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

Just two days after the previous version of OSHA's Heat National Emphasis Program (NEP) expired on April 8, the agency issued a revised and updated directive on April 10, 2026, extending its heat enforcement program for the next five years. The updated National Emphasis Program – Outdoor and Indoor Heat-Related Hazards (CPL 03-00-024) refocuses inspection priorities on 55 high-risk industries using the most recent injury and illness data available.

For employers — particularly those in construction, agriculture, manufacturing, warehousing, and food service — this means OSHA's heat enforcement program is not only continuing, but becoming more data-driven and targeted. With summer approaching, now is the time to review heat illness prevention programs and ensure your workplace is prepared.

What Changed in the Revised NEP

The original Heat NEP was launched on April 8, 2022, as part of OSHA's broader initiative to address heat-related hazards in the workplace. It was extended for one year in January 2025 by then-OSHA Assistant Secretary Douglas Parker. That extension expired on April 8, 2026, prompting concern from worker advocacy groups that the program might lapse entirely — particularly given that the proposed federal heat standard has stalled.

Instead, OSHA issued a revised version of the directive with several notable changes:

Updated Industry Targeting

The previous NEP targeted more than 70 high-risk industries. The revised version narrows the focus to 55 industries in both indoor and outdoor settings, selected using OSHA enforcement data and Bureau of Labor Statistics injury and illness data from calendar years 2022 through 2025. This data-driven approach helps direct resources to industries where heat-related incidents, citations, and hazard alert letters have been most concentrated.

Targeted industries span general industry, construction, maritime, and agriculture, and include sectors such as:

• Construction: Residential and commercial building, highway and bridge construction, utility system construction
• Agriculture: Crop production, cattle ranching, and support activities for farming
• Manufacturing: Bakeries, sawmills, glass products, metal fabrication, chemical manufacturing
• Warehousing and distribution: Warehousing and storage, grocery and wholesale distribution
• Food service and retail: Restaurants, bakeries, and retail operations with significant heat exposure

Reorganized Appendices

The revised directive introduces two reorganized appendices: one for evaluating employer heat illness prevention programs and another providing citation guidance for compliance officers. These replace the previous structure and are designed to standardize how inspections are conducted and documented across OSHA's regional offices.

Removal of Numerical Inspection Goal

The original NEP included a specific numerical target for heat-related inspections. The revised version removes this target, instead focusing on strategic, data-driven deployment of resources. This shift allows compliance officers to concentrate on workplaces where the risk is greatest rather than meeting an arbitrary inspection count.

Improved Tracking and Implementation

The update adds new coding categories — including codes for Worksite Assistance and Unprogrammed Emphasis Hazards — to improve how heat-related enforcement activities are tracked across the agency. This should make it easier for OSHA to measure the program's effectiveness and adjust priorities as new data becomes available.

The NEP's Track Record: 7,000 Inspections in Three Years

The significance of the Heat NEP is best understood by its enforcement results. Between April 2022 and December 2024, OSHA conducted approximately 7,000 heat-related inspections under the program — a dramatic increase from the roughly 200 annual heat inspections conducted between 2015 and 2020. During this period, the agency:

• Issued 60 citations under the OSH Act's General Duty Clause
• Distributed 1,392 hazard alert letters to employers
• Removed nearly 1,400 workers from hazardous heat conditions

These numbers underscore a fundamental reality: even without a finalized federal heat standard, OSHA has the authority and the willingness to enforce heat protections through the General Duty Clause. The NEP provides the framework for targeting those enforcement efforts.

Why Heat Remains an Occupational Health Priority

The data behind this enforcement push is sobering. According to the Bureau of Labor Statistics, 48 workers died from exposure to environmental heat in 2024. In the 2023–2024 reporting period, there were approximately 7,100 nonfatal heat-related cases involving days away from work, job restriction, or transfer. The National Safety Council notes that these figures likely undercount the true burden, as heat-related illnesses are frequently misclassified or underreported.

Heat is the leading cause of death among all weather-related hazards in the United States, according to the National Weather Service. Workers who are new to a job, returning from an absence, or not yet acclimatized to hot conditions face disproportionately high risk — NIOSH research has found that a significant share of heat-related fatalities occur within a worker's first few days on the job.

With climate trends driving more frequent and intense heat events, the occupational health case for sustained enforcement is clear.

The Federal Heat Standard: Still Stalled

Separate from the NEP, OSHA's effort to establish a permanent federal heat illness prevention standard remains in limbo. The agency published a Notice of Proposed Rulemaking (NPRM) on August 30, 2024, that would require employers to develop written heat prevention plans, provide water and rest breaks, implement acclimatization procedures, and monitor workplace heat conditions at two trigger levels (80°F and 90°F heat index).

The public comment period closed on January 14, 2025, and an extended post-hearing comment period closed on October 30, 2025. However, as the Ogletree Deakins law firm noted, no further steps toward finalizing the rule have been taken since. The most recent entry in the federal unified regulatory agenda did not include a target date for final action.

This means the NEP — along with the General Duty Clause — remains the primary federal enforcement mechanism for heat-related hazards. The revised NEP's five-year duration suggests OSHA recognizes that the proposed standard may not be finalized anytime soon.

State-Level Heat Standards: A Growing Patchwork

While federal rulemaking stalls, several states have moved ahead with their own enforceable heat illness prevention standards. As of 2026, states with heat-specific requirements include:

• California — The most comprehensive state standards, covering both indoor and outdoor work, with additional high-heat procedures at 95°F
• Oregon — Enforceable standards with temperature-triggered protections for indoor and outdoor workers
• Washington — Similar standards with mandatory rest, hydration, and monitoring requirements
• Maryland — Adopted heat illness prevention requirements effective September 2024
• Minnesota — Long-standing heat stress protections focused primarily on indoor work environments
• Colorado — Heat illness prevention rule covering primarily agricultural workers
• Nevada — New regulations implemented in 2025 requiring written prevention programs and worker training

Employers operating in multiple states need to track these evolving requirements carefully. In states with OSHA-approved State Plans, state heat standards are enforceable regardless of what happens at the federal level.

What Employers Should Do Now

The revised Heat NEP makes clear that OSHA is not stepping back from heat enforcement — it is sharpening its approach. Here is what employers in targeted industries should do before summer arrives:

1. Determine If Your Industry Is on the Target List

Review the revised NEP directive (CPL 03-00-024) to determine whether your industry is among the 55 now targeted for programmed inspections. Even if your industry is not on the list, OSHA compliance officers can expand any inspection to address heat hazards observed on site.

2. Develop or Update Your Heat Illness Prevention Plan

A written heat illness prevention plan is the foundation of compliance readiness. Your plan should address:

• Water, rest, and shade: Ensure workers have continuous access to cool drinking water, shaded or air-conditioned rest areas, and adequate rest breaks
• Acclimatization procedures: Implement a graduated exposure plan for new employees and workers returning from absences of seven or more days
• Training: Train all workers and supervisors on recognizing heat illness symptoms, emergency response procedures, and the employer's prevention plan
• Environmental monitoring: Track heat index conditions and adjust work schedules when temperatures reach dangerous levels
• Emergency response: Establish clear procedures for responding to heat-related medical emergencies, including calling 911 and providing first aid

3. Train Supervisors to Recognize Early Warning Signs

Supervisors are the first line of defense against heat illness. They should be trained to recognize symptoms of heat exhaustion (heavy sweating, weakness, nausea, dizziness) and heat stroke (confusion, loss of consciousness, hot and dry skin), and to take immediate action when a worker shows signs of distress.

4. Prepare for Inspections on Heat Priority Days

Under the revised NEP, OSHA compliance officers will conduct random inspections in high-risk industries on days when the National Weather Service issues a heat advisory or warning. Employers should ensure that their heat prevention programs are fully implemented and documented — not just written down — before the first heat wave of the season.

5. Use OSHA's Free Consultation Resources

OSHA's On-Site Consultation Program offers free, confidential safety and health assessments for small and medium-sized businesses. These consultations are separate from enforcement and do not result in citations or penalties. The agency has specifically highlighted this program as a resource for employers seeking help with heat illness prevention.

6. Check State-Specific Requirements

If you operate in California, Oregon, Washington, Maryland, Minnesota, Colorado, or Nevada, verify that your heat illness prevention program meets state-specific requirements, which may be more stringent than federal expectations.

Looking Ahead

The revised Heat NEP signals that OSHA is committed to heat-related enforcement for the foreseeable future — at least through 2031. For occupational health professionals and employers alike, the message is clear: heat illness prevention is not optional, and enforcement is not going away.

With the proposed federal heat standard stalled and state standards continuing to expand, employers who invest in comprehensive heat illness prevention programs now will be better positioned to protect their workers, demonstrate good-faith compliance, and avoid costly citations when OSHA comes knocking on the next heat priority day.

Visit OSHA's heat illness prevention page for resources, training materials, and guidance on building an effective workplace heat safety program.

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 (OSHA Directive, April 2026)
• OSHA's Heat Program to Expire While Heat Standard Stalls (Ogletree Deakins, March 2026)
• OSHA Extends Heat Hazard Program: Employers Should Act Before Summer Sets In (Jackson Lewis, May 2025)
• OSHA's Heat Program Expired April 8 (EHS Today, April 2026)
• Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings — Notice of Proposed Rulemaking (Federal Register, August 30, 2024)
• Work Safety: Exposure to Environmental Heat (National Safety Council Injury Facts)
• Injuries, Illnesses, and Fatalities (Bureau of Labor Statistics)
• Criteria for a Recommended Standard: Occupational Exposure to Heat and Hot Environments (NIOSH, 2016)
• OSHA Heat Illness Prevention Resources
• OSHA On-Site Consultation Program
• General Duty Clause — Section 5(a)(1) of the OSH Act