SC&RA/CISC Submit Comments to OSHA Regarding Potential Heat Injury & Illness Prevention Standard

(January 11,2024) - SC&RA, through the Construction Industry Safety Coalition (CISC), has submitted additional comments to the Occupational Safety and Health Administration regarding a potential standard for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. CISC members strongly believe that a regulatory approach – if adopted – must be a flexible performance-based standard. The construction environment is inherently fluid and the CISC has significant concerns with any regulatory approach that imposes prescriptive, complicated requirements on construction industry employers. Specifically, the CISC cited the following four overarching concerns and provided supporting details regarding this potential standard: 

• If OSHA moves forward with efforts to regulate heat injury and illness, its standard should be flexible, performance-based, and emphasize training.
• The proposed recordkeeping and written plan requirements are unnecessary and impose burdensome compliance obligations on construction employers.
• Personal risk factors are outside of an employer’s control but significantly impact how an employee will be affected by extreme heat, and construction employers should not be required to collect information about such risk factors.
• A construction worksite is not purely an “indoor” or “outdoor” work environment.

The CISC is comprised of 30 trade associations, including SC&RA, representing virtually every aspect of the construction industry including small, medium, and large contractors, general contractors, subcontractors, and union contractors alike. To read the full comment and detailed response, click here. For more information on this issue, contact Senior V.P., Crane & Rigging Beth O’Quinn.