ILMA Testifies on OSHA’s Heat Injury and Illness Rule
On Monday, ILMA CEO Holly Alfano and Regulatory Counsel Jorge Roman raised concerns before the Occupational Safety and Health Administration (OSHA) about its overly broad proposed heat injury and illness standard.
The proposed rule, published in August 2024, would impose significant regulatory burdens on lubricant manufacturers—from the installation of on-site temperature monitoring devices to highly prescriptive requirements for air movement or air conditioning. After highlighting the value of the lubricants industry, Alfano pointed out that OSHA failed to consider the proposal’s disproportionate impacts on small businesses.
“We believe that OSHA should withdraw the proposed rule. OSHA failed to adequately consider the extensive concerns provided during the SBREFA process regarding the inflexibility of the proposed requirements. While OSHA did address some of the small entity recordkeeping issues, it fails to provide a performance-based approach that would allow employers to tailor heat stress prevention programs beyond what they currently have in place based on their unique work environments, employee needs, and geographic differences.”
In his testimony, Roman outlined three key policy and legal concerns with the proposal:
- OSHA has not provided substantial evidence that heat-related stress poses a significant risk warranting federal intervention under such a blanket approach—particularly for the lubricants industry.
- If regulatory efforts continue, OSHA must go back to the drawing board and assess risk on a granular basis, rather than relying on unsupported assumptions to fill data gaps.
- The proposed rule fails to account for the unique conditions of indoor facilities like lubricant manufacturing plants, creating unnecessary compliance burdens and diverting focus from critical occupational safety priorities.
Alfano expressed a willingness to collaborate with OSHA on non-regulatory solutions to address any real risks from heat stress.
“We have a long-standing history of meaningful collaboration with OSHA. While our formal Alliance concluded in 2011, that partnership produced several important tools that continue to benefit our industry and improve workplace safety,” said Alfano.
“We are ready to work with OSHA to develop targeted educational materials and best practices focused on heat illness prevention—tailored to the actual working conditions in our industry,” she added.