Safety in the sun: when is your workplace too hot to handle
A consistent trend in emerging economies is the rapid development of industrial and housing projects, even in very arid landscapes. In just over a decade, cities like Dubai have been raised from desert. The desire for accelerated construction processes has been largely met by technological advances but has also led to an increase in human heat exposure in workplaces. As an EHS Director, it is important to know whether your employees and the employees of your contractors are protected from the heat, whatever hemisphere you happen to work in.
Working in the heat
Work involving excessive heat exposure is a serious health and safety hazard and can lead to various health problems, ranging from physical discomfort to life threatening conditions. In fact, every year, thousands of workers suffer from illnesses directly related to occupational heat exposure, some ending in fatalities.
Outdoor work which involves hot and humid conditions such as construction, mining, and oil and gas operations, to name a few, are especially likely to cause heat-related illnesses, particularly when they involve heavy work tasks, requiring equipment and protective clothing. However, it is important to recognize that such consequences are preventable if the correct precautions are taken. And yet, as is often the case when economic considerations are in play, not every country is imposing sufficient measures.
Below we highlight examples of regulatory activity, as it pertains to heat exposure, which Enhesa has been tracking over the past few years.
Spread over such a vast area, China is subject to extremes in weather, including unbearable heat. Consequently, Chinese facilities are taking extensive and precise measures to reduce working hours for their workers in hot weather. When the temperature reaches 104ºF / 40°C or above, outdoor operations are directly suspended, and when between 99ºF / 37° C and 104ºF / 40°C, employees must not work outside for more than 6 hours, or conduct any outside operations during the hottest 3 hours of the day. As of July 2012, facilities conducting operations in high temperature environments exceeding 95ºF / 35°C are forced to utilize new technology and equipment, and provide cold beverages and resting rooms. There is still room for improvement, however, as China could aim to reduce thresholds by also taking humidity levels into account. Moreover, non-compliance could be better identified by the increase of workplace inspections.
Famous for its oppressively arid climate and temperature extremes, it’s no surprise that much of the terrain in the Middle East is uninhabited. Temperatures can reach a scorching 140 ºF / 60° C during the summer months—heat so intense that exposure can be fatal.
United Arab Emirates
Unsurprisingly, heat stress is a phenomenon that is recurrent in the United Arab Emirates during the summer period and beyond, where the ambient temperature can reach highs of 122ºF / 50°C, putting exposed workers at risk. Every summer, the Ministry of Labor imposes a country-wide ban on outdoor work between 12:30 pm and 3:00 pm during the summer months. Employers are required to specify and display working hours, as well as provide appropriate rest areas and protection against the risks of heat. For activities requiring continuous work or in emergency cases, first aid kits, drinking water, and a means of preventing direct exposure to sunlight are essential. The Ministry of Labor is continuously intensifying its inspection campaigns every year. In fact, according to the Assistant Undersecretary for Inspectional Affairs at the Ministry, compliance with the ban was around 95.5% last year. Violations of the annual ban are penalized, including fines or closure of the worksite, depending on the offence. In terms of monetary fines, companies could be forced to pay 5,000 AED (1,361 USD) per worker and up to 50,000 AED (13,613 USD) if multiple workers are found to have been working during the banned time. To ensure compliance, the Ministry plans to launch over 60,000 inspection visits. The inspections will be carried out by the 18 inspection squads formed by the Ministry. In particular, the inspection squads will regularly monitor construction sites to ensure their compliance with the ban.
To help companies with compliance, the Ministry of Labor also plans to conduct 20,000 informational visits to sites aimed at spreading awareness and understanding of the midday work ban and heat stress in general. The individual emirates also seek to address these issues by providing guidance and regulations on the local levels.
In the Emirate of Dubai, for example, Local Order No. 61 of 1991 requires all employers to ensure safe working conditions in the workplace, which is used as the basis upon which Dubai Municipality tackles the heat stress problem. The Public Health and Safety Department of Dubai Municipality issued the Guidelines for Heat Stress at Work in 2010 in order to provide guidance on prevention, recognition, and treatment.
Since 2006, Saudi Arabia has observed a midday work ban during the summer months aimed at protecting the health and safety of workers from the sweltering heat. Every year the Ministry of Labor issues information and guidance to remind companies of, and assist them in complying with, the ban. Between 15 June and 15 September, companies are prohibited from employing workers under direct sun exposure between the hours of 12:00PM and 3:00PM. Interestingly, outdoor workers in the petroleum, natural gas, or emergency maintenance work industries are exempt from this prohibition. However, the employers of such exempt workers must ensure that precautionary measures preventing direct exposure to sunlight are provided. Companies found in violation of the heat stress order will not get off lightly; they’ll receive a fine of up to 10,000 SAR (2,666 USD) or even a shutdown of the concerned facility for up to a month after the second violation. Companies found in violation of the ban for a third time could face permanent closure.
Comparison: emerging markets vs. developed countries
The governments of the member states of the Gulf Cooperation Council (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates) are not the only actors involved in these attempts to protect workers from the dangerous summer heat. Through the region, and even the world, nongovernmental actors are also stepping up to bring attention to the plight of migrant workers, who repeatedly have been found facing dire work conditions. Migrant workers are especially impacted by companies’ compliance with the midday work ban since they make up the bulk of the construction workforce in many GCC countries. Saudi Arabia’s National Society for Human Rights (NSHR), for example, conducts initiatives aimed at monitoring the implementation of the Ministry of Labor’s midday work ban during the summer months across the country, where there are approximately 9 million migrant workers employed largely in the construction sector. The Society is just one of several organizations that criticized the lack of enforcement actions taken by the Ministry in the past, and in previous years, the Ministry has responded with intensified inspections and enforcement actions. As the media remains focused on the region, we can expect, and hope for, more positive changes resulting from the weight of public opinion.
Over the past few years, Australia has experienced record-breaking heat waves so hot that darker shades of red had to be added to the weather map. Workers however can rest assured that the same won’t be happening to their skin, as the country is well prepared for such conditions, leading by example when it comes to promoting the safety of its workers.
The 2011 Work Health and Safety Regulation calls for close monitoring of the physical well-being of workers exposed to heat. Training provisions are requisite to recognize the early symptoms of heat strain, how to follow safe work procedures and how to report problems immediately. Most importantly, Australia has very active enforcement agencies that prioritize inspections during times of climate strain.
Companies can refer to a published guidance document from the Ministry for Health and Social Solidarity to help prevent heat stress for workers. The guidance document covers how to assess the risk of heat stroke, training, emergency response and first aid during periods of high temperatures. The guidance is not compulsory but can aid employers in protecting employees from heat stroke.
In Poland, when the temperature is above 86ºF / 30°C employers must ensure air-conditioned rest areas, sanitary facilities, of which depends on the working place and number of employees, as well as drinking water or beverages that is accessible within a maximum of 75 meters from the workplace.
United States: California
Over the last few years, the state of California has moved towards more prescriptive requirements for heat illness prevention. Recently the California Occupational Safety and Health Standards Board finalized amendments to heat illness prevention regulation to strengthen requirements and ensure medical services are provided. Beginning May 1, 2015, companies with operations that require employees to work in high temperatures will need to comply with amendments to the Heat Illness Prevention section of the General Industry Safety Orders. Under the final amendments, employers must implement high heat procedures when the temperature reaches 85 ºF, provide cold drinking water, monitor employees for signs of heat illness, and develop, implement and maintain heat illness prevention plans.
Though we are seeing increased regulatory activity across all continents, a consistent global approach to protect the rights of workers is still lacking, notably in the construction industry. Of course it is impossible to eliminate all climate-related illnesses completely, however, the risk of developing heat stress can be minimized. Educating both employers and workers is vital for the correct implementation of rules and policies that are already in place, and in countries where requirements are insufficient, further action is necessary. Not only will this be beneficial for workers, it is widely accepted that better conditions in the workplace lead to increased productivity.