Based on AGC’s review and analysis of the NEP, it is unclear if following the principles of Water. Rest. Shade. under OSHA’s Heat Illness Prevention Campaign will be deemed acceptable. It also raises questions as to whether current best practices that go above and beyond these principles meet NEP requirements.
As previously reported, OSHA issued the first NEP addressing outdoor and indoor heat-related hazards to further focus on heat-related hazards. Under the NEP, each OSHA Region is expected to have a fiscal year goal of increasing their heat inspections by 100% above the baseline of the average of fiscal years 2017 through 2021. Given the potential for aggressive enforcement under the NEP, AGC is demanding that the agency provide clear guidance to ensure consistent enforcement across OSHA, while also allowing AGC to provide the necessary resources to contractor members to protect workers and avoid citations.