Summer OSHA Topics

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Summer is here. It is a time for many of us to vacation or slow down our hectic lives. For OSHA, though, it is still business as usual. Enforcement remains a priority for the agency. This summer, OSHA is focusing on:

Heat Illness

As the midpoint of summer passes, it is still important to be aware of heat stress and its impacts on workers. Since 2008, there have been several heat related fatalities throughout the country, including some in southern Wisconsin and northeastern Illinois. As a result, OSHA has implemented a nationwide Heat Illness Prevention Campaign.

Heat stress results when the body cannot naturally cool itself. As a consequence, a variety of heat illnesses can occur, ranging from minor heat rash to serious—and sometimes fatal—heat stroke. Some people are more susceptible to heat illness than others. Persons who work outside and/or perform strenuous work activities in heavy clothing are most at risk for developing a heat-related illness. The protection of these more susceptible workers is a priority for OSHA.

OSHA's heat awareness program is summarized by "Water, Rest, Shade." Specifically, if workers are in an environment that could produce heat stress, OSHA recommends that they:

  • Drink water every 15 minutes, even if not thirsty;
  • Rest in shade to cool down;
  • Wear a hat and light colored clothing;
  • Learn the signs of heat illness and what to do in a heat-related emergency;
  • Keep an eye on fellow workers (in stressful conditions a buddy system is recommended); and;
  • Acclimate to conditions.

Another recommendation is to use sunscreen protection with a sun protection filter (SPF) of 30 or more—as appropriate for the conditions of the work environment (i.e., sun exposure). For more information, see OSHA's website under the heading "Heat Illness Prevention Campaign."

Chemical Hazard Communication Standard (HCS)

As discussed in previous e-alerts (July 2012 and December 2012), OSHA is aligning the HCS with the Globally Harmonized System of Classification and Labeling (GHS). By December 1, 2013, employees must be trained on the new label elements and safety data sheet format required under the GHS. The goal of the GHS is to establish a worldwide system for uniform management of chemicals and their associated hazards.

In June 2013, OSHA signed a Memorandum of Understanding (MOU) with its counterpart in Canada: The Healthy Environments and Consumer Safety Branch of the Department of Health of Canada (HECS). The MOU cements the GHS-related working relationship between the U.S. and Canada. Under the agreement, OSHA and the HECS will establish a working group to reduce barriers between the national systems responsible for occupational safety and health involving workplace chemicals. The agencies will collaborate to reach common positions on the GHS and proposed updates to the systems. Given the close import/export relationship between the United States and Canada, these collaborative efforts will enhance business between the two countries.


Isocyanates are chemical compounds containing the isocyanate group (-NCO). Isocyanates in the form of raw materials are incorporated into numerous polyurethane products, such as foams, paints, spandex fibers, insulation materials, car seats, mattresses, under carpet padding, packaging materials, polyurethane rubber, adhesives and fiberglass. Many industries use polyurethane products (and isocyanates), including automotive, medical care, printing, plastics, mining, textiles, paints, food, building construction and electronics. Thus, isocyanates are widely used and are found in many of the products we use.

The health effects of isocyanates include irritation of skin and mucous membranes, difficulty breathing and chest tightness. OSHA and similar regulators have developed occupational exposure limits for eight isocyanate components. One isocyanate, 2,4-toluene diisocyanate, has been classified as reasonably anticipated to be a human carcinogen.

OSHA and its counterpart agencies also have prepared several reference documents addressing isocyanates. On June 20, 2013, OSHA released a new Instruction for the Field Operations Manual (Instruction Manual) regarding isocyanates. The Instruction Manual describes policies and procedures for implementing a National Emphasis Program on Occupational Exposure to Isocyanates to identify and reduce/eliminate the incidences of adverse health effects associated with occupational exposure to isocyanates. OSHA's Instruction Manual sets forth a system that targets multiple industries and focuses on evaluating inhalation, dermal and other routes of occupational exposure to isocyanates. If you have employees who work with polyurethane (and isocyanates), you should consult the Instruction Manual.

Patient Handling

OSHA continues to track injuries and illnesses in the health care industry. OSHA is concerned about hazards likely to cause musculoskeletal disorders among health care workers responsible for patient care, most commonly sprains, strains, soft tissue and back injuries. Nurses, nursing aides, attendants, orderlies and home health aides sustain most of these injuries. To address this concern, OSHA prepared a safe patient handling guide that includes developing and implementing a safe patient handling program.

As the U.S. population ages, there will be more patients, and more health care workers will be employed to help those patients. It will be imperative, from patient and provider points of view as well as in the interest of cost management, to implement a safe patient care program and adhere to it.

For more information on the OSHA topics discussed above, please contact your Reinhart attorney or one of the authors listed below.


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