OSHA’s Heat Program Expires

On April 8, 2022, OSHA issued a National Emphasis Program – Outdoor and Indoor Heat-Related Hazards. 

In January 2025, Douglas Park, OSHA's assistant secretary, extended the directive, saying it would remain in effect until April 8, 2026. 

It expired on April 8, 2026.

Ogletree Deakins, in an article on the topic, notes that under the NEP, "OSHA dramatically increased its focus on heat-related hazards in the workplace. The program targeted more than seventy high-risk industries—including construction, manufacturing, landscaping, restaurants, retail, and agriculture—and authorized proactive inspections whenever the heat index reached 80°F or when the National Weather Service issued a heat warning or advisory.

"The NEP also prioritized on-site responses to heat-related fatalities, complaints, referrals, and employer-reported hospitalizations. By its terms, the program required employers to demonstrate measures such as providing cool drinking water, shaded rest areas, acclimatization plans for new or returning workers, training on heat stress symptoms, and monitoring of environmental conditions."

From April 2022 until December 2024, OSHA conducted approximately 7,000 heat-related inspections. This was a "dramatic increase from the roughly 200 annual heat inspections conducted between 2015 and 2020," the firm said. "The agency issued sixty citations for violations of the Occupational Safety and Health (OSH) Act’s General Duty Clause, distributed 1,392 hazard alert letters, and reported removing nearly 1,400 employees from hazardous heat conditions."

“Allowing this program to expire at the start of heat season is both dangerous and unacceptable,” said Jessica E. Martinez, Executive Director of National COSH. “We already know what works. Water. Shade. Rest. Acclimatization. Training. These are simple, evidence-based steps. But without a standard, they are not guaranteed. They are not enforceable. When OSHA steps back, workers are left exposed to preventable harm.”

The group noted that heat is the leading cause of death among all weather-related hazards in the United States, according to the National Oceanic and Atmospheric Administration and the National Weather Service.

National COSH points to federal data from the U.S. Bureau of Labor Statistics,which shows that an average of 3,389 workers suffer heat-related injuries and illnesses serious enough to require days away from work each year.

And the group noted that between 1992 and 2021, exposure to environmental heat killed 999 workers in the United States, with dozens of fatalities continuing to occur annually, including 43 deaths in 2022 alone.

Currently, OSHA has not publicly announced any intention to extend or renew the NEP.

In addition to the NEP, OSHA proposed a notice of proposed rulemaking (NPRM) titled “Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings, on August 30, 2024.

The proposed rule would apply across general industry, construction, maritime, and agriculture and would require employers to develop substantial written heat injury and illness prevention plans, monitor workplace heat conditions, implement controls at two trigger levels (an initial heat trigger at a heat index of 80°F and a high heat trigger at 90°F), provide mandatory rest breaks, establish acclimatization protocols, and train employees and supervisors.

The law firm notes that the public comment period closed on January 14, 2025, and an extended post-hearing comment period closed on October 30, 2025. However, no further steps toward finalizing the rule have been taken since.