Indoor heat: measure and record under 3396
The 82 F program, the 87 F control measures, and the measurement records you have to keep for a year.
California T8 3396 applies to indoor places of employment and has two tiers. At 82 F you owe a cool-down area, water, a written indoor heat illness prevention plan, training, and emergency response. At a heat index of 87 F you owe assessment and control, with engineering controls first. The clothing and radiant heat clause pulls the control obligation down to 82 F, and measurement records have to be kept for twelve months.
Takeaways
- Say what is owed at 82 F and what changes at heat index 87 F.
- Apply the clothing and radiant heat clause that lowers the control trigger.
- Order controls correctly: engineering, then administrative, then equipment.
- Keep the measurement records the rule requires for twelve months.
The two tiers
The clothing and radiant heat clause
The control hierarchy, in order
What to measure and how long to keep it
The written indoor plan
Frequently asked questions
- Does 3396 apply to every indoor workplace in California? It applies to indoor places of employment where the temperature reaches 82 F, with limited exceptions including certain emergency operations and some incidental exposure. Most warehouses, kitchens, and manufacturing floors are covered.
- Is the cool-down area the same as shade? It serves the same purpose but the specification differs. Indoors the cool-down area has to be kept below 82 F, which usually means a mechanically cooled space rather than just a shaded one.
- How often do I have to measure? The rule does not set a fixed interval. Measure when the control obligation applies, and often enough to describe the actual conditions employees worked in. Once at the hottest part of the shift is a common practical minimum.
- Do I need a separate indoor plan if I already have an outdoor HIIP? The procedures required by 3396 have to be documented. They can live in the same written program as the outdoor procedures, as long as it is clear which apply where.