Advocating for Practical Heat Safety Rules: ILTA Engages in OSHA Rulemaking
Over the past year, the International Liquid Terminals Association (ILTA) has actively engaged in the U.S. Occupational Safety and Health Administration’s (OSHA) ongoing rulemaking process related to heat injury and illness prevention. OSHA’s proposed Heat Injury and Illness Prevention Rule would require companies across general industry, construction, maritime, and agriculture to establish comprehensive prevention plans during periods of extreme heat. These plans may include rest breaks, hydration protocols, access to shade, and other mandated practices.
Recognizing the potential impact on our members and the operational flexibility of terminal facilities, ILTA joined the Employers Heat Illness Prevention Coalition—an industry-wide alliance led by the labor and employment law firm Conn, Maciel, Carey LLP. Through this coalition, ILTA contributed to the development of a detailed comment letter submitted to OSHA on January 16, 2025. The letter provided legal, technical, and operational feedback on the proposed rule, emphasizing the need for a balanced and practical approach to worker safety.
In addition to written comments, ILTA member Kinder Morgan took a more public step by participating in OSHA’s informal rulemaking hearing. Represented by Richard “Rich” Steinberg, Kinder Morgan offered testimony on behalf of the bulk liquid terminal industry. Mr. Steinberg advocated for a final rule that recognizes the diversity of working environments and allows companies the flexibility to tailor heat prevention practices to their specific operational needs, rather than imposing a rigid, one-size-fits-all mandate.
ILTA remains committed to working with OSHA and industry stakeholders to ensure that any final regulation prioritizes worker safety while remaining operationally feasible. For more information, you can view the full comment letter and testimony using the links below.
Comments on a Proposed Rule Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings
June 17, 2025: Watch as Richard Steinberg of ILTA member company Kinder Morgan, Inc. testifies during OSHA’s informal rulemaking hearing on the proposed standard for preventing heat injury and illness in both outdoor and indoor work environments.