MEETING RECORD
Tuesday January 25, 2000
2100 Katella Avenue, Anaheim, California
Attendees
Sherry Baron, California Dept. of Health Services, Oakland
Selma Benjamin, AFSCME (Retired), Santa Monica
Marianne Brown, UCLA Labor Occupational Safety & Health Program,
Los Angeles
Larry Callahan, Owens Illinois, Inc., Tracy, CA
J. Felix De La Torre, California Rural Legal Assistance Foundation,
Sacramento
Steven Dornbusch, Hotel Employees and Restaurant Employees, Local 681,
Anaheim
Marcia Dunham, Pacific Gas & Electric Company, San Francisco
Hamilton Fairburn, Organization Resources Counselors, Fountain Hills,
AZ
Dennis Gibbons, California Dept. of Pesticide Regulation, Sacramento
Ross Grayson, University of California, Riverside
Jay Heaney, Naval Health Research Center, San Diego
Don Holler, IBEW Local 47, Diamond Bar, CA
Keven Lancaster, William L. Vee Law Offices, San Francisco
Galen McCray, California Dept. of Forestry and Fire Protection, Sacramento
Dan Napier, DNA Industrial Hygiene, Lawndale, CA
Prem Notani-Sharma, Los Angeles County Environmental Health and Safety
Kevin Thompson, Cal/OSHA Reporter, Petaluma
John Vocke, Pacific Gas & Electric Company, San Francisco
Richard Warner, Southern California Edison, Westminster, CA
Charles Wheeler, CalTrans, Sacramento
Mike Wurm, Quest Technologies, Oconomowoc, WI
Otto Zahn, Computer Sciences Company, Edwards Air Force Base, CA
Attendees from the Division of Occupational Safety and Health (DOSH)
Bob Barish, San Francisco
Mike Doering, San Diego
William Estakhri, Sacramento
William Krycia, Sacramento
Bob Nakamura, San Francisco
Jerry Neisler, Anaheim
Joyce Simonowitz, Los Angeles
Bruce Wallace, San Francisco
Minutes
Bob Barish welcomed those attending the meeting and asked those who had not attended the first meeting of the committee on December 9, 1999 to introduce themselves. Bob noted that minutes of the first meeting, which had been mailed out to those who attended, were also available at the back of the room.
Bob Barish briefly reviewed the meeting on December 9, 1999. He recalled that the morning session of that meeting consisted primarily of an overview presentation on the subject of heat stress by Dr. Francis-Dukes Dobos, an expert in the field currently affiliated with the University of South Florida and retired from NIOSH where, among other positions, he had been the chief of the Physiology and Ergonomics Branch from 1972 to 1980. The afternoon discussion on December 9 focused on a review of several recent heat stress fatalities investigated by DOSH, the importance of worker and supervisor training in heat stress prevention, and some difficulties that could be faced at non-fixed work sites with implementation of some aspects of a heat stress control program.
Bob Barish indicated that he envisioned the meeting on January 25 discussing major elements likely to be included in a regulatory proposal for a heat stress standard such as provision for employee acclimatization to heat, maintenance of hydration, and possible threshold levels of environmental conditions that would activate coverage under the standard. Bob indicated that the tentative plan of the Division was to use the information gathered in this meeting to develop a proposal to be presented for discussion at the next meeting of the committee.
Background of the petition for a heat stress standard
Before starting the open discussion of heat stress issues, Bob Barish asked Selma Benjamin to address the meeting. Ms. Benjamin, originated the petition to the Cal/OSHA Standards Board for consideration of a standard on heat stress which led to the formation of this advisory committee. Ms. Benjamin explained that at the time the petition was submitted in August 1984, she worked in the Los Angeles Public Library system. Ms. Benjamin noted that after World War II with a significant increase in population in the area, many small libraries were built in Los Angeles but often lacked air conditioning. She also said that at the time she filed the petition, some areas of the central library were without air conditioning and that temperatures in these areas, for example the shipping area, sometimes exceeded 100 oF.
Ms. Benjamin reported that there were a number of cases of heat exhaustion among library workers on days when temperatures exceeded 90 oF. She recalled two cases that resulted in temporary closure of branch libraries. Ms. Benjamin noted that with attention to the problem, particularly increased installation of air-conditioning and procedures for library closure in the event of air-conditioning system breakdowns, she believed that the heat stress problem was greatly improved in the Los Angeles Public Library system. She also noted however that 20 or so other Southern California union locals signed the petition, and she believed that many of those unions still had workers facing the hazard of heat stress.
Marianne Brown Director of the UCLA LOSH program, suggested that the library situation described by Selma Benjamin appears to have been a success story in the sense that the employer did respond to employee injuries and concerns. She noted that while some employers such as Southern California Edison may address the heat stress hazard now even without a standard in place, she suggested that many employers do not currently address the problem adequately, or at all.
Bob Barish asked the group why they thought most of the heat stress fatalities investigated by DOSH had occurred, at least in recent years, in non-fixed work situations such as agriculture and construction.
Fixed versus remote locations
Larry Callahan with Owens Illinois, Inc. a glass manufacturing company, a traditional hot industry, thought that serious incidents were generally less frequently observed in fixed location situations because it was easier to provide adequate first aid quickly, there was more regular observation of workers for potential symptoms of heat illness, and greater potential for providing effective preventive measures such as adequate quantities of cool drinking water and cooled break areas.
Mike Doering, industrial hygienist in the DOSH San Diego District Office, noted that the five or so heat stress fatalities he had investigated were all in relatively remote locations such as an agricultural field and a wildlands fire fighting situation.
Bob Barish asked if for remote work site situations there might be a need for different provisions than for sites where aid was readily available and prevention measures were more easily implemented and managed.
Office situations and malfunctioning air-conditioning systems
But Dr. Prem Notani-Sharma, Chief of Environmental Health and Safety Programs for Los Angeles County, noted at the other end of the spectrum that her office often receives complaints from workers and others when air-conditioning systems break down on hot days. She thought that a heat stress standard should provide direction on how to address such situations.
Bob Barish asked if these complaints were related to potential heat illness or more to discomfort. Dr. Notani-Sharma said that some appeared to be real illness, which some in the group suggested could be feasible where manual work was being done, and presuming the workers were not acclimatized. Jay Heaney, a work physiologist with the U.S. Naval Health Research Center in San Diego, said that discomfort could lead to illness or at least symptoms, for example that extreme discomfort could lead to hyperventilation.
Bob Barish said that the Industrial Welfare Commission orders for most or all industries included provision for prevention of worker discomfort from excessive temperatures in the workplace, though the orders did not specify maximum temperatures not to be exceeded.
Bruce Wallace, industrial hygienist with the DOSH Research & Standards Development Unit, noted that Title 8 Section 5142 required maintenance of building ventilation systems.
Larry Callahan noted that breakdowns of air conditioning in office situations could result in exposure of employees not acclimatized to heat, thus increasing the potential for heat illness, especially where manual labor was being performed.
Workplace categories
Bob Barish began to suggest several different categories of work situations that could conceivably warrant different requirements, or should at least be considered with respect to practicality, in developing a Cal/OSHA standard to prevent heat stress illness:
Maintenance of hydration
The meeting then moved on to an extended discussion of maintaining worker hydration.
Jay Heaney suggested that maintenance of hydration, along with electrolyte replacement when necessary under special circumstances, were highly feasible keys to moderating the risk of heat illness.
Bob Barish suggested that it should be relatively easy for employers to comply with a requirement for provision of water to employees to prevent heat stress. Bob Barish then asked how feasible it would be for employers to assure adequate consumption of water by employees exposed to heat stress. Richard Warner of Southern California Edison, among others, said that he did not see how a requirement to assure consumption of water could be worded in a standard in such a way that employers could reliably comply. He said that while he thought it was reasonable to require provision of sufficient quantities of water to workers under circumstances that would encourage them to drink sufficient quantities, he did not think it was reasonable to expect employers to assure that employees consumed the quantity of water they needed to prevent heat illness.
There was some agreement that the need to assure consumption of sufficient water could at least be addressed by a requirement in a standard to discuss the importance of water consumption in employee and supervisor training.
Jay Heaney showed the group a 2-liter water supply that could be worn around the waist, with a built in drinking tube. He said such devices could encourage water consumption by making a relatively large quantity of water readily available at all times. He said that the increased work of carrying the weight of the water was insignificant with respect to risk of heat stress compared to the benefits of the additional water consumption.
Felix De La Torre, of the California Rural Legal Assistance Foundation, suggested that it was important to specifically require employers to assure adequate consumption of water. He said that current requirements under Cal/OSHAís field sanitation standard require provision of water to workers covered by the standard, but that many employer practices discouraged consumption. He noted for example that in piecework situations a foremanís pay may be tied to the productivity of workers they supervise, so that even if a worker being paid on a piecework basis wanted to be conscientious about water consumption, the foreman might view it as reducing their own compensation. He noted that in his experience in the Army superiors would check the canteens of subordinates as a means of trying to assure, or at least emphasize the importance of, adequate water consumption in hot situations.
Mr. De La Torre said that agricultural workers were often well-acclimatized but that the potential for heat illness was increased by lack of cool break areas, and sometimes lack even of shade, discouragement of rest breaks in the interest of productivity, particularly in piecework situations, and the frequent need of growers to rush the harvest process as a result of weather and/or market conditions. He also felt that limitations in emergency response in rural and often remote locations, as well as the barrier to training presented by different languages of supervisors and workers also contributed to the potential for heat illness among agricultural workers.
Mr. De La Torre noted that some employers in agriculture are cognizant of providing water and encouraging consumption. This suggested the importance of a standard to provide a level playing field so that conscientious employers were not penalized for their efforts. He also noted the importance of training of employees and supervisors in the need for consumption of water in hot situations beyond that needed simply to address thirst. However, he said he was skeptical that a training regulation would be sufficient by itself because it was too easy to provide documentation suggesting training had occurred even if it was inadequate or not actually provided at all.
Shifting the discussion to the fixed location situation, Larry Callahan indicated that in the glass plants he is responsible for, union agreements address provision of work breaks to consume water to prevent heat illness.
Mike Doering suggested a standard should require continuous provision of cool potable water readily accessible to employees.
William Krycia, DOSH Regional Manager in Sacramento, and lead person for the DOSH Agricultural Safety and Health Inspection Program (ASHIP), noted that the field sanitation standard (Title 8 Section 3457) required provision of water to covered workers and made mention of heat stress prevention. [Section 3457(c)(1)(A) requires provision of potable water that is "Ösuitably cool, and in sufficient amounts, taking into account the air temperature, humidity, and the nature of the work performed, to meet the needs of all employees." Section 3457(c)(4) requires that covered employees be informed of the importance of practices to minimize exposure to hazards in the field including heat, and that they should drink water frequently, especially on hot days.]
Bob Barish noted that existing Cal/OSHA standards for construction and general industry, and some other Cal/OSHA standards for specific industries required provision of adequate quantities of water to employees, though these standards did not specifically mention heat stress.
In light of what would appear to be a greater potential to assure water consumption than employee acclimatization in short term hiring situations as can prevail in agriculture and construction, Bob Barish asked the extent to which adequate hydration could make up for a lack of, or inadequate, acclimatization. Jay Heaney suggested that adequate hydration could be a significant factor in preventing heat illness among inadequately acclimatized workers. However Sherry Baron cautioned that hydration should not be viewed as the only important preventive measure.
Jay Heaney noted on a whiteboard that hydration was particularly important to several of the beneficial effects of acclimatization. He drew a rough graph of sweat rate vs. body core temperature for acclimatized and non-acclimatized workers. He explained that an important aspect of acclimatization in increasing the cooling efficiency of the human body is that it results in the body starting to sweat at a lower core body temperature, thus initiating cooling before the core temperature begins to increase significantly. He also indicated that a physically conditioned, but non-acclimatized individual tended to increase their rate of sweating faster as body core temperature rose, when compared with an unconditioned non-acclimatized individual. Dr. Dukes-Dobos in the meeting on December 9, 1999 had noted that an important effect of acclimatization was increased production of a more dilute sweat.
With so much of the effect of acclimatization thus depending on increased sweating, it was apparent that adequate hydration was essential to obtaining the benefits of this important protective mechanism.
A suggestion was made by several group members that a proposed standard might have a general requirement for assuring hydration, or at least provisions of readily accessible drinking water, but that specification of minimum quantities of water should be left to guidance in an appendix to the standard. Consistent with many published reports, Jay Heaney indicated that in situations posing a significant risk of heat illness, 1 to 2 liters of water is required to be consumed per hour.
Bob Barish noted that this could amount to 2 to 4 gallons per person per 8-hour workday. Bob suggested that it could take a significant amount of employer awareness, and planning, to assure availability of these quantities in remote situations without running water. For example, a crew of five could require 10 to 20 gallons of water just for drinking in a single 8-hour shift. There was also some discussion of the value of having water available for external cooling purposes, especially in the case of a person being unconscious.
Cooling vests
Bob Barish asked Jay Heaney about the cost and value of the cooling vests he had brought to show members of the group. Jay Heaney indicated that the vests using ice cost about $120 to $130 and could allow significantly increased exposure times without increasing risk of heat illness. He said the vests could help cool for up to 2 hours at a time. He noted that some vests employ a coolant that is flammable and so these could not be used in situations where fire is a potential hazard.
Bob Barish asked if cooling vests could be used as a tool by employers to facilitate or substitute for acclimatization. Jay Heaney indicated that this was possible to a limited extent. He noted that the vests can take some getting used to and wearers may feel uncomfortably cold when they first start wearing them.
General Discussion
Dennis Gibbons of the California Department of Pesticide Regulation described his agencyís standard, promulgated in 1985, to prevent heat stress for workers applying pesticides while wearing chemical resistant suits. He noted that with the additional stress they can put on the human body, pesticides can in some instances increase risk of heat illness for a given level of exposure.
Jay Heaney, along with Sherry Baron, both noted that some chemical exposures, as well as some prescription and non-prescription drugs, can increase the effect of heat stress and increase risk of heat illness.
Joyce Simonowitz, an occupational health nurse with DOSH, suggested that a proposed standard should contain an environmental threshold beyond which water must be provided in sufficient quantities to prevent heat illness. She said it would be important to specify in the regulation that the environmental measurements be made in the actual work areas where employees are exposed, and not assumed to be the conditions generally detailed in news or U.S. Weather Service reports.
Thresholds for coverage under a standard
Bob Barish suggested moving on to discussion of threshold levels for initiating coverage under a proposed standard.
There was a brief discussion of the Industrial Welfare Commission Orders for various occupations which specify that workplace temperatures should be maintained at comfortable levels and generally not fall below 68 oF. However, these were acknowledged to be focused primarily on maintenance of comfort and not prevention of exposure to heat or cold stress.
Jay Heaney described the approach taken by the U.S. Navy to prevent heat stress. The Navy developed a system of Physiological Heat Exposure Levels (PHELs). The system is based on dry bulb temperatures and an assumed relative humidity of 60 percent, time on station and work rate. An important point about the Navy PHELs is that they assume full acclimatization for whatever environment and work rate is encountered.
Mike Wurm of Quest Technologies asked why the ACGIH TLVs or a similar approach was not being considered. Bob Barish replied that the TLV approach was probably too complicated to expect all employers to be able to follow it.
Discussion ensued in general on the need for whatever threshold approach
is adopted to be relatively simple to understand and implement. Bruce Wallace
suggested that since humidity is so important to potential for heat illness
and is such a dominant part of the WBGT formula that perhaps wet bulb temperature
alone could be a threshold. There was some questioning of this idea but
it was
not entirely excluded.
Mike Doering suggested perhaps requiring assessment of relative humidity at some specified dry bulb temperature, and then preventive measures at some threshold relative humidity.
Larry Callahan made the point that in the glass industry, particularly in hot locations, changes of season lead to gradual changes in plant operations and levels of worker acclimatization that provide protection from heat stress. While supportive of the general concept of a standard to protect workers from excessive heat stress, he was concerned with a standard being based on particular exposure levels on particular days leading to requirements that did not take into account the gradual ramping up of protection that occurs in his and probably other traditional hot industries as a result both of natural processes (acclimatization) and an ongoing heat stress management program. He suggested that with an approach requiring the employer to assume, based on their past experience, geographical location, nature of work, etc. that heat stress will be a potential problem then there is no need for a particular environmental threshold level, but rather a focus on the employer having an effective program in place to address a hazard that will inevitably be faced at least seasonally each year.
Galen McCray of the California Department of Forestry (CDF) supported the concept suggested by Larry Callahan of a standard not being based on particular environmental threshold levels, but rather on general reasonable expectations of occurrence of heat stress exposure in an employerís workplace being the threshold for that employer to implement a heat stress management program to prevent heat illness. As an example, he described how CDF employees on call for wildlands fire fighting were required to undertake a regular program of physical training when not on the fire lines and provisions for maintaining acclimatization, all in recognition of the fact that at any moment they could be transported into situations where they could be exposed to high levels of environmental and fire generated heat that could put them at significant risk for heat illness.
Mike Doering asked about the potential for a threshold to be some physiological measurement such as pulse rate or an indicator of deep body temperature such as oral temperature.
Galen McCray indicated that CDF had a program for pulse rate monitoring.
Based on the immediately preceding discussion Bob Barish proposed the idea of a "soft" trigger for coverage under a regulation based on general reasonable expectations that employees will be exposed to risk of heat illness. For example in agriculture and construction work during the day in the Central Valley of California it would be very unusual in the summer for workers not to be exposed to temperatures in excess of 95 oF on a regular basis and under conditions of fairly demanding work load. A regulation could detail a program these employers would be expected to have in place to control risk of heat illness.
William Krycia expressed concern with relying only on the soft trigger approach because in his experience conditions of temperature and relative humidity, especially in outdoor situations, can change rapidly and there may be immediate need for preventive measures on particularly hot and humid days which occur early in the season with little warning. He felt these situations could be particularly hazardous if work levels are not adjusted because with rapid climate change workers might have little protection from acclimatization.
Larry Callahan expressed concern that if particular environmental conditions were specified as thresholds for coverage under a heat stress standard that they not be so low that time would be wasted documenting areas where the standard would not apply rather than effectively implementing preventive measures where they were truly needed.
Discussion then ensued on the potential for using Cal/OSHAís general requirement for an Injury and Illness Prevention Program (Title 8 Section 3203) as a means of requiring employers to address prevention of heat illness. Richard Warner suggested that perhaps Section 3203 could be sufficient to address the risk of heat stress.
Next meeting
The date of the next meeting was then discussed. Bob Barish indicated that the Division planned to have a written draft proposal prepared for the next meeting, based upon the discussion at the first two meetings. Bob Barish had previously suggested Wednesday April 12 to allow for participation of members of the ACGIH Physical Agents Committee who would be meeting in Oakland April 14-16. However, this was not a good day for a number of the participants present. Bob Barish indicated he would send out notices of the next meeting date well in advance.