With the heat of summer approaching, contractors need to be aware of the dangers of exposing workers to the heat. To address the hazards, ADOSH and Federal OSHA have both published Heat Emphasis Programs which enhance inspections and compliance activities on construction sites during the summer months. The program means that all ADOSH and OSHA inspections will now include an inquiry about the measures that have been put in place to mitigate heat hazards. One of the things that compliance officers will be asking about is whether or not you have a written heat safety plan. While a written plan is not specifically required in any current regulation, a written plan may be needed to show that you have evaluated the hazards and taken appropriate steps to keep workers safe. ADOSH intends to review plans created by an employer to reduce the risk for heat related illnesses and injuries. Written plans should address water, rest, shade, acclimatization, and training to recognize signs and symptoms of heat stress.
The ADOSH announcement of the Heat Emphasis Program can be viewed at https://www.azica.gov/sites/default/files/2023-08/ADOSH%20Announces%20State%20Emphasis%20Program%20to%20Combat%20Heat%20Illness%20and%20Injury%20in%20the%20Workplace%20Release.pdf
The City of Phoenix has also been working to draft legislation that pertains to all contractors, sub-contractors, and leasing companies that would apply to any company working on a City of Phoenix Contractor, or doing work on City of Phoenix owned property (including city streets and other facilities). The currently proposed language is fairly straightforward with the main requirement being the all employers must have a written plan. The proposed legislation does not currently set any limitations or restrictions, but simply states that all employers must have a written plan to address the same things outlined in the ADOSH Heat Emphasis Program.
The current proposed City of Phoenix legislation can be viewed by downloading the file below. The City has held several public meetings about the proposed legislation (which is being opposed by AGC of Arizona) and expects to put this before City Council before May 2024.
This draft was sent to stakeholders on March 12, 2024 and includes feedback from the March 7th stakeholders meeting.
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