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Safety and Security Jun 13, 2025

What Are the New OSHA Heat Regulations? + How to Prepare

OSHA’s federal heat standard is nearing completion, and enforcement of existing state and national rules is intensifying. Discover exactly how to keep your employees safe and your business compliant.

Heat Safety Checklist
Safeguard your employees from the effects of dangerously high temperatures.
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Heat safety is getting closer to a formal OSHA standard, with the agency recently releasing the unofficial version of their proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings rule.

But while we wait for the official version to pass, there are still extensive requirements for how you need to protect your employees. Learn all about how to stay heat-safe and OSHA-compliant.

Heat is a top concern for all businesses, but it’s particularly important for those with employees working outside or in areas without sufficient cooling measures. Global temperatures have risen at record-breaking rates. Protecting your employees from the dangers of extreme heat is a growing concern that will, unfortunately, not lessen in the near future.

Paul Yura, Warning Coordination Meteorologist at the National Weather Service, talked with us on The Employee Safety Podcast all about extreme heat. “What we’re seeing [looking into the future of extreme heat] is what we’re going to get, if not worse, because of climate change,” he told us. “Businesses have to get ahead of this right now because it’s not going to reverse itself any time soon.”

Hot environments are a daily fact of life in many workplaces. Researchers found that outdoor workers in the U.S. face up to 35 times the risk of dying from heat exposure compared to the average American.
But employees in indoor work settings also risk exposure to high heat—facilities such as warehouses and factories rarely have air conditioning, and equipment like furnaces and ovens exacerbate high temperatures. This is the reason for the OSHA indoor temperature regulations included in the larger OSHA temperature regulations.

Beat workplace heat and its effect on your employees with this detailed checklist.

Breaking Down the New OSHA Heat Rules (+ Current Heat Regulations and Recommendations)

Heat-related stress in the workplace has high financial and health costs for both businesses and employees. Until this recent ruling proposal, they’ve relied on the General Duty Clause when issuing heat-related citations.

“Heat is a recognized hazard by OSHA, and it’s been using the General Duty Clause traditionally [to enforce safety]. It is also working on a permanent standard with more specifics as to what employers have to do. But in the meantime, OSHA has come out with a national emphasis program. It’s a three-year program in which OSHA is devoting a big part of its resources to sending its inspectors into the field and into workplaces, showing up and ensuring that employees who might be exposed to heat illness are being protected.”

—Courtney Malveaux, Co-Leader of the Workplace Safety and Health Practice Group at Jackson Lewis

However, the new OSHA rules would create specific heat safety and preparedness requirements. While the specific language is still subject to change, the new OSHA temperature regulations would apply to all outdoor workers and indoor workers where combined temperature and humidity levels rise above 80 degrees.


Current status as of June 2025

OSHA’s federal Heat Illness Prevention Standard remains in the proposal stage, published as a Notice of Proposed Rulemaking (NPRM) on August 30, 2024. Public comments closed January 14, 2025, and informal hearings are scheduled through July 2, 2025. While no final rule or enforcement date has yet been announced, OSHA anticipates finalizing this regulation in late 2025 or early 2026, followed by a 150-day phase-in period. Until then, OSHA continues enforcing heat safety through its existing National Emphasis Program (NEP) and General Duty Clause.

Federal enforcement priorities for heat

Even without a finalized federal heat standard, OSHA’s commitment to heat safety has intensified. OSHA recently extended its Heat-Related Hazards National Emphasis Program (NEP) through April 2026. Under the NEP, OSHA proactively inspects high-risk industries, particularly during heat waves. Employers may face citations under OSHA’s General Duty Clause if inspectors find insufficient protections against heat-related hazards. To date, OSHA has conducted thousands of NEP heat inspections, issued hazard alert letters, and intensified efforts, particularly on days with extreme heat.


What will be required under the new OSHA rule?

Here are the new requirements that would be introduced when this proposal is accepted. You can read the full details and exemptions in the unofficial text of the proposal here.

  1. Employers must have a heat injury and illness prevention plan
  2. Employers must identify and monitor heat hazards
  3. If temperatures rise to or above threshold (80 degrees), the following controls must be implemented
    1. Drinking water
    2. Break areas with shade or air conditioning
    3. Fans, air conditioning, or heat exposure reduction
    4. Acclimatization for new or returning workers
    5. Rest breaks
    6. Effective, two-way communication with employees
    7. Cooling PPE
  4. Additional controls are implemented at the high heat trigger of 90 degrees, including:
    1. Additional paid rest breaks
    2. Mandatory observation for signs and symptoms of heat illness
    3. Heat hazard alerts with critical information
  5. Employers must develop and implement heat illness and emergency response plans
  6. Employers must train their employees on heat stress hazards, heat-related injuries and illnesses, including risk factors, signs, and symptoms, as well as heat safety and company-specific policies and resources. Supervisors also have specific training requirements.
  7. Employers must maintain accurate and comprehensive records

What these requirements mean

Illness reporting: Injuries like a broken finger are easy to identify, but heat-related illnesses vary widely in symptoms and severity. Detailed reporting—including conditions like heat stroke and heat exhaustion—will help refine the rulemaking process over time. Additionally, more extensive reporting is expected to help address the disproportionate effect of heat hazards on people of color and economically disadvantaged groups.

Prevention and training programs: Existing state regulations are a possible clue of what federal regulations will include. For example, California’s training requirements for both employees and supervisors are a potential model for what companies will need to offer in the future.

Environmental monitoring: OSHA currently recommends using wet bulb globe temperature (WBGT) devices to track workplace heat. According to the National Weather Service, WGBT measures the impact of heat in direct sunlight, taking into account temperature, humidity, wind speed, sun angle, and cloud cover. It’s a safe bet that WBGT monitoring will be a component of the upcoming regulations. Some industry groups have suggested the use of a heat index for environmental monitoring. However, OSHA has traditionally shied away from that metric because it takes into account fewer variables than WBGT monitoring.

Engineering and administrative controls: Engineering controls vary widely by setting—what applies to a bakery wouldn’t make any sense for a landscaping company. However, there are many contextual and situational engineering requirements that could end up in the final regulations based on industry, company size, and workplace circumstances. Additionally, administrative procedures are likely to be a key component of the rules.

Personal protective equipment: OSHA already regulates PPE from a variety of other safety perspectives. Extending those rules to the prevention of heat-related illnesses and fatalities is a natural fit. Certain types of PPE can also increase the risk of overheating, so regulations will likely address balancing protection from other hazards against temperature-related dangers.

Courtney Malveaux, Jackson Lewis
How OSHA’s New Heat Hazard Program Affects Organizations
Learn how OSHA's extreme heat National Emphasis Program might affect your organization from Courtney Malveaux, a former labor commissioner who currently represents employers in regulatory issues and OSHA citations.
Listen Here

These requirements will make huge advancements in protecting employees from the hazards of working in extreme heat conditions. In the meantime, there are things you can do right now to protect your employees, stay compliant with current regulations, and prepare your business for compliance under these new rules.

OSHA’s current heat requirements

OSHA points to NIOSH’s Recommended Heat Standard as guidance for heat safety standards, and the recently established national emphasis program enables it to perform more proactive facility inspections.

State-level heat safety standards — 2025 updates:

  • California: As of July 2024, California added an indoor heat illness standard (trigger at 82°F), alongside its existing outdoor rules (trigger at 80°F, enhanced measures at 95°F). Employers must ensure separate indoor and outdoor compliance.
  • Washington: Revised its outdoor heat rule (2023) with year-round application, lower temperature triggers (80°F), mandatory paid breaks at higher temperatures, acclimatization, and buddy-system requirements.
  • Minnesota: Indoor workplaces regulated by WBGT-based temperature thresholds, requiring controls if heat stress exceeds specified levels based on task intensity.
  • Oregon: Comprehensive rules (2022) for indoor/outdoor workplaces when the heat index reaches 80°F (enhanced protections above 90°F).
  • Maryland: New standard effective September 2024; applies indoor/outdoor at heat index ≥80°F, mandatory rest breaks at higher temperatures, and specific acclimatization protocols.
  • Nevada: New rule enforcement started in April 2025 requires Job Hazard Analysis (JHA), written heat safety programs, monitoring, training, and a hierarchy of controls.
  • Colorado: Introduced in 2025, Colorado’s proposed legislation aims to protect workers from extreme temperatures. The bill outlines requirements for employers to implement measures that mitigate heat-related risks.
  • New York: While specific statewide regulations are pending, New York has launched initiatives to protect workers from extreme heat, including the development of interactive heat risk tools and guidelines for employers.

California’s heat safety and heat illness prevention standards have recently been updated to include indoor heat safety as well as outdoor. According to the new standards, all indoor places of employment where the temperature reaches 82 degrees Fahrenheit or above must comply with regulations around access to water, cool-down areas, acclimatization, training, and more.

Firefighters drinking water in the heat

Start by Assessing Employees’ Level of Risk from Environmental Heat Stress

The release of OSHA’s heat regulations is still pending, but it’s never too soon to work on building a safer work environment. As with any work-related hazard, prevention starts with understanding your level of exposure to risks.

There are countless variables that contribute to heat-related illnesses, such as an individual’s age, health, and diet. Conditions that are dangerous for one employee might be perfectly safe for others. Balancing duty of care with business continuity is already difficult for many companies, and the complicated standards can make enforcing heat safety feel a bit uncertain. But there are plenty of other resources to turn to when creating your heat safety plan. Here are concrete steps you can take internally to identify and mitigate risks of heat-related illnesses.

Get an onsite consultation

One option for assessing your risks is to take advantage of OSHA’s voluntary onsite consultations. A specialist will visit your worksite to evaluate potential heat-related hazards and make recommendations on existing prevention and training measures.

The service is completely free and confidential, and they won’t issue any fines or citations. Your company will need to correct any serious hazards that they identify, but the consultation also qualifies you for a one-year exemption from OSHA inspections.

Teach heat hazard recognition

When discussing situational awareness in the workplace, hazards like a wet floor or dangerous chemicals are easy to identify. However, the same concepts apply to recognizing heat hazards, which can be more nuanced. Employees need to be aware of their surroundings and make decisions accordingly.

There are several key factors to monitor when assessing the dangers of extreme heat:

  • Environmental factors such as air temperature, sunlight, humidity, and airflow
  • Level of exertion and workload
  • Clothing or PPE that impacts the body’s ability to shed heat
  • Presence of excess heat sources like ovens or furnaces

Understand personal risk factors

Every employee at a worksite is subject to the same environment, but their bodies will each handle it differently. It’s critical for workers to understand the personal risk factors that can increase sensitivity to heat-related illnesses:

  • Body weight, especially obesity
  • Diabetes, high blood pressure, and other chronic health conditions
  • General physical fitness level
  • Medications that impact hydration or sweating
  • Overall alcohol intake
  • Illicit drugs that affect the body’s metabolism

Establish a Heat Illness Prevention Plan to Protect Employees

When it comes to heat hazards, there are a variety of risk factors to monitor, environmental conditions may change rapidly, and it can be challenging to spot early signs of illness. Building heat-related illness prevention into your workplace safety policy is integral to ensuring your employees engage in safe work practices. And building this plan now will help ease the transition when the official ruling is passed.

Here are six areas to focus on when establishing plans and protocols for heat safety.

1. Hydration and rest breaks

  • Develop a mandatory break schedule and increase the frequency as the risk of heat-related illness rises
  • Set up easily accessible hydration stations with enough drinking water for each employee to consume one quart per hour
  • Provide sports drinks, ice pops, and hydration supplements
  • Make first aid kits available throughout worksites, and regularly check that they’re fully stocked

2. Engineering controls

  • Make cooling systems such as air conditioning and fans available wherever possible
  • Install insulation around heat sources and use reflective shields to redirect radiant heat
  • Improve ventilation and airflow wherever possible to encourage heat dissipation
  • Leverage powered equipment like conveyors and forklifts to reduce employee workload and physical exertion
  • At outdoor worksites, set up ample shade and misters for employees to cool off during breaks
  • Use a wet bulb globe temperature device to monitor environmental conditions

3. Training

  • Train all employees on precautions to take and heat safety tips to follow in hot environments as well as how to adjust to changing conditions
  • Make sure workers understand the early signs of heat-related illness and set clear action plans for how to report symptoms
  • Provide first aid classes, instructions on how to treat heat-related illnesses, and guidance on when to seek emergency medical care
  • Discuss contingency plans for possible complications like unseasonably warm temperatures, power outages, and broken cooling systems
  • Include heat hazard planning in monthly safety meetings during warmer months to serve as a refresher for employees

4. New workers and acclimatization

  • Ensure new workers have clothing that is well-ventilated and allows excess body heat to dissipate
  • Follow acclimatization guidelines by restricting new workers to no more than 20% of a shift at full intensity, increasing by 20% each day until they’re comfortable with the conditions
  • Pair newer workers with experienced employees who can help them understand the work conditions and ease into the situation
  • Train supervisors to proactively monitor new hires and ensure they’re taking frequent breaks, hydrating, and following your company’s heat policies

5. Work practices

  • Create an inclement weather policy that includes contingencies for extreme heat
  • When possible, schedule work during cooler parts of the day, such as early morning
  • Set a maximum temperature for work as appropriate for your environmental conditions
  • Rotate high-effort job functions among workers to minimize exertion and workload
  • Use an employee safety monitoring platform to communicate weather conditions and give employees a way to report issues or illnesses in real time

6. Personal protective equipment

  • Identify how PPE increases heat hazards and factor that into your plans to monitor conditions
  • Encourage the use of reflective clothing, as well as light and loose-fitting materials
  • In outdoor settings, provide sunscreen and give employees the option to wear hats as long as they don’t conflict with other PPE guidelines
  • Provide cooling neck wraps and jackets or vests with built-in ice packs to help reduce body temperature

What Employers Should Do Now

  • Review and update heat illness prevention plans to align with new state regulations and prepare for upcoming federal requirements.
  • Monitor temperatures actively using WBGT devices or heat index apps; implement safety measures proactively at triggers like 80°F and heightened measures at 90°F.
  • Implement acclimatization plans for new or returning employees, providing close monitoring during initial heat exposure periods.
  • Enhance employee training annually, emphasizing heat illness recognition, prevention strategies, and emergency response procedures.
  • Prepare proactively for OSHA inspections, particularly in construction, agriculture, manufacturing, landscaping, and warehouse industries, which are targeted by OSHA’s NEP.
  • Track regulatory deadlines closely. Immediate compliance is needed in Nevada and Maryland, and California’s new indoor rules were also recently effective.

Plan Ahead to Implement OSHA Recommendations for Heat Safety

Environmental conditions are outside of your control, and for many industries, working in high temperatures is unavoidable. That’s why your company needs a heat illness prevention plan based on OSHA upcoming requirements for heat safety—to keep your business running without sacrificing your employees’ well-being.

Given the increasing risk and high cost of heat-related incidents to your business and your people, the anticipation for OSHA’s new regulations is palpable. The forthcoming regulations will help shape and refine your heat illness prevention plan, but starting the process now gives you a head start. Whether you’re starting from scratch or refining existing heat hazard policies, your employees’ health and safety depend on robust prevention, training, and response plans.

With proper foresight, your employees can stay cool on even the hottest days and happily return to the comfort of their air-conditioned homes after a hard day’s work.

Heat Safety Checklist

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