The 2022 FIFA World Cup in Qatar kicked off on November 20, 2022, in a special late fall edition of the quadrennial tournament—highlighting the dangers of high-heat work environments. Typically held in June and July, the 2022 World Cup is being held in November and December this time to avoid the high summer temperatures in the Persian Gulf country—which average more than 100°F during the summer months—that can make it dangerous or difficult for players. Even before the games started, there were reports of workers who constructed the stadiums and other infrastructure to host the event who died or suffered serious injuries related to working in the extreme heat of Qatar.
Beyond the Middle East, protecting workers from heat-related injuries is a growing issue for employers due to rising global temperatures. In the United States, the Biden administration has made addressing heat-related injuries in the workplace a priority. In furtherance of this goal, the Occupational Safety and Health Administration (OSHA) issued an advanced notice of proposed rulemaking in October 2021 regarding a future standard for employers for preventing heat-related injuries. Further, in April 2022, OSHA issued a new National Emphasis Program (NEP) for indoor and outdoor heat-related hazards that will be in effect for three years.
Addressing Heat Illness
Heat-related illness, such as heat exhaustion or heat stroke, can occur when a person’s body is unable to cool itself, which it usually does through sweating. When the body’s temperature rises too fast, it can cause damage to the brain and other vital organs. Warning signs include excessive sweating, dizziness, headaches, and passing out.
OSHA’s NEP applies when employees are exposed to outdoor heat at or above 80°F with the humidity at or above 40 percent. Under the NEP, OSHA will target high-risk workplaces for inspection.
Inspections will focus on whether employers:
- provide cool drinking water;
- have a written heat illness and injury plan;
- train employees on signs of heat illness and first aid;
- monitor temperatures and work exertion;
- have scheduled hydration breaks and access to shaded areas;
- allow time for workers to acclimate to hotter work temperatures;
- rotate schedules to limit heat exposures; and
- use a “buddy” system on hot days.
Employers, particularly those with agricultural or construction workers outside—especially those located traditionally warmer locations—may want to review their heat illness and injury policies. Employers may further want to consider working conditions for some with employees who have circumstances or certain health conditions that may carry additional risks for heat illness, such as pregnancy, heart disease, and obesity.
Employers facing these issues may be interested in heat-related hazard policy templates to assist them in complying with heat-related safety initiatives. Ogletree Deakins will continue to monitor and report on developments with respect to OSHA’s national emphasis program on indoor and outdoor heat-related hazards and will post updates on the firm’s Workplace Safety and Health blog. Important information for employers is also available via the firm’s webinar and podcast programs.