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Heat Stress Exposure Limits

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Table of Contents

Purpose of the Report .......................................................................................................................... 3

Executive Summary .............................................................................................................................. 3
Provincial and National Perspective .............................................................................................. 3
International Perspective .................................................................................................................. 6
Discussion and Recommendations ................................................................................................. 7
Conclusions ............................................................................................................................................. 8
Bibliography ........................................................................................................................................... 9
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Purpose of the Report

The purpose of this report is to compare and discuss the regulation of occupational temperature
exposure limits in Canada at the federal and provincial levels, and the policies of the United
States France, the United Arab Emirates are briefly presented and discussed.
Recommendations and conclusions regarding the effectiveness of legislation in limiting worker
exposure to heat stress are offered based on the research.

Executive Summary

Every year occupational heat stress causes the illness, injury and death of thousands of
workers around the globe. While many counties have Occupational Health and Safety
legislation, few include heat exposure thresholds. In Canada Occupational legislation varies
from province to province, but most jurisdictions recognize and use the Threshold Limit Values®
for heat stress that are published by the American Conference of Governmental Industrial
Hygienists (ACGIH). The United Arab Emirates’ policy and programs to reduce heat stress
among workers is recommended as a model for other countries to consider.

Provincial and National Perspective

Region Heat Exposure Limits Employer Responsibilities Document

Nunavut SAFETY ACT CONSOLIDATION OF
Working environment to be consistent OCCUPATIONAL HEALTH AND
SAFETY REGULATIONS R-003-2016 In
with work requirements. Employers to force March 29, 2016, S. 74
provide effective worker health and
safety protection including reasonable
thermal comfort

Maximum and Program required when thermal CONSOLIDATION OF MINE HEALTH

minimums as per conditions and nature of work can AND SAFETY ACT S.N.W.T. 1994,c.25
ACGIH TLV cause distress. 1994-1995 ACGIH In force December 15, 1995: SI-014-95
TLVs®. S.s 9.57 to 9.62

North West Workplace temperature consistent with OCCUPATIONAL HEALTH AND

Territories work requirements, providing for
effective protection of worker health
and safety, and reasonable thermal
comfort
Maximum and Program required when thermal
minimums as per conditions and nature of work can
ACGIH TLV cause distress. 1994-1995 ACGIH
TLVs®.
SAFETY REGULATIONS R-039-2015 S.
74
MINE HEALTH AND SAFETY ACT
S.N.W.T. 1994,c.25 In force December
15, 1995; SI-014-95 9.57 to 9.62
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Yukon Conditions specific to tower cranes The Occupational Health and Safety
Regulations, 1996, S. 5.75
Temperature consistent with work. The Occupational Health Regulations

Region Heat Exposure Limits Employer Responsibilities Document

Ontario Maximum heat 38°C as Employers have a duty to protect S. 25(2)(h) Ontario Occupational Health
per ACGIH TLV workers from harm and illness, and Safety Act
including implementing procedures for
workers in hot environments
S. 260(3)(d): Underground workers’ Occupational Health and Safety Act
change room for minimum 27°C ONTARIO REGULATION 213/91
S. 357(7): Minimum of 18°C Medical CONSTRUCTION PROJECTS, S.
locks required 260(3)(d), S. 357(7), S. 380 (2), S. 384(2)
S. 380 (2): Maximum of 27 °C. air lock
Also see S. 384(2), 38 °C maximum
Minimum temperature of 18°C in Occupational Health and Safety Act,
enclosed work space R.R.O. 1990, REGULATION 851,
INDUSTRIAL ESTABLISHMENTS, S. 129
Quebec Maximum and S.116 to 120: Workplace temperature Regulation respecting occupational health
minimums as per consistent with work requirements and safety, S.116-124, Schedule IV & V
ACGIH TLV S.121 to 124: Heat Stress
Schedule IV: Standards of
Temperature in Establishments.
Minimum depends on work (e.g.,
heavy work 12°C; light work 20°C)
Schedule V: Evaluation of Heat Stress
–Work/rest schedule and Wet Bulb-
Globe Temperature (WBGT)
equations.
Newfoundland Maximum heat as per S. 44: Temperature consistent with NEWFOUNDLAND AND LABRADOR
ACGIH TLV work requirements.as established by REGULATION 5/12 Occupational Health
current ACGIH TLVs® and Safety Regulations, 2012 under the
Minimum temperature S. 566: Refuge station provided at Occupational Health and Safety Act (O.C.
10°C as per Act minimum 10°C 2012-005), S. 44, S. 566
Nova Scotia Maximum and 2.1 and 2.3: current ACGIH TLVs® for Workplace Health and Safety Regulations
minimums as per heat and cold exposure made under S. 82 of the Occupational
ACGIH TLV Health and Safety Act, 2.1 and 2.3

New Brunswick Maximum and S. 21: Enclosed workplace minimum General Regulation - Occupational Health
minimums as per temperature consistent with work and Safety Act N.B. Reg. 91-191, S 21,
ACGIH TLV requirements. (e.g., heavy work 12°C; S. 22
light work 20°C)
S. 22: Extremes of Temperature: 1997
ACGIH TLVs® for heat and cold
exposure
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Region Heat Exposure Limits Employer Responsibilities Document

Prince Edward Maximum and S. 11.10 and 11.11: In an enclosed Occupational Health and Safety Act,
Island minimums as per place of employment, minimum S.11.9-11.11
ACGIH TLV depends on work being done (e.g.,
heavy work 12°C; light work 20°C).
Exceptions apply.
S. 11.9: relative humidity in an office
environment must be minimum of 30%
S. 42.1: Extremes of temperature -
current ACGIH TLVs® for heat and
cold exposure
Manitoba Maximum and S. 4.12 Procedures and control Workplace Safety and Health Regulation
minimums as per measures consistent with ACGIH S. 4.12, S. 4.13
ACGIH TLV Standard must exist for cases of heat
stress
S. 4.13 Workers to be educated about
identification of heat stress and its
treatment.
Indoor temperatures are to be
consistent with work requirements
Workers to be educated about Guideline for Thermal Stress 2007
identification and treatment of heat
stress - wet bulb globe measurements,
acclimatization schedule, clothing
adjustment factors and prevention and
control measures (engineering,
administrative and PPE) are suggested
Saskatchewan Provide and maintain measures to The Occupational Health and Safety
protect workers, regarding Regulations, 1996, S. 70
temperatures of working conditions.
Offer reasonable thermal comfort to
workers.
Alberta “…stop work until the Published guidelines - no legislation. OHS Prevention guidelines Working in
Humidex is 44°C or Extreme Temperatures as per p. 75
less” Humidex Based Heat Response Plan
From: Occupational Health Clinics for
Ontario Workers appears as Table 17 in
Best Practice – Working Safely in the
Heat and Cold

British Exposure limits as per 7.28 Exposure limits and Clothing Workers Compensation Act
Columbia ACGIH TLV Corrections ACGIH Standard. OCCUPATIONAL HEALTH AND
7.29 Heat stress assessment and SAFETY REGULATION B.C. Reg.
exposure control plan 296/97 S.7.27-.7.32
7.30 Heat stress controls: Engineering,
Administrative and Personal Protective
Equipment
7.31 Provision of water
7.32 Removal from and treatment for
heat exposure
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Region Heat Exposure Employer Responsibilities Document

Limits
Canada S. 9.9: personal service food Canada Labour Code (R.S.C., 1985, c. L-
2), S.9.9, S.14.9(2),
preparation area: 18°C minimum/29°C
S. 16.10(2)(b)
maximum
S.14.9(2): motorized materials handling
equipment, operators' compartment:
26°C maximum
S. 16.10(2)(b) First aid room: 21°C to
24°C

Workstation Humidex S.2.2 Defines Environmental Working National Joint Council Occupational
maximum 40°C Health and Safety Directive, 2011, S.2.2
Conditions: ideal 20-26°C;
uncomfortable 17°C and 20°C, and
above 26°C (work should not exceed 3
hours daily or 60 hours annually in
uncomfortable); maximum limit 40°C

International Perspective

The occupational heat stress policies of the United States, France, The United Arab Emirates
(UAE), and China are reviewed below, followed by a brief discussion.

There is no federal legislation addressing occupational heat stress reduction in the United
States (US) and only three states have such laws. While there is no legislated maximum
occupational temperature, the US government publishes guidelines that employers may choose
to follow.

In France there is no occupational maximum temperature, but employers must ensure the
safety of workers and provide fresh drinking water. The government publishes guidelines for
employers, similar to those of the US and many other countries.

In 2012 the United Arab Emirates imposed a ban on outdoor work during the summer, between
12:30pm and 3:00pm. Employers are required to post employees' working hours and provide
rest areas. First aid kits, drinking water, and a means of preventing direct exposure to sunlight in
emergency cases and jobs requiring continuous work or in are essential.
The Ministry of Labour performs approximately 60 000 workplace inspection visits annually to ensure
compliance with the ban, paying special attention to construction sites. Compliance with the ban is
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around 95.5%. Ban violation penalties include fines, or closure of the worksite, depending on the
offence.

China has extensive legislation requiring employers to measure temperatures and respond in
accordance with policies designed to control worker exposure to heat stress. Outdoor operations are
directly suspended at 104ºF / 40°C Between 99ºF / 37° C and 104ºF / 40°C, employees must not
work outside for more than 6 hours or perform outside operations during the hottest 3 hours of the
day. Environments exceeding 95ºF / 35°C must use new technology and equipment and provide
cold beverages and resting rooms.

The United States, France, The United Arab Emirates, and China all have regions that
experience annual periods of extreme temperature, however, only the UAE and China have
specific legislation to reduce incidence of occupational heat stress illness, injury and death. The
United States and France publish guidelines, which employers may choose to use, but neither
country has legislated occupational heat exposure thresholds. This approach is typical of many
countries.

The UAE model is recommended for adoption by other countries. It is unclear to what extent
China enforces its heat stress legislation, but in the UAE, there is a proactive inspection system,
which is supported by comprehensive legislation with significant penalties that can include
company closure.

Discussion and Recommendations

A common approach to addressing heat stress is for countries to include it with the general
duties of employers under existing Occupational Health and Safety legislation. Governments
often publish guidelines and educational material that employers are encouraged, but not
required to use. In the absence of regulatory values, employers may use the heat exposure
thresholds published by organizations such as the International Organization for Standardization
(ISO), or the American Conference of Governmental Industrial Hygienists (ACGIH).

Most legislation has not included maximum heat exposure thresholds because temperature is
influenced by numerous factors, such as the work environment (indoors, outdoors, direct
sunlight, confined space, etc.), radiant temperature, humidity, air velocity and countless details
relating to the type of work in question. Variables complicate creating and enforcing laws, which
is why most countries have empowered employers to create job-specific heat stress programs.
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To reduce the number of occupational heat stress casualties, legislating heat exposure
thresholds is good place to start, especially regarding outdoor work. However, threshold laws
fail to address the biggest challenge regarding occupational heat stress, which is that some
employers take advantage of vulnerable populations who are willing to work under any
conditions, especially migrant workers in the agriculture and construction industries. These
employers will not stop inhumane practices without significant financial loss.
To address these problems, laws need to define specific heat thresholds and necessary
engineering, administrative and behaviour controls, such as using personal protective
equipment, regular breaks, and ample hydration. However, to be effective the laws must carry
heavy financial fines that increase with each offence, as well as the possibility of business
closure after too many offences.
Adapted work schedules should also be implemented during heatwaves and hot seasons,
banning outdoor work, or work in direct sunlight during certain periods of the day. This approach
has been implemented effectively in the United Arab Emirates and other countries.

Conclusions

Although there are many laws that address occupational heat stress in Canada, laws vary
between Canadian jurisdictions, however, the same heat exposure threshold standard (AGIC) is
used across most of the country.
It is important for countries around the world to create legislation that defines heat exposure
thresholds and controls, to mitigate heat stress hazards. To significantly decrease the numbers
of workers who suffer heat related illness, injury and death, legislation must be enforced and
include penalties that significantly threaten the financial viability of companies that fail to comply.
Enforcement should focus on employers of migrant agricultural and construction workers, as
these groups are at greatest risk of suffering the effects of heat stress at work.
The UAE offers an effective model upon which other countries may base their own occupational
heat stress legislation and programs.
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Bibliography

Gil, Natalie. (2016,July 19) Scorchio! When Are Workplaces Around The World Legally
Considered Too Hot?. Refinery29. https://www.refinery29.com/en-
gb/2016/07/117224/workplace-temperature-limit-around-world. Accessed Oct 8, 2019.

Irfan, Umair. (2018, July 27) Heat waves can be deadly for workers and will drain the US
economy. Vox.
https://www.vox.com/2018/7/27/17611940/heat-wave-2018-cost-workers-deaths-health-
climate-change. Accessed Oct 8, 2019.

Onyeka, Thelma. Salaheldin, Maram. (2015, June 23) Safety in the Sun: When is Your
Workplace Too Hot to Handle?. Enhesa. https://www.enhesa.com/blog/safety-sun-when-
your-workplace-too-hot-handle. Accessed Oct 5, 2019.

Table 1 Canadian health and safety regulations with respect to thermal conditions in the
workplace. Canadian Centre for Occupational Health and Safety.
https://www.ccohs.ca/oshanswers/phys_agents/temp_legislation.html. Accessed Oct 5, 2019.