes Board to ensure that the voices of workers and their representatives are central to the development of this standard.

Thank you for giving the USW an opportunity to comment.