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Is Your Indoor Workplace Too Hot for Cal/OSHA?

California employers tend to think about heat illness prevention as an outdoor-work issue. That is understandable. Agriculture, construction, landscaping, field work, delivery routes, and other outdoor operations have been the traditional focus of Cal/OSHA heat enforcement for years.

But that is no longer the whole picture. Cal/OSHA now has separate heat illness prevention rules for indoor workplaces. That means restaurants, warehouses, manufacturing facilities, distribution centers, auto shops, bakeries, laundries, commercial kitchens, maintenance areas, and other indoor workplaces may need a closer look before the next heat event.

Here is the issue: if an indoor work area reaches 82 degrees Fahrenheit when employees are present, Cal/OSHA’s indoor heat illness prevention standard may apply. 

What about mixed operations? Cal/OSHA’s guidance states that employers may be covered under both the indoor and outdoor rules if they have both indoor and outdoor workplaces. For example, a delivery employee moving between indoor and outdoor work areas may raise both sets of issues. 

When Do the Indoor Rules Apply?

The indoor rule applies to most indoor work areas where the temperature is at or above 82 degrees when employees are present. That 82-degree threshold matters because many workplaces can reach it without appearing to be a classic high-heat environment.

In some situations, additional assessment and control obligations may apply, including when the temperature or heat index reaches 87 degrees, when employees wear clothing that restricts heat removal and the temperature reaches 82 degrees, or when employees work in a high radiant heat area and the temperature reaches 82 degrees.

That is why a general instruction to “stay hydrated” is not enough. Employers need procedures that fit the workplace. A hot kitchen is different from a warehouse loading area. A manufacturing floor with radiant heat sources is different from an office area with reliable air conditioning. Employers should not assume that a roof, a fan, or a partially enclosed work area removes the issue. The analysis depends on the work area, the temperature, the heat index, radiant heat, clothing or PPE, available cooling, and the employer’s actual procedures. See Cal/OSHA Heat Illness Prevention Guidance and Resources for Cal/OSHA’s comparison of the indoor and outdoor standards. See also Indoor Heat Illness Prevention FAQs.

What Employers Should Review Now

With June gloom fading and temperatures on the rise, California employers should use the summer heat season as a prompt to review the basics. At minimum, employers should confirm whether their heat illness prevention procedures address:

  • Do you have a Heat Illness Prevention Plan that complies with Cal/OSHA regulations and guidance?
  • Indoor work areas that may reach 82 degrees or higher while employees are present;
  • Access to fresh, suitably cool drinking water;
  • Shade for outdoor work and cool-down areas for indoor work;
  • Preventive cool-down rests and how supervisors should respond when employees need them;
  • Emergency response procedures, including how employees will contact a supervisor or emergency medical services;
  • Acclimatization for new employees, newly assigned employees, and employees working during heat waves;
  • Training for both supervisors and non-supervisory employees;
  • Procedures for measuring temperature or heat index where required;
  • Whether the written plan is available at the worksite and in the language understood by the majority of employees.

Why Documentation Matters

Heat illness prevention is not just a safety issue. It is also a documentation issue. If Cal/OSHA shows up at your worksite, it will ask for the employer’s written procedures, training records, measurement records, or emergency response steps; your business needs to be able to show what it actually implemented.

A policy that restates the regulations is unlikely to be enough. Cal/OSHA’s indoor heat FAQ explains that a compliant heat illness prevention plan should be specific and customized to the employer’s operations. In practice, that means HR, safety, and operations should be aligned on what supervisors are expected to do on a hot day.

Final Takeaways

The simplest and most practical first step is to: identify which work areas can reach 82 degrees indoors, confirm which outdoor operations remain covered by section 3395, and then review and update your written heat illness prevention plan before supervisors need to use it.

If you would like help reviewing or updating your heat illness prevention procedures, training materials, employee communications, or Cal/OSHA documentation, the attorneys at EmployLaw Group can help. Contact us today at (805) 586-1381 for more information, or visit EmployLawGroup.com to schedule a consultation.

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