OSHA Updates Heat National Emphasis Program: 55 High-Risk Industries Now Targeted for Inspections

Just days after the previous version of its Heat National Emphasis Program reached its expiration date, OSHA announced a renewed and revised version on April 10, 2026, signaling that heat-related enforcement will not only continue but intensify. The updated program sharpens the agency's focus on 55 high-risk industries and introduces clearer guidance for both inspections and citations — a development with direct implications for employers heading into summer.

For occupational health professionals and employers in construction, agriculture, manufacturing, warehousing, and other heat-exposed industries, the timing is critical. Summer heat season is approaching, and this updated enforcement framework means OSHA is better equipped than ever to target workplaces where heat stress poses the greatest risk.

What Is the Heat National Emphasis Program?

The Heat National Emphasis Program (NEP) is OSHA's primary enforcement tool for addressing heat-related workplace hazards. Originally issued in April 2022, the NEP directs OSHA's area offices to prioritize heat inspections and outreach in industries and regions where heat illness is most likely to occur.

Unlike a standalone occupational health standard — which OSHA has proposed but not yet finalized — the NEP operates as an enforcement directive. It tells compliance officers where to focus, when to inspect, and how to cite employers for heat-related hazards using the General Duty Clause of the OSH Act.

The program has been a significant enforcement tool since its original launch. In the years since 2022, OSHA has used it to conduct thousands of heat-related inspections across the country, issuing citations and hazard alert letters to employers who fail to protect workers from heat stress.

What Changed in the April 2026 Update

The revised NEP makes several notable changes that employers should understand:

Data-Driven Targeting of 55 High-Risk Industries

The most significant change is the use of updated data from OSHA and the Bureau of Labor Statistics covering calendar years 2022–2025 to identify 55 high-risk industries. These are industries in both indoor and outdoor work settings where heat-related illness rates are highest and where employers have received heat-related citations or hazard alert letters in recent years.

This data-driven approach means OSHA is concentrating its limited inspection resources on the industries where workers face the greatest risk — rather than casting a wide net across all workplaces.

Elimination of Numerical Inspection Goals

The revised program removes the former numerical inspection goal that was part of the original 2022 NEP. This shift suggests OSHA is moving toward a more flexible, risk-based approach to heat enforcement rather than aiming for a fixed number of inspections per year.

Reorganized Appendices

The update restructures the program's appendices into two key sections:

1. Evaluating heat programs — Guidance for compliance officers on assessing whether an employer's heat illness prevention plan meets OSHA's expectations
2. Citation guidance — Updated instructions for how and when to issue citations for heat-related violations under the General Duty Clause

This reorganization is intended to improve consistency in how OSHA offices across the country evaluate and enforce heat safety standards.

Improved Tracking and Implementation

The revised NEP includes clearer guidance to improve how OSHA tracks heat-related enforcement and outreach activities, making it easier for the agency to assess the program's effectiveness and adjust as needed.

Five-Year Duration

The updated program is effective immediately and will remain in place for five years from the effective date — extending through approximately April 2031. This gives OSHA a long runway for sustained heat enforcement, regardless of whether the proposed federal heat standard is finalized in the interim.

How OSHA Conducts Heat Inspections Under the NEP

Understanding how the NEP works in practice is essential for employers preparing their workplaces. Under the updated program:

• Heat priority days: When the National Weather Service issues a heat advisory or warning for an area, OSHA compliance officers conduct random inspections focused on heat hazards in high-risk industries within that area.
• Expanding existing inspections: If a compliance officer is already on-site for any reason and finds evidence of heat-related hazards on a heat priority day, the inspection can be expanded to include a full evaluation of the employer's heat illness prevention measures.
• Outreach and compliance assistance: Compliance officers also conduct outreach to employers on heat priority days, offering guidance on preventing heat-related illness rather than focusing solely on enforcement.

This dual approach — combining targeted enforcement with compliance assistance — aligns with OSHA's broader OSHA Cares initiative, launched in March 2026, which emphasizes a more collaborative relationship between the agency and employers.

The Occupational Health Case for Heat Prevention

Heat illness remains one of the most preventable causes of workplace injury and death. According to NIOSH, occupational heat stress is the combination of metabolic heat, environmental heat, and clothing or personal protective equipment (PPE) that results in increased heat storage within the body. When the body cannot cool itself effectively, the consequences range from heat rashes and cramps to heat exhaustion, rhabdomyolysis, and potentially fatal heat stroke.

The data underscores the urgency. The Bureau of Labor Statistics has documented dozens of heat-related workplace fatalities each year and thousands of nonfatal heat-related cases involving days away from work. Experts consistently note that official statistics likely undercount the true scope of the problem due to underreporting and misclassification of heat-related incidents.

What makes heat illness particularly dangerous from an occupational health perspective is how quickly conditions can become life-threatening — especially for workers who are not acclimatized. OSHA data shows that almost half of heat-related deaths occur on a worker's first day on the job, and over 70 percent occur during the first week. This makes acclimatization protocols a critical — and often overlooked — component of any heat illness prevention program.

What Employers Should Do Now

With the updated NEP in effect and summer approaching, employers should take concrete steps to prepare:

1. Review and Update Your Heat Illness Prevention Plan

If you have an existing plan, review it against the updated NEP's guidance. If you don't have one, now is the time to develop a written Heat Illness Prevention Plan that includes:

• Monitoring weather conditions daily and identifying heat priority days
• Providing adequate drinking water, rest breaks, and shade or cool-down areas
• Establishing work/rest schedules based on heat index levels
• Designating a supervisor or safety coordinator responsible for heat safety
• Creating emergency response procedures for heat-related illness

2. Implement Acclimatization Procedures

Given the data on first-week fatalities, acclimatization is non-negotiable. OSHA and NIOSH recommend the "Rule of 20 Percent" for new and returning workers:

• Day 1: Work only 20 percent of normal duration in the heat
• Each subsequent day: Increase by 20 percent until the worker reaches a full schedule
• Workers returning from absence of one week or more should follow the same protocol

3. Train All Workers and Supervisors

Training should cover:

• Recognizing the signs and symptoms of heat-related illness — including heat exhaustion, heat stroke, rhabdomyolysis, and heat cramps
• How to respond to a heat emergency, including when to call 911
• The importance of hydration, rest, and reporting symptoms
• How to use the OSHA-NIOSH Heat Safety Tool app to check conditions

4. Know Your High-Risk Workers

Certain workers face elevated heat risk and should be monitored more closely:

• New and temporary employees
• Workers returning from extended leave
• Workers wearing heavy PPE or non-breathable clothing
• Workers performing strenuous physical tasks
• Workers with certain medical conditions or taking medications that affect heat tolerance
• Older workers and pregnant workers

5. Use OSHA's Free Resources

OSHA provides extensive free resources for heat illness prevention, including:

• The OSHA-NIOSH Heat Safety Tool mobile app for real-time heat index calculations
• Heat illness prevention training materials and posters in multiple languages
• Free, confidential consultations through the On-Site Consultation Program for small and medium-sized businesses

6. Document Everything

Maintain records of your heat safety training, daily weather monitoring, acclimatization schedules, and any heat-related incidents. Documentation demonstrates good faith compliance and can be critical if OSHA conducts an inspection.

Looking Ahead: The NEP and the Proposed Heat Standard

The renewal of the Heat NEP takes on additional significance in the context of OSHA's proposed Heat Injury and Illness Prevention Standard, which was published in the Federal Register on August 30, 2024. If finalized, the standard would establish specific, enforceable requirements for employer heat safety programs — including trigger temperatures, mandatory rest breaks, acclimatization protocols, and written prevention plans.

Until that standard is finalized, the Heat NEP remains OSHA's primary tool for heat enforcement. The five-year duration of the updated program ensures that OSHA will have robust enforcement authority over heat hazards regardless of the timeline for the proposed standard's completion.

Employers who begin aligning their heat safety programs with both the updated NEP expectations and the proposed standard's requirements now will be best positioned for compliance — whether enforcement comes through a General Duty Clause citation under the NEP or a future standard-specific violation.

As temperatures rise and OSHA's enforcement sharpens, the message to employers is clear: heat illness prevention isn't optional, and the time to act is before the first heat wave — not after.

Sources

• US Department of Labor updates national emphasis program to protect workers from indoor, outdoor heat hazards (OSHA News Release, April 10, 2026)
• National Emphasis Program – Outdoor and Indoor Heat-Related Hazards (CPL 03-00-024, Revised April 2026) (PDF)
• Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings — Proposed Rule (89 FR 70698, Federal Register)
• OSHA Heat Illness Prevention Campaign
• OSHA Heat Illness Prevention: Addressing Heat Hazards
• OSHA: Planning and Supervision for Heat Illness Prevention
• OSHA: Protecting New Workers from Heat-Related Illness
• NIOSH: Heat Stress — Overview and Prevention
• OSHA On-Site Consultation Program
• OSHA General Duty Clause — Section 5(a)(1) of the OSH Act