Dear Assistant Secretary Parker:
On behalf of the Employers Heat Illness Prevention Coalition (the “Coalition”), I am pleased to submit these Comments addressing the Occupational Safety and Health Administration’s (“OSHA” or “the agency”) August 30, 2024, proposed rule on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings set forth at 29 CFR § 1910.148 (Docket No. OSHA-2021-0009) (hereinafter the “proposed rule”).
The Coalition is composed of a broad and diverse group of employers and trade associations representing many industries, including construction, manufacturing, energy, delivery and distribution, retail, warehousing, petroleum refining, liquid terminal operations, recycling, supermarkets and other grocers, automotive manufacturing, and many more, with millions of employees across hundreds of thousands of workplaces in every state in the Nation. In addition to representing a vast array of industries, Coalition members also represent essentially every kind of workplace affected by the proposed rule. For example, we have potential heat illness exposure hazards in outdoor-only, indoor-only, and outdoor/indoor work settings, and represent every size employer, from large international corporations to small businesses with brick-and-mortar locations. As our member organizations would be directly impacted by the proposed rule, the Coalition has a substantial interest in the outcome of this rulemaking.
The common thread among the Coalition’s diverse members is that they are responsible and conscientious employers that care deeply about their employees’ safety and health. Indeed, although no two are the same, each employer in the Coalition already has in place a heat illness prevention program. Our motivation here is to ensure that if OSHA promulgates a heat injury and illness prevention standard, that it is effective in its purpose–protecting workers from heat illness hazards–and reasonable in the burdens it places on employers.
Attached below is a copy of the full comments.