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On May 1st, 2025, the Occupational Safety and Health Administration (OSHA) announced an extension of its current heat hazard program. Known as the National Emphasis Program on Outdoor and Indoor Heat-Related Hazards (NEP or heat hazard program), this initiative added a targeted enforcement campaign to OSHA’s existing effort to prevent heat-related illnesses. First announced in 2022, the NEP was scheduled to expire on April 8th, 2025. However, OSHA has extended that date to April 6th, 2026. Accordingly, OSHA will continue inspections of high-risk industries, specifically during heat warnings or heat advisory weather alerts. Earlier this month, OSHA released its 2024 Injury and Illness data report.
Why the Heat Hazard Program is Important
Millions of U.S. workers are exposed to heat in the workplace. Each year, thousands of these workers experience heat-related illnesses and injuries. In fact, heat-related illness is sometimes considered a common workplace hazard. A portion of those cases prove fatal. According to OSHA, 50 to 70% of outdoor fatalities occur in the first few days of working in warm or hot environments. Hazardous heat exposure can occur indoors or outdoors. Furthermore, hazardous heat exposure can happen during any season, under the right conditions, not just during heatwaves.
In addition, the heat hazard program cites the effects of climate change as a factor that makes heat-related illness prevention a pressing issue. Finally, low-wage workers and workers of color represent a disproportionate amount of the worker population regularly exposed to heat hazards.
Preventing Heat-Related Illnesses in High-Risk Industries
Specifically, the NEP targets over 70 high-risk industries, impacting both outdoor and indoor sectors. It focuses on industries where workers experience significant heat-related illnesses, like construction, agriculture, landscaping, manufacturing, retail, and warehousing. OSHA based its targeting criteria on:
- Bureau of Labor Statistics data reporting heat-related illnesses rates and the related number of employee days away from work;
- Elevated numbers of reported fatalities or hospitalizations; and
- The most significant number of heat-related general duty clause 5(a)(1) violations and Hazard Alert Letters over 5 years (1/1/2017 through 12/31/2021), or the highest number of OSHA heat inspections since 2017.
Overview of the Heat Hazard Program
In essence, the NEP is a nationwide enforcement program that allows OSHA to inspect workplaces in high-risk industries for heat hazards. OSHA will conduct proactive inspections in such workplaces before workers suffer heat-related illnesses, injuries, or fatalities. Additionally, the NEP offers outreach and compliance assistance. To that end, the heat hazard program reminds employers to protect workers from heat hazards by taking specific actions. In detail, this includes:
- providing employees access to water, rest, and shade;
- giving adequate training; and
- implementing acclimatization procedures for new or returning employees.
The NEP also establishes “heat priority days” for when the heat index is 80°F or higher. On these days, OSHA will provide compliance assistance in those high-risk industries. Finally, OSHA will conduct pre-planned inspections in specific high-risk industries on days when the National Weather Service has announced a heat warning or advisory in the area.
Employer Takeaways
In conclusion, according to its May 1 news release, OSHA claims that its review of the NEP determined the program was successful. Overall, the heat hazard program helped protect nearly 1,400 employees from ongoing exposure to hazardous heat conditions. Specifically, between April 8th, 2022, and December 29th, 2024, the agency:
- conducted approximately 7,000 heat-related inspections,
- issued 60 heat citations, and
- provided 1,392 Hazard Alert Letters to employers.
This is a significant increase compared to data collected between 2015 and 2020. Employers must be aware that OSHA will continue to inspect any alleged heat-related illnesses, injuries, complaints, or referrals, regardless of whether they occur in one of the industries targeted explicitly by the NEP. As of May 1st, 2025, the NEP to prevent heat-related illnesses remains in effect until April 6th, 2026, unless it is canceled or extended.
