Does The Heat Illness Standard Apply To Indoor Workplaces?

According to Eric Andersen, CSM of L.L. Andersen a professional safety, health and environmental consulting firm, the answer is a definite YES.  The Heat Illness Standard ("Standard") is found in section 3395 of Title 8 of the California Code of Regulations.  The standard specifically states that it "applies to all outdoor places of employment." 

Exactly what "outdoor" means is still ambiguous.  For example, what about the driver who operates a motor vehicle, or a semi-enclosed facility?  But leaving that issue aside, why would the Standard apply to indoor places of employment? 

Mr. Anderson claims that Cal/OSHA will enforce the Standard on indoor places of employment through the General Duty Clause.   Some of you safety experts might ask how Cal/OSHA can enforce the Standard under the general duty clause.  After all, Cal/OSHA does not have General Duty Clause citation authority. 

However, Cal/OSHA does have Special Order authority to issue an order upon finding of an unabated hazard and the lack of an applicable standard.  An employer must comply with a Special Order or face a failure to abate citation. 

Summer is quickly on its way and the temperature is rising.  Now is the time for businesses to review their compliance with the Standard.  Even those businesses that arguably have indoor places of employment should review the Standard and determine how to best protect employees from the consequences of heat illness.