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Comments on NIOSH’s Latest Criteria for a Recommended Heat Stress Standard and Letter to OSHA Imploring Their Adoption Within a Federal Standard

February 25, 2014

View the comments submitted to NIOSH.

View the letter sent to OSHA.

From 1992 to 2012 (the most recent year for which federal data are available), at least 655 workers have died and 53,564 have been severely injured by heat stress injuries. Public Citizen applauds the latest evidence-based draft criteria for a recommended heat stress standard issued by the National Institute for Occupational Safety and Health (NIOSH). We also urge the Occupational Safety and Health Administration (OSHA) to adopt NIOSH’s latest criteria recommendations on heat stress, once finalized, as the basis for a federal heat stress standard.

View the response to our letter from OSHA head Dr. David Michaels.

*NOTE: In his response, Dr. David Michaels pointed out that OSHA did, in fact, issue 21 citations to employers for violations of the General Duty Standard for heat stress-related violations from May 1, 2012 to February 18, 2014. In our letter to OSHA and comments to NIOSH, we stated that OSHA had not issued a single citation for heat stress-related violations between June 2012 and February 2014. This discrepancy is due to the use of two different search strategies of OSHA’s General Duty Standard inspection database ( Our strategy did not take into account an apparent lag, of up to two years, in OSHA’s classification of heat stress violations to the relevant category (“Heat”) on the publicly available website. Going forward, we will use the more expansive search criteria, apparently employed by OSHA, in order to account for this apparent delay.

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