Thank you for the opportunity to provide input on the NOIRA for the Heat Illness Prevention Standard.

As the COO and Co-Founder of ProTect Athletics, and a former Athletic Equipment Manager with decades of experience on the sidelines, I strongly support DOLI’s work on this standard. Our organization is a 501(c)(3) non-profit built by professionals who have spent their careers protecting athletes at every level, from youth sports to the professional ranks.

When we talk about occupational heat hazards, it is critical that we do not overlook the athletic sector. Athletes, coaches, athletic trainers, and support staff spend hours operating in high-heat environments, often wearing heavy protective equipment. They are workers who need to be protected from exertional heat illnesses just like anyone else.

As your team drafts this standard, I urge you to include:

1. Mandatory heat acclimatization protocols: Outdoor workers and athletic staff need time to safely adjust to high-temperature exertion.
2. Clear education and empowerment: Everyone on site needs to know how to spot the early warning signs of heat exhaustion and stroke, and feel empowered to trigger an emergency action plan immediately.
3. Sector-specific rules: Recognize the unique risks of athletic environments, such as the added danger of wearing protective gear in the heat.

At ProTect Athletics, our core belief is that safety has to come first. We would welcome the opportunity to collaborate with DOLI and share our expertise in athletic safety, risk analysis, and operations management as you develop these regulations.

Thank you for everything you are doing to protect Virginians.

As a longtime operator of full-service restaurants in Virginia, I am opposed to any type of regulations or government oversight on managing the heat in restaurant environments.

It has long been known in our industry that it is hot in the kitchens at certain times. While we go to great expense to provide AC and make up air in our kitchens, there is no hiding the fact that it gets very hot at times. I believe this is a commonsense issue. If any employee gets overheated, they take a break.  They either go to the front of the house for a few minutes to cool down or go in one of the many walk-in coolers they have full access to in order to cool down quickly. We don't need the govt to regulate this....it's a matter of practicality in our industry and we have been self-managing this for many years. 

I have been running restaurants in VA for 47 years and don't recall ONE incident where someone complained it was too hot in the kitchen.  It is a known fact that it gets hot in the kitchen of all restaurants and employees and managers find ways to cool down if it ever gets uncomfortable.  

Workplace safety is of paramount importance, we all agree, but regulating this is unnecessary govt overreach in my opinion.  Employees are smart enough to understand this and never has a truer statement been said: "If you can't stand the heat, get out of the kitchen!"

Please exempt restaurants from these regulations

Extreme heat is the leading cause of weather-related mortality worldwide and has been projected to intensify as climate change increases both mean temperature and humidity while amplifying the frequency and severity of heat waves across the United States. 

Assessing heat risk requires a metric that reflects the full physiological burden of heat stress. Wet Bulb Globe Temperature (WBGT) integrates air temperature, humidity, wind speed, and solar radiation into a single index. WBGT has established flag categories for risk quantification and has been adopted by numerous state high school athletic associations, the Occupational Safety and Health Administration (OSHA), the American Industrial Hygiene Association (AIHA), the American Academy of Pediatrics, and many athletic event organizers. WBGT better predicts heat-illness risk in athletes and laborers than air temperature or heat index alone.

I strongly urge the state of Virginia to adopt WBGT as the key metric to evaluate heat stress on workers and provide guidelines for work/rest periods for indoor and outdoor laborers. Adopting evidence-based WBGT guidelines will ultimately lead to better public health outcomes and allow for proper heat stress mitigation techniques to be used. This will ultimately increase worker productivity and lead to fewer lost labor hours and event cancelations due to taking an evidence-based and structured approach to preventing heat-related illness. 

Virginia has an opportunity to close a significant gap in worker protection by requiring the use of Wet Bulb Globe Temperature (WBGT) as the official metric for evaluating the impacts of heat in the workplace. I urge the Commonwealth to adopt WBGT-based thresholds as the basis for setting work/rest schedules  

This is by no means a novel or untested approach. Employers, regulators, and safety organizations across the country already rely on it. OSHA references it in guidance materials, the American Industrial Hygiene Association adopts it in creating their professional standards, and the American Academy of Pediatrics endorses it for protecting children involved in athletics. High school athletic associations in many states have built their own heat safety guidelines around WBGT’s flag-based alert system, giving Virginia’s employers an already proven, straightforward framework for workplace decision making.  

The principal justification for this adopting WBGT comes down to accuracy. Unlike air temperature readings or conventional heat index calculations, which use a limited set of inputs, WBGT incorporates four separate environmental factors at once: temperature, humidity, wind speed, and solar radiation. Because heat-related illness in the human body is a product of all of these variables taken together, as opposed to any one variable alone, WBGT outperforms these simpler metrics in analyzing actual physiological risk for people working outdoors, in a climate that continues to produce hotter and hotter weather patterns.  

It’s incredibly important to get this right. No other weather hazard kills more people in the U.S. than extreme heat, and warming temperatures, higher humidity levels, and more frequent and severe heat waves are all expected to make conditions more dangerous for Virginia’s workers in the coming years  

Aside from the direct health benefits, there’s also a strong economic justification for this metric. A uniform, evidence-based system for monitoring and limiting heat exposure helps prevent sudden workplace absences, expensive work stoppages, and reduces the chances that outdoor activities or job sites need to cease operations entirely due to unsafe heat conditions. Protecting our workers and maintaining workplace productivity are not mutually exclusive.

For all these reasons, I strongly urge that Virginia move forward with WBGT-based heat safety standards.