OSHA’s federal heat standard has stalled, but enforcement of existing state and national rules is intensifying. Discover exactly how to keep your employees safe and your business compliant.
Safety and Security May 29, 2026
OSHA Heat Regulations: What Employers Need to Know [2026 + Checklist]
Heat Safety Checklist
Safeguard your employees from the effects of dangerously high temperatures.
OSHA’s proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings rule remains unfinished, with no firm finalization date on the horizon.
But while the federal rule remains stalled, there are still extensive requirements for protecting 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 outdoors or in areas without adequate 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, spoke 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 reality 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 can exacerbate it. This is why the Occupational Safety and Health Administration’s indoor temperature regulations are included in the broader OSHA temperature regulations.
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Safeguard your employees from the effects of dangerously high temperatures.
Breaking Down OSHA’s Heat Rules (+ Current Heat Regulations and Recommendations)
Heat-related workplace stress has high financial and health costs for both businesses and employees. Historically, 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 worker safety]. It is also working on a permanent standard with more specific requirements for employers. But in the meantime, OSHA’s National Emphasis Program… sends inspectors into the field and into workplaces to ensure 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
Note: OSHA’s original Heat National Emphasis Program (NEP) expired in April 2026 and was replaced by a revised, expanded NEP running through April 2031.
However, the new OSHA rules would create specific heat safety and preparedness requirements. If finalized, the proposed rule would apply to all outdoor workers and indoor workers where the combined temperature and humidity exceed 80 degrees.
Current status as of May 2026
OSHA’s federal Heat Injury and Illness Prevention Standard has stalled. The NPRM was published on August 30, 2024, public hearings concluded by late 2025, and the post-hearing comment period closed on October 30, 2025—but no finalization date has been set, and the rule is not a current administration priority. Employers should not plan around an imminent federal standard.
What has changed is enforcement. OSHA’s original Heat National Emphasis Program expired April 8, 2026, and was replaced two days later with a revised, expanded NEP effective through April 2031. The updated NEP uses BLS injury data from 2022–2025 to target 55 high-risk industries (see the list below). Heat inspections have increased from roughly 200 per year to approximately 2,400 per year—now accounting for about 6% of all OSHA inspections. Even without a final rule, the enforcement risk is at an all-time high.
On the legislative front, the Asunción Valdivia Heat Illness and Fatality Prevention Act has been introduced in Congress, which would mandate a permanent federal heat standard—but its passage remains uncertain. Until then, OSHA continues enforcing heat safety through the revised NEP and the General Duty Clause.
What the proposed OSHA rule would require
Here are the new requirements that would be introduced if this proposal is finalized. You can read the full details and exemptions in the unofficial text of the proposal here.
- Employers must have a heat injury and illness prevention plan
- Employers must identify and monitor heat hazards
- If temperatures rise to or above the threshold (80 degrees), the following controls must be implemented
- Drinking water
- Break areas with shade or air conditioning
- Fans, air conditioning, or heat exposure reduction
- Acclimatization for new or returning workers
- Rest breaks
- Effective, two-way communication with employees
- Cooling PPE
- Additional controls are implemented at the high heat trigger of 90 degrees, including:
- Additional paid rest breaks
- Mandatory observation for signs and symptoms of heat illness
- Heat hazard alerts with critical information
- Employers must develop and implement heat illness and emergency response plans
- 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.
- 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 offer a preview of what federal regulations could include if finalized. 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 monitor workplace heat. According to the National Weather Service, WGBT measures the impact of heat in direct sunlight, accounting for temperature, humidity, wind speed, sun angle, and cloud cover. WBGT monitoring is expected to be a component of any finalized federal regulation. 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 considers 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 prevent heat-related illnesses and fatalities is a natural fit. Certain types of PPE can also increase the risk of overheating, so any finalized regulations would likely address the balance between protection from other hazards and temperature-related dangers.
How OSHA’s 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 represents employers in regulatory issues and OSHA citations.
These proposed requirements reflect where federal enforcement is heading. In the meantime, there are steps you can take now to protect your employees and remain compliant with current regulations.
OSHA’s current heat requirements
OSHA points to NIOSH’s Recommended Heat Standard as guidance for heat safety standards, and its revised 2026 National Emphasis Program enables it to conduct proactive facility inspections across 55 targeted industries.
State-level heat safety standards—2026 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 compliance with separate indoor and outdoor requirements.
- 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 are 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 indoors and outdoors at a heat index ≥80°F, requires mandatory rest breaks at higher temperatures, and includes 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: HB25-1286, which would have required employers to implement protections against heat and cold stress, was postponed indefinitely in committee in March 2025. Sponsors have indicated plans to reintroduce the legislation.
- New York: While specific statewide regulations are pending, the state has launched initiatives to protect workers from extreme heat, including the development of interactive heat risk tools and employer guidelines.
Beat workplace heat and its effect on your employees with this detailed checklist.
California’s heat safety standards now cover both indoor and outdoor work environments. According to the new standards, all indoor workplaces where the temperature reaches 82 degrees Fahrenheit or higher must comply with regulations on access to water, cool-down areas, acclimatization, training, and more.
Start by Assessing Employees’ Level of Risk from Environmental Heat Stress
Building this plan now prepares you for state enforcement requirements today and any federal standards that may follow. 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 complex standards can make enforcing heat safety feel somewhat 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 on-site 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 it identifies, 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 respond 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. Building this plan now prepares you for the state requirements already in effect and any federal standards that may follow.
Here are six areas to focus on when establishing heat safety plans and protocols.
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
- Provide cooling systems, such as air conditioning and fans, 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.
- Apply a hierarchy of controls: Prioritize engineering solutions (cooling systems, ventilation, shade) first, then administrative controls (scheduling, rotation), and PPE as a last resort. OSHA guidance and several state standards, including Nevada’s, explicitly require this sequencing.
- Use powered equipment, such as 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.
- Ensure workers understand the early signs of heat-related illness and establish clear action plans for reporting 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 potential complications, such as 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 heat 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 that is 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 and light, loose-fitting materials.
- In outdoor settings, provide sunscreen and give employees the option to wear hats, provided 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 current state requirements—and position your organization to comply quickly if a federal standard is finalized.
- 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, and provide 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.
- Know your state’s current requirements. Nevada (April 2025), Maryland (September 2024), and California (July 2024) have all enacted heat standards that are actively enforced—with more states expected to act ahead of any federal rule.
Frequently Asked Questions About OSHA Heat Regulations
- Does OSHA currently have a specific heat standard? Not yet at the federal level. OSHA's Heat Injury and Illness Prevention Standard is still in the rulemaking process—the NPRM was published in August 2024, public hearings concluded by late 2025, and the post-hearing comment period closed October 30, 2025—but no finalization date has been set and the rule is not a current administration priority. In the meantime, OSHA enforces heat safety using two existing mechanisms: the General Duty Clause and the National Emphasis Program (NEP).
- What is the General Duty Clause, and how does it apply to heat? Section 5(a)(1) of the OSH Act requires employers to provide a workplace "free from recognized hazards that are causing or are likely to cause death or serious physical harm." Heat is a recognized hazard, and OSHA has used the General Duty Clause to issue heat citations even without a specific heat standard. If an inspector determines your workers are exposed to heat stress without adequate controls, a citation can follow—regardless of whether a formal heat rule exists.
- Which industries are high-risk under OSHA's heat NEP? OSHA's NEP targets industries where workers face elevated heat exposure: construction, agriculture, manufacturing, landscaping, warehousing, food processing, utilities, and transportation. If your organization operates in one of these sectors, proactive OSHA inspections are more likely—particularly during heat waves or on heat priority days.
- What are heat priority days, and what happens during them? Heat priority days are days when the National Weather Service issues a heat advisory, watch, or warning for a given area. On these days, OSHA and its state partners increase inspection activity and outreach. Employers in high-risk industries should treat any NWS heat advisory as a signal to activate their heat illness prevention plan and ensure all controls are in place.
- What happens during an OSHA heat inspection, and what is a hazard alert letter? OSHA conducts both programmed inspections (scheduled, targeting high-risk industries) and unprogrammed inspections (triggered by worker complaints, referrals, or fatalities). Inspectors evaluate whether employers have adequate heat controls in place—water, shade or cooling areas, rest breaks, acclimatization plans, and training. If an inspector identifies heat-related hazards but doesn't issue a formal citation, they may issue a hazard alert letter—a formal notice that violations were observed and that the employer is expected to correct them. A hazard alert letter is not a citation, but it signals elevated scrutiny and potential enforcement action if hazards go unaddressed.
- What are the indoor heat requirements under current OSHA guidance? There is no finalized federal indoor heat standard yet, though the NPRM would apply to indoor workplaces when heat and humidity conditions create risk above 80°F. Several states have acted ahead of federal rulemaking: California's indoor heat standard triggers at 82°F; Oregon and Maryland apply their rules at a heat index of 80°F indoors; and Minnesota regulates indoor workplaces using WBGT-based temperature thresholds tied to task intensity. Employers in these states must ensure separate indoor and outdoor work compliance programs.
- What is OSHA's guidance on using fans for heat control? Fans can help reduce heat stress by improving air circulation, but OSHA cautions that fans alone are insufficient—and can be counterproductive—when ambient temperatures exceed body temperature (approximately 95–99°F). At those levels, moving hot air across the skin accelerates heat gain rather than cooling. OSHA recommends fans be used alongside other engineering controls such as air conditioning, evaporative coolers, or misting systems, not as a standalone solution.
- Can OSHA issue heat-related citations today, before a final rule exists? Yes. OSHA has already issued heat citations under the General Duty Clause and has conducted thousands of NEP heat inspections resulting in hazard alert letters and formal citations. Employers don't need to wait for a final standard to face enforcement consequences—the current NEP and General Duty Clause create real liability now, particularly in high-risk industries during peak heat season.
Plan Ahead to Implement OSHA Recommendations for Heat Safety
Environmental conditions are beyond your control, and in many industries, working in high temperatures is unavoidable. That’s why your company needs a heat illness prevention plan grounded in current enforcement realities—to keep your business running without sacrificing your employees’ well-being.
Given the increasing risk and high cost of heat-related incidents, the question is no longer whether heat enforcement is coming—it’s already here. The revised NEP, active state standards, and the General Duty Clause create real compliance obligations today. Whether you’re starting from scratch or refining existing 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.
Download Our Heat Safety Checklist
Safeguard your employees from the effects of dangerously high temperatures.
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