Construction workers wearing orange vests and hardhats.

The Arizona Division of Occupational Safety and Health (ADOSH) has unveiled a new comprehensive state emphasis program (SEP) aimed at mitigating heat-related illnesses and injuries at both indoor and outdoor workplaces.

Quick Hits

  • Arizona’s new state emphasis program is intended to mitigate heat-related illness and injuries by encouraging early intervention by employers.
  • The state emphasis program calls for new targeted inspections and outreach efforts, with a focus on industries known to have heat-related hazard incidents.

On July 17, 2023, ADOSH published the new “State Emphasis Program – Outdoor and Indoor Heat-Related Hazards,” setting forth policies and procedures to ensure that employees are protected from heat-related hazards, which may include serious illnesses, injuries, or death. The SEP applies to high-hazard industries or work activities where a heat hazard exists, such as working outdoors during a heat wave, as announced by the National Weather Service (NWS), or working indoors near a radiant heat source, such as in iron and steel mills.

The program comes amid growing concerns regarding heat-related injuries and is similar to the national emphasis program (NEP) on indoor and outdoor heat-related hazards issued by the federal Occupational Safety and Health Administration (OSHA) in April 2022. The NEP will be in effect until 2025.

Under Arizona’s SEP, ADOSH will conduct targeted inspections and outreach efforts with a focus on ensuring that workers are not exposed to hazardous heat conditions without adequate protection, including access to water, rest, shade, training, and acclimatization procedures. Key points of the SEP include:

  • Changes to Current Inspections. Compliance safety and health officers (CSHOs) who are investigating a workplace for “any purpose” will now report or open a heat-related inspection for any “hazardous heat conditions observed.”
  • New Programmed Inspections. Programmed inspections in industries with historically high rates of heat-related incidents and illnesses will now occur on any day that the NWS has announced a heat warning or advisory for the local area. These programmed inspections will be targeted at more than fifty specific indoor and outdoor industry sectors, including construction, restaurants, auto dealerships, warehousing and storage, manufacturing, mining, couriers, and express delivery services, among others.
  • Data Collection. The SEP directs CSHOs to ask specific questions about the employer’s heat illness and injury program during all heat-related inspections, including whether a written program existed, how the employer monitored the ambient temperature, whether unlimited cool water was readily accessible, whether a buddy system was in place on hot days, and whether administrative controls on heat exposure were used, such as earlier start times and employee/job rotation. The SEP also directs CHSOs to code all activities (inspections, complaints, and referrals) and visits conducted under the SEP with a new code, “HEATEP.” ADOSH has stated that this will help it “identify and consider future steps and policies” the agency may want to pursue to address heat-related hazards and injuries.
  • Outreach. In conjunction with new inspections, ADOSH will conduct outreach activities with regard to heat-related illnesses, including sharing information and compliance assistance tools and resources. This information may include webinars, presentations, and written materials distributed to employers, employee groups, and unions at conferences, and involve developing resources with various stakeholders and high-hazard industry groups. Further, ADOSH has stated that it will create a poster for employers to post in their workplaces, which will be available for download on ADOSH’s heat stress resource page.

Employers may wish to review the SEP’s recommendations and resources on early interventions for new and existing employees, including water, rest, shade, training, and acclimatization procedures. The SEP emphasizes it is essential for employers to train new or returning workers on heat-related hazards (including heat stress), gradually increase their workloads, ensure more frequent breaks and access to cooling areas as they acclimatize to ambient conditions, and monitor them for signs of heat illness.

Ogletree Deakins’ Workplace Safety and Health Practice Group will continue to monitor developments and will provide updates on the Arizona and Workplace Safety and Health blogs.

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