OSHA’s Heat National Emphasis Program (NEP), which has guided enforcement efforts around heat-related workplace hazards, is set to expire on April 8, 2026, with no formal replacement currently in place.
While this specific program is ending, it does not eliminate employer obligations to protect workers from heat-related illnesses and hazards under the General Duty Clause. Federal rulemaking on a permanent heat standard is ongoing but has not yet been finalized.
NEP, which began in April 2022, focused on identifying and reducing heat-related risks through inspections, employer education, and targeted enforcement in high-risk industries such as construction, manufacturing, and agriculture. NEP authorized inspectors to initiate inspections during heat warnings or advisories as OSHA had seen increased heat-related injuries and fatalities necessitating an immediate, proactive enforcement mechanism, rather than relying solely on post-incident investigations.
Between April 2022 and late 2024, OSHA conducted approximately 7,000 heat-related inspections, issuing sixty citations for General Duty Clause violations and distributing 1,400 hazard alert letters to employers after investigating fatalities, complaints, and referrals.
Commonly cited outdoor environments were subject to direct sun exposure and high ambient temperatures (construction, landscaping, agricultural work), outdoor warehouse loading/unloading operations and delivery drivers without climate control.
Indoor work environments are often overlooked though OSHA frequently cited indoor heat hazards when ventilation or cooling is inadequate (manufacturing plants), work locations with heat-generating equipment (furnaces, welding), commercial kitchens, warehouses without air conditioning or enclosed industrial spaces.
Employers should be aware that OSHA can still enforce heat safety requirements under the General Duty Clause, which requires employers to provide a workplace free from recognized hazards. In addition, several states, including California, Washington, and Oregon, maintain their own heat illness prevention standards that remain fully in effect.
All three states trigger requirements (shade, water) at 80°F, mandatory paid rest breaks when conditions reach 90°F+ and more frequent breaks in 100°F+ conditions. To remain compliant, employers should continue implementing heat illness prevention measures such as:
- Providing access to water, rest breaks, and shade
- Training employees and supervisors to recognize signs of heat-related illness
- Monitoring high-temperature working conditions in outdoor or high-heat environments
- Monitoring risks factors such as direct sunlight, high humidity, heavy physical labor, limited access to shade or water, poor ventilation, confined spaces, or lack of cooling systems
For additional guidance, please visit OSHA’s Heat Illness Prevention resources here: https://www.osha.gov/heat.
If you have questions about your organization’s compliance or would like assistance reviewing your policies, our HR team is available to help.
