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Field guide

What OSHA expects on heat illness prevention today

As of November 2026, there is no final federal OSHA heat standard. The proposed rule is still in rulemaking. OSHA enforces heat hazards today under the General Duty Clause and its revised Heat National Emphasis Program, effective April 10, 2026. Employers should write a heat plan, train crews, give water, rest and shade, and acclimatize new workers.

Updated November 5, 20267 min read

No final federal rule

OSHA's heat rule is a proposed rule. It is not final as of November 2026.

Enforcement is live

OSHA cites heat hazards under the General Duty Clause and runs a revised Heat NEP.

Random heat inspections

The NEP adds random inspections in high-risk industries on NWS heat advisory or warning days.

A written plan helps

OSHA tells employers to write a heat illness prevention plan and name a person to run it daily.

Is there an OSHA heat standard in 2026?

No. As of November 2026, OSHA has not issued a final federal heat standard. A proposed rule is in rulemaking, and OSHA enforces heat hazards today under existing law. This guide is for information only. It is not legal advice, so check your own duties with counsel or a state agency.

OSHA published its proposed heat rule on August 30, 2024. OSHA’s own page says it “published in the Federal Register a Notice of Proposed Rulemaking (NPRM) for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings.” The post-hearing comment period ended October 30, 2025. OSHA’s rulemaking page still calls it a proposed rule when we checked on November 5, 2026.

Our OSHA heat rules pillar tracks the status. The short version for a safety manager: plan as if the rule is coming, because the General Duty Clause already applies.

What law does OSHA use to enforce heat hazards today?

OSHA uses the General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act. OSHA’s standards page says this “includes heat-related hazards that are likely to cause death or serious bodily harm.” The clause applies when a hazard is recognized and a feasible fix exists.

OSHA also says it relies on WBGT to decide if a heat hazard was present. WBGT is a heat reading that adds sun, wind and humidity to air temperature. Our WBGT vs heat index guide shows how to read it.

Other OSHA rules touch heat too. OSHA’s first aid standards (29 CFR 1910.151 and 29 CFR 1926.50) require trained first aid people when no clinic is close. Sanitation rules require potable water. OSHA’s standards page lists these.

What is the Heat National Emphasis Program?

It is OSHA’s enforcement and outreach program for heat. OSHA revised the Heat NEP on April 10, 2026. The revision is effective immediately and runs five years. It points inspections at 55 high-risk indoor and outdoor industries.

OSHA’s news release adds two details for employers. Compliance officers “will conduct random inspections focused on heat hazards in high-risk industries on days when the National Weather Service issues a heat advisory or warning.” They also expand any inspection where they see heat hazards on heat priority days.

Item What it is Status as of November 2026
General Duty Clause Existing law that covers recognized heat hazards In force
Heat NEP Inspection and outreach program, 55 high-risk industries Revised April 10, 2026, in place five years
Proposed heat rule Would require a plan to evaluate and control heat hazards Proposed only, not final
State heat laws Washington, Minnesota, California, Oregon, Colorado In force in those states

Sources for each row appear in the list at the end of this page.

What does the proposed OSHA heat rule say?

The proposed rule would require employers to write a plan. OSHA says the standard “would require employers to create a plan to evaluate and control heat hazards in their workplace.” It would cover general industry, construction, maritime and agriculture.

The NPRM comment period closed January 14, 2025. OSHA held an informal hearing from June 16 to July 2, 2025. Final text can differ from the proposal, so treat every proposed item as proposed, not as a current duty.

The proposal does show where OSHA is heading. Written plans, heat measurement, training, water, rest and acclimatization all show up in OSHA’s own guidance today. You can build them now without waiting for a final rule.

Which states have their own heat laws, and what about Texas?

OSHA says “Washington, Minnesota, California, Oregon, and Colorado have specific laws governing occupational heat exposure.” Employers in those states must follow the state rule. Other states fall back on federal OSHA.

Texas has no state heat standard for private employers. Texas HB 2127 took effect September 1, 2023. The Texas Tribune reported that the law “will nullify ordinances enacted by Austin in 2010 and Dallas in 2015 that established 10-minute breaks every four hours” so that construction workers could drink water. Federal OSHA still applies in Texas, including the General Duty Clause and the Heat NEP. Our Texas heat rules guide covers the details.

Which workplaces face heat hazards?

Heat hazards occur indoors and outdoors, in any season. OSHA says “Hazardous heat exposure can occur indoors or outdoors, and can occur during any season if the conditions are right, not only during heat waves.” Its overview lists industries where workers have suffered heat-related illnesses.

Outdoors Indoors
Agriculture Bakeries, kitchens and laundries
Construction, especially road, roofing and other outdoor work Electrical utilities, particularly boiler rooms
Landscaping Fire service
Mail and package delivery Iron and steel mills and foundries
Oil and gas well operations Manufacturing with hot local heat sources, like furnaces
Warehousing

Warehouse and plant managers face the same General Duty Clause exposure as roofing foremen. The NEP covers both indoor and outdoor settings.

How does OSHA decide a heat hazard exists?

OSHA looks at the whole picture, not one temperature. Its overview says “Occupational heat exposure is a combination of many factors.” These include physical activity, air temperature, humidity, sunlight, heat sources, air movement, clothing, and personal risk factors.

OSHA also tells employers that workers “may experience heat stress at temperatures much lower than public heat advisories.” Personal risk factors include medical conditions, lack of physical fitness, previous heat illness, alcohol, drugs and some medications. OSHA says management should protect all employees, whatever their heat tolerance.

That is why a single “too hot” number does not work. Measure heat at the work, think about the job, and watch the people.

What should employers do now to prevent heat illness?

Follow OSHA’s own guidance. Write a plan, name a daily lead, measure heat, give water, rest and shade, acclimatize new workers, train everyone and rehearse the 911 call. OSHA says employers “should create a written plan to prevent heat-related illness.”

  1. Write a heat illness prevention plan. Use OSHA’s planning questions: oversight, new workers, first aid, controls, measurement, advisory days and training.
  2. Name one person to run it every day. OSHA says an individual at the worksite should be “responsible for monitoring conditions and implementing the employer’s heat plan throughout the workday.”
  3. Measure heat where the work happens. Use a WBGT meter near the work.
  4. Apply Water. Rest. Shade. OSHA encourages all three as prevention and as treatment.
  5. Acclimatize new and returning workers. Use the schedule in our heat acclimatization guide.
  6. Train crews and supervisors. Cover symptoms, first aid and when to call 911.
  7. Set a plan for NWS advisory days. The NEP targets those days.

Our heat stress program guide gives the full eight-step build.

What must employers report or record after a heat event?

Report deaths and hospitalizations on a clock. OSHA says employers must “report to OSHA all work-related fatalities within eight hours, and all work-related inpatient hospitalizations within twenty-four hours.” That includes heat illness, heat stroke, kidney injury and rhabdomyolysis that lead to death or inpatient hospitalization.

Recordkeeping depends on treatment. OSHA says that if a worker “is only instructed to drink fluids for relief of heat stress, the case is not recordable.” Cases with medical treatment beyond first aid can be recordable. Ask your safety lead or counsel to classify each case.

Where can small employers get free help?

OSHA’s On-Site Consultation program is free and confidential. OSHA describes it as a program for “small- and medium-sized businesses” that “can assist employers with developing strategic approaches for addressing heat-related illnesses and injuries in workplaces.” It is separate from enforcement.

Consultation can review your heat plan before an inspection. Ask your state’s consultation office how to book a visit.

How does hydration fit into OSHA’s guidance?

OSHA puts water first in Water. Rest. Shade. Its heat overview says “OSHA encourages water, rest, and shade as prevention as well as treatment for heat-related illness.” OSHA’s water page adds that for jobs longer than two hours, “employers should provide electrolyte-containing beverages such as sports drinks.”

JMAR Solutions supports the hydration step. Rapid Restoration Drops are a dietary supplement that replaces electrolytes lost in sweat and supports hydration. They are not medicine and they do not replace first aid. JMAR also runs hydration programs with onsite toolbox talks, training and coaching. Supervisors also need to know the signs of heat illness.

OSHA says “Confusion, slurred speech, or unconsciousness are signs of heat stroke.” In that case, call 911 and start cooling the worker.

Next step

Want a heat plan your crew will follow? Book a 15-minute demo with JMAR Solutions, or request a free sample of Rapid Restoration Drops for your next toolbox talk.

Frequently asked questions

Is there an OSHA heat standard?

Not a final one. As of November 2026, OSHA's heat rule is still a proposed rule. OSHA enforces heat hazards today under the General Duty Clause and its Heat National Emphasis Program. Five states, Washington, Minnesota, California, Oregon and Colorado, have their own heat laws.

Can OSHA cite an employer for heat without a heat standard?

Yes. OSHA says the General Duty Clause covers heat-related hazards that are likely to cause death or serious bodily harm. OSHA also says it uses WBGT to decide whether a heat hazard was present. This guide is not legal advice.

What is the OSHA Heat National Emphasis Program?

It is an OSHA enforcement program for indoor and outdoor heat hazards. OSHA revised it on April 10, 2026. It directs inspections to 55 high-risk industries and adds random heat inspections on days when the National Weather Service issues a heat advisory or warning.

What should a heat illness prevention plan include?

OSHA lists who oversees heat controls each day, how new workers build tolerance, first aid and 911 steps, controls, how heat is measured, what to do on a heat advisory day, and training. Our heat stress program guide turns these into eight steps.

Does Texas have its own heat rule?

Texas is not among the five states OSHA lists with specific heat laws. Texas HB 2127 ended the Austin and Dallas local water-break ordinances effective September 1, 2023. Federal OSHA still applies in Texas, including the General Duty Clause and the Heat NEP.

Terms on this page

Sources

  1. OSHA: Heat overview, working in outdoor and indoor heat environments
  2. OSHA: Heat overview, working in outdoor and indoor heat environments
  3. OSHA: Heat standards
  4. OSHA: Heat injury and illness prevention rulemaking
  5. OSHA: Heat injury and illness prevention rulemaking
  6. OSHA: US Department of Labor updates national emphasis program to protect workers from indoor, outdoor heat hazards
  7. OSHA: US Department of Labor updates national emphasis program to protect workers from indoor, outdoor heat hazards
  8. OSHA: US Department of Labor updates national emphasis program to protect workers from indoor, outdoor heat hazards
  9. OSHA: US Department of Labor updates national emphasis program to protect workers from indoor, outdoor heat hazards
  10. OSHA: Heat planning and supervision
  11. OSHA: Heat planning and supervision
  12. OSHA: Heat standards
  13. OSHA: Heat standards
  14. Texas Tribune: As Texas swelters, local rules requiring water breaks for construction workers will soon be nullified
  15. Texas Tribune: As Texas swelters, local rules requiring water breaks for construction workers will soon be nullified
  16. OSHA: Heat overview, working in outdoor and indoor heat environments
  17. OSHA: Heat standards
  18. OSHA: Heat standards
  19. OSHA: Water. Rest. Shade.
  20. OSHA: Heat-related illnesses and first aid
  21. OSHA: Heat overview, working in outdoor and indoor heat environments
  22. OSHA: Heat overview, working in outdoor and indoor heat environments
  23. OSHA: Heat overview, working in outdoor and indoor heat environments
  24. OSHA: Heat overview, working in outdoor and indoor heat environments
  25. OSHA: Heat hazard recognition
  26. OSHA: Heat overview, working in outdoor and indoor heat environments

Checked against the sources above on November 5, 2026. Rules and guidance change, so check the linked page before you act. This page is general information, not legal or medical advice.

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