Written by Adam Thomas, ARM, AINS
Senior Casualty Loss Prevention Consultant, Unison Risk Solutions
The Occupational Safety and Health Administration (OSHA) has renewed and updated its National Emphasis Program (NEP) for Outdoor and Indoor Heat-Related Hazards, reinforcing the agency’s focus on preventing heat‑related illnesses and fatalities in the workplace.
Heat illness remains a significant and largely preventable risk for both outdoor and indoor workers. OSHA’s updated directive is intended to better target industries and workplaces where heat stress hazards are most likely to occur and where injuries have historically been more severe. As warmer months approach, employers should expect increased attention to heat‑related conditions across a broad range of work environments.
Expanded and Refocused Industry Targeting
OSHA significantly revised the industries covered by the Heat‑Related Hazards NEP using recent injury, illness and enforcement data:
- 46 industries were removed
- 33 industries were retained
- 22 industries were added
As a result, 55 high‑risk industries are now subject to targeted enforcement and outreach. Appendix A of the revised NEP (Directive CPL 03‑00‑024) outlines the specific industries prioritized for inspection and compliance assistance.
Targeted sectors include construction, such as building construction, highway and bridge construction, utility systems construction and special trade contractors, as well as industries within agriculture, manufacturing, retail trade, transportation, warehousing and storage.
Updated Enforcement and Inspection Approach
Under the renewed NEP, OSHA compliance officers may:
- Conduct outreach and compliance assistance related to heat illness prevention
- Expand inspections when evidence of heat‑related hazards is identified
- Perform random, programmed inspections in high‑risk industries on days when the National Weather Service issues a heat advisory or warning
- Focus enforcement on both outdoor and indoor work environments, including warehouses, manufacturing operations and process‑heat facilities
OSHA has also updated internal inspection guidance, citation criteria and documentation procedures to promote greater consistency across inspections.
Why This Matters
Heat‑related illnesses can escalate quickly and may result in hospitalization or fatality if not properly addressed. OSHA continues to cite employers under the General Duty Clause where adequate heat illness prevention measures are not in place. With the renewed NEP:
- Inspections may occur without a complaint
- Employers may face heightened scrutiny during warm weather events
- Indoor operations should not assume they are exempt from heat‑related enforcement
Expectations Remain Clear Without a Federal Heat Standard
While there is currently no federal heat illness prevention standard, OSHA issued a proposed rule in 2024 addressing heat injury and illness prevention for outdoor and indoor work settings. Through enforcement activity and published guidance, OSHA has also made clear what it expects to see in an effective heat illness prevention program.
Several states, including California, Colorado, Maryland, Minnesota, Oregon and Washington, already require formal heat illness prevention measures. These requirements typically include:
- Access to clean drinking water
- Rest breaks and recovery periods
- Shade or cooling measures
- Acclimatization for new or returning workers
- Worker and supervisor training
Steps Employers Should Take to Prepare
Employers, especially those operating in targeted industries, should take proactive steps to reduce risk and prepare for potential inspections:
- Review and update heat illness prevention programs
- Ensure water, rest, and shade or cooling measures are readily available
- Implement or reinforce acclimatization procedures
- Train supervisors to recognize heat illness symptoms and respond quickly
- Monitor weather conditions and adjust work schedules during heat events
- Document heat‑related training, monitoring and corrective actions
Key Takeaway
OSHA’s renewed Heat‑Related Hazards NEP signals continued and increased enforcement attention on heat stress risks. Employers that take proactive steps now can reduce the risk of worker injury, avoid preventable citations and demonstrate compliance with OSHA expectations.
Our Risk Consulting team can help organizations evaluate existing heat illness prevention practices, identify gaps and strengthen programs ahead of the summer season. Connect with us today to discuss how these updates may affect your organization’s operations.
For additional guidance on managing heat stress risks and navigating evolving OSHA expectations, register for our upcoming webinar Understanding Heat Stress in the Workplace.
