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OSHA has updated and extended its National Emphasis Program on heat hazards for workplaces in the U.S., according to an April 10 news release.
The previous NEP, originally issued in April 2022 and extended in 2025, officially expired April 8. But on April 10, OSHA issued an updated NEP that is now slated to run through 2031.
Although not an official OSHA rule, the NEP offers resources and guidance to employers while also outlining how the agency addresses heat as a hazard, including enforcement actions, when temperatures rise. The NEP highlights construction as among those industries at high-risk for heat injury and illness.
Under the new NEP, OSHA compliance officers will continue to conduct outreach and compliance assistance programs and expand any inspection where there is evidence of heat hazards on heat priority days, or when the heat index is expected to hit 80 degrees or more. Additionally, compliance officers will conduct random inspections for high-risk industries on those days.
The revision comes with extra appendices that outline the changes and formalizes procedures that were previously addressed through informal guidance, wrote Mini Kapoor, partner at Dallas-based law firm Haynes and Boone, in a JD Supra post.
Fundamentals of protecting workers remain the same, Kapoor wrote. Basics of a heat illness prevention plan include:
- Providing cool, readily accessible drinking water for employees.
- Creating access to shaded or cool areas.
- Scheduling rest breaks in those areas.
- Setting up gradual exposure protocols for new employees.
- Training and educating workers on symptoms, prevention measures and emergency response.
- Monitoring workers with buddy systems or supervisory roles to identify early signs of heat illness.
The updated NEP’s appendices further explain how OSHA inspectors can evaluate an employer’s heat illness prevention program during an inspection, which Kapoor says could be considered a compliance checklist. Further guidance clarifies when inspectors should issue citations or alert letters.
Phillip Russell, a Tampa, Florida-based OSHA lawyer with law firm Ogletree Deakins, said employers should continue to focus on their duty to protect workers.
“I think employers need to continue to just do the same things they have been doing,” he said. “Treat heat as a workplace hazard and implement appropriate and effective abatement measures.”
Inspections and rules
“Heat illness remains a serious hazard for indoor and outdoor workers, leading to preventable injuries and fatalities every year,” according to an announcement from OSHA about the update. “Ensuring that employers take the steps needed to safeguard workers is essential, and this updated program allows OSHA to better focus on outreach, compliance assistance, and enforcement efforts in high-risk industries and promote effective prevention practices.”
Notably, the emphasis program is not a standard. There is not a specific rule mandating what employers must do to protect workers from heat, though one was proposed in July 2024. That standard has yet to be officially adopted, but data shows how heat safety is still an area of increasing focus for the agency.
For example, OSHA conducted about 2,400 heat related hazard inspections a year between 2022 and 2025, according to the updated NEP, including approximately 50 heat-related fatality inspections annually. At the same time, heat-related inspections accounted for 6% of all federal OSHA inspections during the previous five years, according to the NEP. That was a considerable increase from the 0.5% share of all inspections prior to the NEP, Safety and Health Magazine reported.
