Memo to Maryland: Start Over on Workplace Heat Protections – NRDC (Natural Resources Defense Council)

November 20, 2022

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The Natural Resources Defense Council works to safeguard the earth – its people, its plants and animals, and the natural systems on which all life depends.
Maryland Occupational Safety and Health (MOSH) closed a public comment period last week on a proposed rule to protect workers from heat. The overwhelming message from unions, worker advocacy groups, and heat experts—including NRDC—is this: Start over.
“This standard is completely inadequate in protecting Maryland workers from heat-related illness or death,” said @liebman_amy. “MOSH has butchered the intent of this standard and that is simply not acceptable. We need a standard that will protect workers.”
— Migrant Clinicians Network (@tweetMCN) November 4, 2022
The current proposal is inadequate, unenforceable, and feels like a check-the-box exercise in response to a 2020 law. Our comments recommend that MOSH go back to the drawing board to thoughtfully create a science-based standard that will ensure Marylanders get home safely after working in the heat. Although anyone in an outdoor or insufficiently cooled indoor workplace can be affected by heat, more than 770,000 people in the state are employed in the most heat-vulnerable industries.
The COVID-19 pandemic has certainly challenged MOSH, just as it has every other health and safety agency in the country. However, there are plenty of resources the agency could have turned to as it drafted its proposal. These include existing standards from other states and the U.S. military, recommendations from the National Institute for Occupational Safety and Health, and, most importantly, the workers who put their bodies on the line when temperatures soar.
Elvert Barnes, Creative Commons, CC-BY-SA 2.0
We provided feedback that MOSH didn’t make a best faith effort to meaningfully engage with affected Marylanders about the proposed standard, or to listen to what they had to say. MOSH should develop a new version that takes a more collaborative approach to identify and address the challenges workers face every day in the warm season.   
Here are two of the most pressing items from NRDC’s comments to MOSH:
As written, employers have to develop and enact a heat-related illness prevention and management plan. Good, right?! Sure … except they don’t have to WRITE ANYTHING DOWN. Nothing. Nada.

MOSH: May I please see your plan?

— Juanita Constible (@JMConstible) November 6, 2022
But wait, there’s more! NRDC joined 37 other groups and 35 individuals on a letter to MOSH with many additional recommendations, which you can read here.
The health and safety threats of heat to Maryland workers are hardly new; from 2011 to 2020, an estimated 680 people missed at least one day of work in Maryland from heat-related illnesses. In fact, federal experts have been recommending an occupational heat standard since at least 1972.
But this old problem is getting worse because of fossil fuel-driven climate change, which is increasing the state’s average temperature and making heat waves longer, stronger, and more frequent. Although we urge MOSH to start over, the agency must not take another two plus years to develop a new version. Delay is deadly for Marylanders.
Maryland needs workplace heat protections in 2023 that:
Only then will MOSH have created an effective tool to protect workers from preventable heat-related illnesses, injuries, and deaths.
Heat-related health harms are entirely preventable, yet heat stress is a major occupational hazard in Maryland. Maryland workers urgently need a strong, enforceable occupational heat standard that protects their right to a safe and healthy working environment.
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