Heat Hazards: OSHA Revises Enforcement Emphasis Program

This month, OSHA revised its National Emphasis Program (NEP) to protect employees from heat-related hazards in outdoor and indoor workplaces. This NEP is effective immediately and expires five years after the effective date (April 10, 2026). The original NEP was issued in April 2022.

OSHA aims to focus better on outreach, compliance assistance, and enforcement efforts in high-risk industries and promote effective prevention practices. Compliance officers will expand any inspection where there is evidence of heat-related hazards on heat priority days, and, on days when the National Weather Service issues a heat advisory or warning, compliance officers will conduct random inspections focused on heat hazards in high-risk industries.

Keep reading for the significant updates to OSHA‘s revised Heat NEP and why OSHA is focusing on heat hazards.

Significant Changes to the Heat NEP

The program now uses OSHA and BLS data from calendar years 2022–2025 to direct inspection priorities to 55 high-risk industries in indoor and outdoor work settings.

Additionally, the revised NEP:

• Removed outdated background information and references.
• Updated links.
• Revised inspection goals.
• Reorganized and added Appendix I: Evaluation of a Heat Program.
• Reorganized and added Appendix J: Citation Guidance.
• Added coding for Worksite Assistance.
• Added coding for Unprogrammed Emphasis Hazards.

Why Focus Enforcement on Heat Hazards?

The US Department of Labor’s Bureau of Labor Statistics (BLS) reports that between 2021 and 2024, exposure to environmental heat resulted in an estimated average of 3,793 days away, restricted, and transfer (DART) cases and 48 fatalities per year.

OSHA says that these statistics likely do not capture the true magnitude and prevalence of heat-related injuries, illnesses, and fatalities.

Current OSHA Heat Regulations

OSHA’s workplace safety and health regulations do not yet contain a Heat Standard. One is in progress, though, and was published in the Federal Register as a Proposed Rule on 08/30/2024. As for the current status of the rule, its extended comment period ended on 1/14/2025, and the Agency held an informal public hearing on 6/16/2025.

The proposed rule would require employers to identify indoor and outdoor heat hazards and develop a heat injury and illness prevention plan (HIIPP). In the rule, OSHA calls heat "the leading cause of death among all weather-related phenomenon in the United States."

OSHA Still Obliges Employers to Protect Employees

Currently, the only OSHA regulation that obliges employers to protect employees from heat-related hazards is the General Duty Clause of the OSH Act of 1970:

Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; shall comply with occupational safety and health standards promulgated under this Act.
Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.
Section 5(a)(1)

Protect Your Workers from Heat Hazards

Symptoms of heat-related illnesses can mimic numerous other, much less serious conditions. Do not leave your team’s safety to chance!

Lion’s Heat Illness Prevention – Supervisors course prepares supervisors to recognize and protect their teams from the effects of heat stress, heat stroke, and heat exhaustion, among other injuries and illness associated with heat.

Lion’s Heat Illness Prevention – Employees course provides initial or refresher training for employees who are at risk for heat stress, heat stroke, exhaustion, cramps, heat rash, and other injuries and illnesses associated with working in heat or humidity.

Both courses are also available in Spanish. OSHA requires employers to provide adequate, relevant safety training in a manner that employees can understand.

Tags: heat safety, osha, osha enforcement