Heat Stress Comment for OSHA
Below is my comment that I submitted to OSHA in response to their “Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings Rulemaking”. You can (and should) submit your own comment (feel free to copy pieces or all of mine, though I’m not sure how sensitive OSHA is to repeat comments, so you may want to tweak it). The deadline for public comment is December 30, 2024, and you can submit your comments here. https://www.regulations.gov/commenton/OSHA-2021-0009-4761
As an Assistant Professor of Industrial and Organizational Psychology, with a focus on Occupational Health Psychology, I feel compelled to publicly support these regulations and to highlight some additional psychologically-oriented research that may be of use.
First, in response to the request for comments, the field of I-O Psychology provides a century’s worth of data-driven best practices on training design, implementation, and evaluation (Bell et al., 2017). Our field can largely speak to the following questions: (1) Whether the inclusion of separate training requirements for supervisors and heat safety coordinators is appropriate, or whether the duty-specific training requirements in proposed paragraph (h)(1) are sufficient. (2) Whether the agency should require annual refresher training or whether the more performance-based supplemental training requirements are sufficient.
Data suggest that broadly, safety training (which would include heat safety training) is effective in improving safety compliance, safety participation, safety motivation, safety knowledge, and safety climate (Hutchinson et al., 2022). Across all forms of training, supervisor support is critical to the effective transfer of training back to the job (e.g., Bell et al., 2017). One way to promote supervisor support of training is to train supervisors themselves on the desired material (e.g., Grace & Straub, 1991. Evidence suggests that safety training for supervisors is effective at improving safety-related outcomes in the workplace (Sinelnikov et al., 2020). Thus, I recommend that additional supervisor-specific training on heat safety regulations, maintaining a heat safety climate, and facilitating transfer of training to the job.
Evidence suggests that knowledge may be retained for longer periods of time than skills (e.g., Lawani et al., 2018). However, all trainings should be rooted in a training needs analysis (Bell et al., 2017; Salas et al., 2012) to ensure that gaps between current and necessary knowledge and skills are adequately addressed by trainings. Moreover, Salas et al suggest that “organizations do not offer sufficient refresher training except when mandated by regulations” and “the research on skill decay shows why refresher training can be critical” and that organizations ought to “provide refresher training when decay cannot be avoided”. Thus I recommend a hybrid approach to refresher training regulations such that annual refresher training is mandated, but triggers, rooted in training evaluations (e.g., presence of a heat stress incident in the workplace) can also incite additional refresher trainings.
Second, I want to highlight broader evidence for the need for more specific recommendations when possible, as well as a need to evaluate heat safety climate/culture. Within I-O psychology, research suggests that individual differences and differences across units and organizations can lead to wide variability in performance. Safety climate, a socially constructed variable focused on the degree to which the organization and people in the organization value safety, is one of the strongest predictors of safety performance (Clarke, 2006) along with safety knowledge and safety motivation (Christian et al., 2009). Research also suggests that the regulatory environment influences organization’s safety practices, with clearer and consistent regulations reducing uncertainty around expected practices, particularly for companies that operate in multiple contexts (e.g., across states or countries) (Griffin & Curcuruto, 2016). Thus, to maximize the impact of regulations on heat safety, they should be clear and consistent (hence the need for federal regulation) and part of the record keeping process should involve evaluation of heat safety climate. This may look like aggregated (anonymized) scores on a modified version of a safety climate survey such as the NIOSH Short Safety Climate Scale (Hahn & Murphy (2008)).
Last, I want to thank OSHA for seeking to protect workers from the increased threat of extreme heat.
References:
Bell, B. S., Tannenbaum, S. I., Ford, J. K., Noe, R. A., & Kraiger, K. (2017). 100 years of training and development research: What we know and where we should go. Journal of Applied Psychology, 102(3), 305–323. https://doi.org/10.1037/apl0000142
Christian, M. S., Bradley, J. C., Wallace, J. C., & Burke, M. J. (2009). Workplace safety: A meta-analysis of the roles of person and situation factors. Journal of Applied Psychology, 94(5), 1103–1127. https://doi.org/10.1037/a0016172
Clarke, S. (2006). The relationship between safety climate and safety performance: A meta-analytic review. Journal of Occupational Health Psychology, 11(4), 315–327. https://doi.org/10.1037/1076-8998.11.4.315
Griffin, M. A., & Curcuruto, M. (2016). Safety climate in organizations. Annual review of organizational psychology and organizational behavior, 3(1), 191-212. https://doi.org/10.1146/annurev-orgpsych-041015-062414
Hutchinson, D., Luria, G., Pindek, S., & Spector, P. (2022). The effects of industry risk level on safety training outcomes: A meta-analysis of intervention studies. Safety science, 152, 105594. https://doi.org/10.1016/j.ssci.2021.105594
Lawani, K., Hare, B., & Cameron, I. (2018). Integrating early refresher practice in height safety and rescue training. Safety science, 110, 411-417. https://doi.org/10.1016/j.ssci.2018.03.029
Salas, E., Tannenbaum, S. I., Kraiger, K., & Smith-Jentsch, K. A. (2012). The science of training and development in organizations: What matters in practice. Psychological science in the public interest, 13(2), 74-101. DOI: 10.1177/1529100612436661
Sinelnikov, S., Bixler, E. A., & Kolosh, A. (2020). Effectiveness of safety training interventions for supervisors: A systematic review and narrative synthesis. American journal of industrial medicine, 63(10), 878-901. DOI: 10.1002/ajim.23163
Grace, P., & Straub, C. (1991). Managers as training assets. Training & Development, 45(6), 49-55.