OSHA Updates National Emphasis Program on Heat Hazards: What Employers Need to Know

 

As temperatures rise across many regions of the United States, occupational heat exposure continues to present serious risks to worker health and safety. On April 10, 2026, the Occupational Safety and Health Administration (OSHA) revised its National Emphasis Program (NEP) on Outdoor and Indoor Heat-Related Hazards, reinforcing the agency’s focus on preventing heat-related illnesses and fatalities in the workplace.

Background: OSHA’s Ongoing Focus on Heat Hazards

OSHA originally introduced the Heat NEP on April 8, 2022, to address increasing concerns around heat-related illnesses and fatalities. The program established a targeted enforcement strategy focused on high-risk industries and emphasized preventive measures such as access to water, rest, shade, and worker acclimatization.

Since that time, heat-related risks have remained a consistent concern. Recent data indicates there are thousands of heat-related illness cases annually, along with dozens of fatalities each year, highlighting the continued need for proactive workplace controls.

Key Updates in OSHA’s 2026 Heat NEP

1. Expanded Focus on High-Risk Industries

The updated NEP uses more recent data from the Bureau of Labor Statistics (BLS) and OSHA enforcement activity to refine its targeting approach. The program now identifies 55 high-risk industries based on injury rates, hospitalizations, and prior inspection data. This shift allows OSHA to focus inspections more strategically on industries where heat-related hazards are most likely to occur.

2. Increased Heat-Related Inspections

Since the original program was introduced, OSHA has significantly increased enforcement activity. The agency now conducts approximately 2,400 heat-related inspections each year, compared to roughly 200 annually prior to the NEP . This increase indicates that heat exposure is no longer treated as a seasonal or secondary concern, but as a routine enforcement priority.

3. Enhanced Inspection and Citation Guidance

The updated NEP includes additional tools and guidance for compliance officers, including expanded resources for evaluating employer heat illness prevention programs and issuing citations. With clearer internal guidance, inspections may become more consistent, and employers may face increased scrutiny when adequate controls are not in place.

4. Continued Emphasis on Real-Time Enforcement

OSHA continues to prioritize inspections based on current environmental conditions and uses a proactive approach to respond quickly to changing workplace conditions and potential risks.  Inspections may be initiated when:

  • The heat index reaches 80°F or higher
  • The National Weather Service issues a heat advisory or warning
  • Heat hazards are observed during other inspections

5. Alignment with Future Heat Regulations

The updated NEP also aligns with OSHA’s broader regulatory efforts. In 2024, OSHA proposed a federal standard addressing heat injury and illness prevention in both indoor and outdoor work environments. While the rulemaking process is ongoing, the NEP serves as an interim enforcement mechanism and signals continued regulatory focus on heat-related hazards.

What Does the Updated NEP on Heat Hazards Mean for Employers?

The updated NEP reinforces that heat exposure is an ongoing priority for OSHA. Employers in both outdoor and indoor environments, particularly those involving physical labor or heat-generating processes, may be subject to increased enforcement attention. Organizations may benefit from reviewing their existing health and safety programs to ensure they adequately address heat-related risks. Considerations may include:

  • Evaluating workplace conditions and heat exposure risks
  • Reviewing written safety programs and procedures
  • Providing employee training on heat-related illness prevention
  • Implementing engineering and administrative controls

A proactive approach can help reduce risk while supporting compliance with OSHA expectations.

Contact RHP Risk Management to Reduce the Risk of Heat Stress in Your Workplace

RHP’s team of experienced Industrial Hygienists supports employers in identifying and understanding heat=related risks as well as in developing and implementing effective occupational health and safety programs.

To learn more about RHP’s expertise in heat stress, explore insights from Rod Harvey, P.E., CIH, CSP, CHMM. He shares warning signs, training, and practical solutions on the Missouri Employers Mutual podcast, and covers OSHA’s National Emphasis Program on heat hazards, along with prevention strategies, controls, training, and related litigation on the Greenberg Traurig podcast.

Contact RHP to schedule an initial consultation, or call (866) 481-8188.