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Occupational SafetyEnvironmental Health and SafetyOSHA

Managing Workplace Heat Risk: OSHA Requirements for Employers

By James A. Junkin
climate change sun heat globe.jpg

Credit: leolintang / iStock / Getty Images Plus

June 22, 2026

Parts of the U.S. are already experiencing extreme heat, even before summer has begun. As temperatures increase, workplace risks of heat-related illness and fatalities are becoming increasingly difficult to ignore. With warming trends now documented across 41 states and heatwaves occurring at roughly twice the frequency seen in the 1960s, an issue that used to be limited to certain seasons is now emerging as an ongoing occupational risk. For employers, this introduces a familiar challenge in sharper focus: how to safeguard workers while remaining compliant with changing safety requirements.

Heat stress has long been part of the workplace safety agenda. What is changing is the level of scrutiny and the overall expectation that employers move beyond awareness to more consistent and structured action. OSHA’s proposed heat stress rule indicates a move from general guidance to a more defined compliance framework, with explicit requirements around monitoring, acclimatization, training, and worker protection.

For many organizations, the issue is no longer whether heat stress deserves priority, but how equipped they are to handle and control it effectively.

 

Heat Stress and its Human Cost

Heat stress develops when the body is unable to cool itself effectively to maintain a healthy temperature, leading to conditions such as dehydration, heat exhaustion, and heat stroke. In extreme cases, it can be fatal.

Outdoor workers in construction, oil & gas and utilities are the most visible risk groups, though indoor workers in environments without adequate climate control, like warehouses and manufacturing plants, are also vulnerable.

Per the Centers for Disease Control and Prevention (CDC), approximately 2,000 people die each year from heat-related illnesses. Heat is not always recorded as a contributing factor, meaning the true toll is likely higher. This underscores the consequences of insufficient protection, and why OSHA’s proposed rule seeks to establish a clearer framework for managing heat stress in the workplace.

 

Meeting Compliance Expectations

OSHA's proposed rule is designed to create a more consistent, enforceable standard for managing heat risk across sectors. At its core, the rule would require employers to take a more structured approach. That starts with regularly evaluating heat exposure. This includes temperature, along with humidity, radiant heat, and the strain of the job.

It also requires the development of a Heat Illness Prevention Plan (HIPP), clearly outlining how the organization handles hydration, rest breaks, acclimatization, and emergency procedures. Importantly, the rule also highlights that not all workers face the same level of risk. New employees or workers returning after time away are considered more vulnerable, requiring a phased approach designed to build their heat tolerance.

There is also a stronger emphasis on training and recordkeeping, ensuring that both workers and supervisors can identify early warning signs and respond effectively.

 

The Price of Inaction

While the price of compliance may be substantial (given requirements for new equipment, operational changes, or added oversight) it should be measured against the longer-term impact of failing to act. Heat-related accidents can lead to a loss in productivity, higher medical costs, and increased operational risk, specifically in high-exposure environments.

That growing operational risk is now being matched by increased regulatory attention. As of April 2026, the Occupational Safety and Health Administration (OSHA) has renewed its National Emphasis Program on heat-related hazards and broadened the scope of industries subject to inspection. There is a greater emphasis on sectors such as construction, oil and gas, utilities, manufacturing, and warehousing, along with indoor workplaces that lack effective climate control. Inspections can now be triggered during periods of extreme heat, even in the absence of a worker complaint, reinforcing the need for employers to actively evaluate and manage heat risk.

Financial enforcement is also increasing. OSHA issued more than $2 million in heat-related fines in 2024 alone, even before a formal standard is in place. As requirements become more clearly defined, employers’ procedures, training programs, and monitoring systems will face greater scrutiny.

For organizations that take a proactive approach, the benefits go well beyond compliance, supporting more consistent operations and safer working conditions wherever heat is an ongoing risk.

 

Establishing a Heat-Safe Workplace

For organizations uncertain of where they stand, a practical first step is a gap assessment, helping them understand how their current safety programs compare to the requirements of the proposed rule. This may uncover the need to invest in new equipment such as heat monitoring devices and cooling systems, as well as revising work schedules to include more frequent hydration breaks.

In practice, that often means taking a closer look at how heat risk is currently evaluated day to day. Are supervisors making consistent decisions about when to pause work or rotate crews? Is there a clear threshold for action, or does it vary by site or team? Standardizing these decision points can make a meaningful difference, particularly in large or distributed operations.

It is also important to assess how well existing processes hold up under pressure. Heat-related incidents often arise during peak demand periods, tight deadlines, or extended shifts. Planning for these conditions rather than ideal scenarios helps ensure that controls remain practical and effective in the field.

Finally, organizations must consider how expectations are communicated clearly. Even well-designed processes can fall short if workers and supervisors interpret them differently. Aligning on what “good” looks like, whether that’s when to escalate concerns, adjust workloads, or intervene early, can help close the gap between policy and practice.

 

Rethinking How Heat is Managed

Despite the potential advantages of OSHA's proposed standard, there are still obstacles that must be addressed. For example, heat tolerance varies widely between individuals. Factors like age, existing health conditions, and physical conditioning can all influence how workers are affected by high temperatures. Tailoring heat stress prevention strategies to account for these different variables can be intricate and time sensitive.

However, the overall direction is clear. Heat is becoming a more persistent workplace hazard, and expectations around how it’s managed are shifting.

At its core, this rule is about establishing safer working conditions in environments where heat cannot be eliminated. For employers, it’s a chance to take a more proactive, structured approach, protecting employees while enhancing overall operational resilience.

KEYWORDS: heat hazards heat stress

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James A. Junkin, MS, CSP, MSP, SMS, ASP, CSHO, is Chair of the Veriforce Strategic Advisory Board, and Chief Executive Officer of Mariner-Gulf Consulting & Services, LLC.

 

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