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Comments to OSHA on Heat Injury and Illness Prevention at Work

We filed joint comments to the Department of Labor’s Occupational Safety and Health Administration (“OSHA”) in response to its advance notice of proposed rulemaking Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. We advised that OSHA develop a heat standard that will be robust to climate impacts, provided recommendations on costs and benefits to consider in the economic analysis for the rule, and encouraged OSHA to use other facets of its statutory authority to complement its rulemaking efforts. In designing the standard, OSHA should consider comprehensive data relevant to addressing heat-related occupational risks, including data on climate change and distributional inequities.