The Occupational Safety and Health Administration (OSHA) announced it will accept public comments through December 30, 2024, on its proposed rule issuing a heat injury and illness prevention standard for both outdoor and indoor workplaces. The rule would require employers to develop a heat injury and illness prevention plan and provide water, rest breaks and control of indoor heat when needed. NATE: the Communications Infrastructure Contractors Association, took exceptions to some of those rules.
NATE said it believes that some of the proposed enhanced safety measures, which could include mandatory breaks in a break area away from the work area or work-stoppages, will not be feasible for tower crews who are responsible for climbing and maintaining communications facilities at height. Communications towers do not have sheltered or shaded facilities built onto the towers, NATE contends, and added sheltered areas on towers may require additional structural analysis, which would cause additional cost.
Other requirements include developing plans for workers unaccustomed to working in high heat. Additionally, the rule would apply to all employers conducting outdoor and indoor work in all general industry, construction, maritime and agriculture sectors where OSHA has authority except for those specified by the rule.
Mandated work-stoppages would require tower technicians to climb down a tower and into a break area, according to NATE. In these scenarios, safety would be compromised because the proposed rule would require more frequent climbing (every two hours) and contribute to fatigue and repetitive stress injuries. Applying the fall protection hierarchy of controls, the most effective measures are applied by eliminating hazards. When workers must descend and ascend a structure multiple times, this creates additional exposures to falls and increases a hazard.
NATE said it “respectfully suggests” that establishing an arbitrary High Heat Trigger enforcement temperature would be unreasonable in the broadcast and communication tower industry. Tower technicians work at elevation on towers ranging from 100 to 2,000 feet above the ground. OSHA may determine that a High Heat arbitrary heat index is cause for safety mitigation measures; however, while working at elevation, temperatures can vary because of higher wind speeds and is a lower heat index than the index on the ground. NATE believes that monitoring the heat index for all climbers in various locations on the structures cannot be completed with sufficient frequency and accuracy with current measuring equipment due to variation in elevation during the work schedule.
NATE believes that establishing a High Heat Trigger enforcement would eliminate the ability for tower crews to complete tall tower maintenance inspections and the ability to “rig” a tall tower as both scopes of work typically exceed two hours.
NATE does not believe that a heat standard based on an arbitrary Heat Trigger ground temperature properly addresses the conditions encountered by tower technicians and fails to provide appropriate workplace safety benefits to tower crews who work at height. Rather, NATE believes that tower technicians should be vigilant about their personal health history, physical conditions, and their ability to acclimate to any new environments.
OSHA states break areas must be “readily accessible” which is defined as: “capable of being reached quickly for operation, renewal, or inspections, without requiring those to whom ready access is requisite to climb over…or to resort to portable ladders…etc.” Descending a structure to access a break area does not meet the definition of readily accessible.
NATE is asking its member companies to submit public comments on the proposed OSHA Heat Injury and Illness Prevention rule. Public comments can be submitted electronically via the Federal eRulemaking Portal at: https://www.regulations.gov.
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