Implementing High-Heat Procedures for Outdoor Workers

Under the outdoor heat illness prevention standard only, employers in specified industries must implement high-heat procedures when the temperature equals or exceeds 95 F.1

The industries subject to the high-heat procedures include:

  • Agriculture;
  • Construction;
  • Landscaping;
  • Oil and gas extraction; and
  • Transportation and delivery of agricultural products, construction materials or other heavy materials, except for employees operating an air-conditioned vehicle and not performing loading or unloading duties.

These high-heat procedures must include the following, to the extent practicable:

  1. Ensuring that effective communication by voice, observation or electronic means is maintained so that employees at the worksite can contact a supervisor when necessary. An electronic device, such as a cell phone or text messaging device, may be used for this purpose only if reception in the area is reliable.
  2. Observing employees for alertness and signs or symptoms of heat illness. Under the revised standard, employers are required to ensure effective employee observation and monitoring of heat illness signs or symptoms. Whichever method is used, the employer must be able to ascertain the employees’ condition at regular intervals, according to the guidelines. Under the regulations, the employer must implement one or more of the following:
    • Direct observation of 20 or fewer employees by a supervisor/designee.
    • Mandatory buddy system.
    • Regular communication with employees working alone.
    • Other effective means of observation.
  3. Designating one or more employees on each worksite as authorized to call for emergency medical services, and allowing other employees to call for emergency services when no designated employee is available.
  4. Reminding employees throughout the work shift to drink plenty of water.
  5. Holding pre-shift meetings to review high heat procedures, encourage employees to drink plenty of water and remind employees of their right to take a cool-down rest when necessary. According to the guidance, the meetings are meant to briefly remind supervisors and employees of the high-heat procedures, not to review every element covered in the training. Topics to be covered include staying hydrated, taking cool-down rests, and identifying employees who should call for emergency medical services, and how employees will be observed.

Agriculture Employers

For employees in the agriculture industry, when temperatures reach 95 F or above, the employer must ensure that the employee takes a minimum 10-minute preventative cool-down rest period every two hours.2

The regulations and Cal/OSHA guidance provide as follows:

  • The preventative cool-down rest period may be provided concurrently with any other meal or rest period required by IWC Wage Order No. 14, thus resulting in no additional preventative cool-down rest period required in an eight-hour workday. In other words, during the first eight hours of a shift, the cool-down periods may be provided at the same time as the rest periods already required.
  • If the workday will extend beyond eight hours, an additional preventative cool-down rest period will be required at the conclusion of the eighth hour.
  • If the workday extends beyond 10 hours, then another preventative cool-down rest period will be required at the conclusion of the 10th hour and so on. Preventative cool-down rest period has the same meaning as “recovery period” in Labor Code section 226.7.
  • The regulations specifically use the word “ensure.” According to the guidance, merely offering the opportunity for a break is not enough. Employers must ensure that employees actually take the required cool-down rest periods.
  • Employers are required to provide the additional breaks as soon as temperatures reach or exceed 95 F. For instance, if the temperature hits 95 F in the last half hour of an eight-hour shift and the shift will last more than eight hours, the employer must ensure the employees take cool-down rest periods starting at the end of the eighth hour of work.

While records of these rest periods are not mandated, Cal/OSHA considers recordkeeping a best practice.


The high heat procedures described above apply under the outdoor heat illness prevention standard only, not the indoor heat standard.


1. 8 CCR sec. 3395(a)(2)

2. 8 CCR sec. 3395 (e)(6)