Federal: OSHA Heat Proposal: Comments Closed, Review Underway

What happened?

OSHA (Occupational Safety and Health Administration), a U.S. Department of Labor agency, is responsible for assuring safe and healthful working conditions by setting and enforcing workplace safety and health standards. On October 30, 2025, OSHA closed the post-hearing comment period on its 2024 proposed standard to prevent heat injury and illness in indoor and outdoor workplaces and is now reviewing the record and drafting a final rule.

Overview

Why this matters: This proposed standard is signaling movement toward a final rule that would require employers to evaluate and control heat hazards across general industry, construction, maritime, and agriculture.

Action Items for Compliance

Proactive heat programs help employers reduce injuries and downtime, improve morale and retention, and stabilize schedules during hotter seasons.

• Draft or refresh a heat plan: define triggers at eighty- and 90 degrees Fahrenheit, monitoring method, controls, training, and emergency response.

• Acclimatization and work and rest: formalize for new or returning workers; increase rest at high heat.

• Water, shade, and cooling: ensure one quart of water per hour per employee, accessible cool‑down areas, and clear communication.

• High heat procedures: mandate paid breaks at 90 degrees Fahrenheit, observe for symptoms, and post required signage.

Recommendations

• Training and records: train supervisors and workers; keep monitoring logs.

• Check state rules: align with existing standards in California, Oregon, Washington, and Minnesota, as well as other applicable states.

Additional Information

What is in the proposal:

• Heat triggers: protections begin at eighty degrees Fahrenheit; heightened measures apply at ninety degrees Fahrenheit.

• Written plan (Heat Injury and Illness Prevention Plan, HIIPP): site-specific monitoring (using heat index or wet bulb globe temperature), controls, training, emergency response, and recordkeeping.

• Core measures: drinking water (approximately one quart per hour per employee), shade or cooled rest areas, acclimatization, paid rest breaks at ninety degrees Fahrenheit, observation for symptoms, hazard alerts, and signage for indoor areas greater than one hundred twenty degrees Fahrenheit.

Expectations:

• OSHA is reviewing the record and drafting a final rule, followed by DOL and OMB review before publication.

• Effective date: Not yet set. Watch OSHA’s rulemaking page and the Federal Register for updates.

What employers and stakeholders said

• Flexibility concerns: many urged a performance-based approach instead of a one-size-fits-all national rule.
• Coalitions: business groups (e.g., CWS) asked OSHA to revise or narrow the proposal.
• Safety professionals: ASSP supported the goal and offered technical input (e.g., ANSI/ASSP A10.50).
• Public health: medical and health organizations pressed for a strong, swift final standard.
• Analysts: noted OSHA already enforces heat hazards under the General Duty Clause and NEP.

Source References

• OSHA – Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings Rulemaking (2024)
• Federal: OSHA Announced Proposed Heat Injury and Illness Indoor and Outdoor Rule (VensureHR)

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