By Nicole Randall, Director of Marketing and External Affairs, International Safety Equipment Association (ISEA)
Heat has always been an on-the-job fact of life for firefighters. But both climate data and occupational health trends are sounding alarm bells for heat’s impact on workers of all kinds, especially those laboring outdoors.
The National Oceanic and Atmospheric Administration (NOAA) reports that the 10 warmest years on record have occurred since 2005. And while a new temperature record was set on average every 13.5 years from 1900 to 1980, a new record was set every 3 years from 1981–2019.
Work-related deaths due to environmental heat exposure have also been trending higher, according to data from the U.S. Bureau of Labor Statistics (BLS). National Public Radio and Columbia Journalism Investigations analyzed BLS data going back three decades and found that “the three-year average of worker heat deaths has doubled since the early 1990s.”
While the National Fire Protection Association’s (NFPA) stats on firefighter deaths by cause and nature of injury attribute only 2% to “exposure to heat” or “heat stroke,” respectively, heat stress could have played a role in fatalities counted under other causes, such as “overexertion/stress/medical” and “sudden cardiac death.” (The International Safety Equipment Association (ISEA) is officially represented on seven NFPA technical committees.)
The International Association of Fire Fighters (IAFF) has emphasized that heat stress and heat stroke “can kill and cause debilitating injuries, as well as reduce a fire fighter’s physiological performance.” The IAFF added that heat also affects firefighters’ decision-making abilities.
Increasing Federal Efforts on Heat Protection
The U.S. Fire Administration (USFA) devoted part of its June 2021 Firefighter Safety Stand-Down to mitigating heat stress. “Exposure to extreme heat situations usually occurs in limited, short doses for most firefighters but the effects of high heat on personnel are cumulative,” the USFA explained on its website. “Extreme heat from environmental conditions adds significantly to the risk of heat-related health emergencies.”
In September 2021, President Biden expressed his administration’s commitment to tackling workplace heat risks. “Rising temperatures pose an imminent threat to millions of American workers exposed to the elements,” he said in a statement. In tandem with the President’s statement, the White House issued a fact sheet on federal efforts to protect workers and communities from extreme heat.
Despite the President’s concern, however, the people who would typically write the regulations at the Occupational Safety and Health Administration (OSHA), had to turn their attention to developing COVID-19-related rules, according to reporting by Bloomberg Law.
OSHA already had a Heat Illness Prevention Campaign dating back to 2011, offering education for employers and workers about the dangers of workplace heat. Its webpage links to training tools, videos, and infographics, as well as the agency’s latest regulatory moves on the subject.
OSHA also formed a Heat Injury and Illness Prevention Work Group within its National Advisory Committee on Occupational Safety and Health (NACOSH). The announcement of the Work Group’s formation didn’t indicate a timeframe for its efforts, but explained that it “will evaluate OSHA’s heat illness and prevention guidance materials, develop recommendations for guidance materials, evaluate stakeholder input, and develop recommendations on potential elements of a proposed heat injury and illness prevention standard.”
Nonetheless, OSHA did issue an advance notice of proposed rulemaking (ANPRM) on October 27, 2021, “to protect indoor and outdoor workers from hazardous heat.” The ANPRM invited input and “additional information about the extent and nature of hazardous heat in the workplace and the nature and effectiveness of interventions and controls used to prevent heat-related injury and illness.” In December, it extended the deadline of that comment period to January 26, 2022.
As often happens, another part of the government had already done some work that OSHA — and fire service professionals — might find useful. In 2016, the National Institute for Occupational Safety and Health (NIOSH) within the Centers for Disease Control & Prevention (CDC) published “Criteria for a Recommended Standard: Occupational Exposure to Heat and Hot Environments.”
There’s more in the nearly 200-page document than its title implies. NIOSH provides a comprehensive deep dive into heat stress. For example, it noted: “Re-education is needed in the workplace, especially about [heat stroke] symptoms. Many workers have incorrectly been taught that as long as they were still sweating they were not in danger of heatstroke.”
Safety Equipment Industry Responds
ISEA, which has become increasingly concerned about workplace heat risks, sent a written response in January 2021 to OSHA’s request for information about current and best practices for protecting workers in a variety of settings from heat exposure.
ISEA’s letter outlined a number of best practices, including:
• Engineering controls.
• Administrative controls.
• Access to water, rest, and shade.
• Cooling personal protective equipment (PPE).
ISEA also asked that OSHA update its record-keeping requirements to include heat stress. A copy of the letter to OSHA is posted on ISEA’s website.
The American Society of Safety Professionals’ ANSI/ASSP A10 Committee has been working on a proposed heat stress management standard (ASSP A10.50), to provide guidance on how to create and sustain a program to keep workers safe from the exposures of hazardous heat.
ISEA has an active committee that is planning outreach activities to coincide with OSHA’s heat-stress prevention campaign to raise awareness in the workplace about the dangers of hazardous heat. ISEA’s committee is also considering organizing a day of Capitol Hill visits to raise visibility in Congress of OSHA’s heat-stress management activities.
Because firefighters’ protective gear can itself create a microclimate between the body and the gear that might trap heat within the suit, a number of ISEA-member companies provide cooling vests for firefighters to wear under their turnout gear.
Nine ISEA-member companies provide a variety of heat stress solutions, including Ansell Healthcare, Bullard, Draëger, Encon, Ergodyne, Honeywell, Protective Industrial Products (PIP), Magid Glove, OccuNomix International, National Safety Apparel, Lakeland Industries, and Radians.
Nicole Randall is the director of marketing and external affairs for ISEA. Headquartered in Arlington, Virginia, the International Safety Equipment Association (ISEA) is the trade association in the U.S. for personal protective equipment and technologies. Its member companies are world leaders in the design, manufacture, testing, and distribution of protective clothing and equipment used in factories, construction sites, hospitals and clinics, farms, schools, laboratories, emergency response, and in the home. Since 1933, ISEA has set the standard for the personal protective equipment industry, supporting member companies united in the goal of protecting the health and safety of people worldwide.