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How OSHA and States Are Cracking Down on Workplace Heat Hazards

By Rose Morrison

Inside the OSHA Heat Stress Standard Update
    The Department of Labor proposed an OSHA heat stress standard update in August 2024. While the new rule has not yet taken effect, and the public comment period is under way. Its timeline beyond that is uncertain, but it could become law within the next couple of years.
    Details of the updated OSHA rules on heat may still change, but organizations should note the proposed standard’s key requirements. The most significant is the mandate for all employers to form a heat injury and illness prevention plan (HIIPP).
    The HIIPP includes site-specific strategies to inform workers of heat hazards, steps to mitigate them and emergency response plans. OSHA would also clarify acceptable measures to reduce heat risks. While that will help employers craft compliant protocols, it also means OSHA inspections will likely begin looking for these factors, so not implementing them can lead to regulatory concerns.

State Heat Hazard Guidelines to Note
    In addition to federal OSHA regulations for heat in the workplace, companies should be aware of state-specific guidelines. At least seven states have heat hazard laws, three of which — California, Maryland and Nevada — took effect or saw updates as recently as 2024.
    All of these require training employees to understand and avoid risks around high temperatures. Most also include steps such as:
    • Providing workers with water.
    • Providing shaded areas to cool down.
    • Mandating rest periods during extreme heat.
    • Acclimating employees to high temperatures.
    • Having an emergency response plan.
    • Having a HIIPP.

    Specific measures and which employees fall under these regulations vary by state. Consequently, employers must review their specific state’s laws to understand what compliance looks like for them. Many of these align with the proposed OSHA heat stress guidelines but may also differ, so safety managers must consider federal and state requirements.

Tips for Complying with OSHA Heat Stress Regulations
    While some rules may vary between locations and the new OSHA heat rules may change before they take effect, it’s a good time to review heat hazard protocols. Businesses can streamline compliance by following these best practices.

Write a Formal Prevention Plan
    Crafting a detailed HIIPP is the first and most crucial step. This is the foundation for the OSHA heat stress standard update and is central to many state laws. At its most basic, a HIIPP should include:
    • A benchmark for high heat.
    • Training to make workers aware of temperature-related hazards.
    • A list of site-specific heat risks.
    • Steps to address these hazards.
    • A record of responsibilities for ensuring compliance with these protocols.

    Remember that different local governments may have varying requirements for these plans and what they include. Always double-check both regional and federal standards and review the HIIPP at least once annually to ensure it’s still in line with applicable regulations.

Have Contingency Plans for Heatwaves
    Most steps within the HIIPP should cover everyday practices. However, these strategies should also include extra measures for heatwaves and other areas or moments when workplace temperatures are excessive. Longer rest periods, shorter workdays and more frequent water breaks are all worth considering in these contingency plans.
    Acclimation is another crucial aspect of heatwave safety. A slower introductory period can stave off the worst health effects by helping employees’ bodies get used to higher temperatures. Employers should halve the first day’s workload amid high heat before increasing work by 10% each day. Doing so will give teams a full workweek to acclimate to the conditions, which prevents extreme stress.

Monitor Heat Hazards
    Monitoring is another crucial aspect of state and OSHA heat guidelines. Both indoor and outdoor temperatures can fluctuate, so necessary protections may change from day to day. Conditions vary widely by specific locations — simply checking a central thermostat or weather forecast is insufficient.
    Indoor work areas near heavy equipment may get hotter than the rest of the facility, so they deserve extra attention. Similarly, outdoor sites near a lot of concrete may experience urban heat island effects, which can raise temperatures by up to 27 degrees Fahrenheit above the surrounding area. OSHA recommends using a wet bulb globe temperature monitor for comprehensive environmental readings for these scenarios.

Provide Appropriate PPE and Training
    In some cases, OSHA heat stress standards may require employers to provide personal protective equipment to counteract these hazards. Even when it is not a regulatory mandate, it’s best to supply it to workers in hot areas anyway. Going above and beyond legal codes provides assurance if things grow stricter in the future and is better for workers’ health.
    Extreme industrial environments may require heat shielding, reflective clothing and heat-resistant gloves to prevent burns. Less intense workplaces that still encounter higher temperatures may need to assign lightweight, breathable uniforms and hats. Personal cooling systems may be necessary in some cases, and shade and water, while not strictly PPE, are important, too.

Consider Implementing Wearables
    Companies with frequent workflows in high heat conditions should consider issuing wearable body temperature sensors. Several commercially available options have appeared, and studies show less than 1% of their data falls outside acceptable parameters, suggesting they’re highly accurate. Many workers also report they’re comfortable enough to wear for a whole workday.
    The key advantage of wearables is that they can alert employees when their body temperature rises too much. They can then inform their managers and take breaks as necessary to cool down before experiencing the worst effects of heat stress. These real-time interventions let workplaces account for each person’s different physiology instead of relying on general guidelines.

OSHA Rules for Heat Demand Attention
    OSHA rules for heat in the workplace are critical at any moment, but especially during the summer months. As regulatory changes come down the pipeline, safety managers must pay increased attention to the matter.
    State regulations are also worth considering and are becoming increasingly common. Heat hazard enforcement is rising across both local and federal levels, and organizations must respond.