OSHA Revises Heat Hazard NEP Effective April 10, 2026

On April 10, 2026, the Occupational Safety and Health Administration (OSHA) updated its National Emphasis Program (NEP) on Outdoor and Indoor Heat-Related Hazards. The revised directive became effective immediately for a period of five years.

The revised NEP removed the former numerical inspection goal and reorganized appendices on heat program evaluation and citation guidance. Programmed heat inspections are now tied to days when the National Weather Service (NWS) issues a head advisory or warning.

This update is applicable nationwide across general industry, construction, maritime, and agriculture, with programmed enforcement focused on 55 high-risk industries and with continued authority for compliance officers to expand inspections when evidence of heat-related hazards is identified.

What Employers Need to Do

• Determine whether any covered operations fall within OSHA’s updated high‑risk industry list and track local NWS heat advisories and warnings (NWS Heat Alerts). Heat NEP inspections are tied to those alerts, and Appendix A identifies OSHA’s highest‑risk industries.

• Review and strengthen the employer’s heat illness prevention approach against OSHA’s Appendix I criteria, including heat and workload monitoring, cool water, hydration breaks, rest, shade/cooling, acclimatization, administrative controls, training, and assignment of a designated heat-safety representative.

• Prepare supervisors and site leaders for heat-priority-day scrutiny. Compliance officers may expand inspections opened for other reasons when the heat index is expected to be 80°F or higher and evidence of heat hazards is present.

• Review heat-related recordkeeping, incident response, and basic protective measures, including OSHA 300/301 entries, access to potable water, training, and first-aid / emergency response practices, because OSHA’s citation guidance points to the General Duty Clause and related standards such as sanitation, recordkeeping, and certain construction safety requirements.

• Consider OSHA’s On-Site Consultation Program, a no-cost, confidential resource designed to help small and midsize employers identify hazards and improve safety and health programs outside of enforcement.

Overview

• The revised directive cancels and replaces OSHA’s prior April 8, 2022, Heat NEP and remains operative for no more than five years from April 10, 2026, unless canceled or extended by a superseding directive.

• OSHA refreshed the target list using updated BLS and OSHA data reflected in Appendix A, and the revision resulted in 46 industries removed, 22 industries added, and 33 industries retained, for a total of 55 target industries.

• The directive states that programmed inspections must occur on any day the NWS announces a heat warning or advisory for the local area, while heat priority days are days when the expected heat index is 80°F or more, prompting additional inquiry into heat controls during other inspections.

• OSHA removed outdated background material, updated links, eliminated the prior numerical inspection goal, and reorganized or added Appendix I (Evaluation of a Heat Program) and Appendix J (Citation Guidance) to improve consistency in enforcement and documentation.

• The revised NEP also adds coding for Worksite Assistance and Unprogrammed Emphasis Hazards, and it requires each Regional or Area Office to complete a 90-day outreach program before programmed inspections begin in industries newly added to the target list.

Why This Matters

The revised NEP increases OSHA’s focus on heat hazards in the industries and workplaces it considers highest risk, while still allowing heat-related scrutiny during complaints, referrals, and other inspections where hazards are observed.

The guidance provides employers with a clearer understanding of what OSHA expects in a heat illness prevention program. Appendix I provides a practical evaluation framework, and Appendix J reinforces that OSHA may continue pursuing heat cases under the General Duty Clause, along with other applicable requirements such as potable water, sanitation, recordkeeping, and construction training rules.

Employers operating in multiple jurisdictions may face overlapping obligations, as OSHA identifies several State Plan jurisdictions with their own heat standards.

Key Risks for Employers

• Higher inspection likelihood on extreme-heat days, especially where the employer operates in one of OSHA’s 55 target industries and the NWS has issued a local heat advisory or warning.

• Inspection expansion during non-heat inspections may occur when compliance officers observe heat hazards in plain view or when supported by records or employee statements on heat priority days.

• General Duty Clause exposure, since OSHA’s citation guidance continues to frame heat as a recognized hazard that may be cited when the agency can document hazardous conditions and feasible abatement measures.

• Recordkeeping and documentation issues, because inspectors are directed to review OSHA 300/301 logs, records of heat-related treatment or transport, weather and heat-index conditions, workload factors, and employer program implementation.

• Broader corporate follow-up where the directive contemplates letters to corporate entities if similar operations at other locations may expose workers to comparable heat hazards.

Additional Information

OSHA’s revised NEP continues outreach, compliance assistance, and use of the agency’s heat illness prevention resources, and it preserves OSHA’s ability to provide worksite assistance even where evidence is insufficient for a citation.

For small and midsize employers, OSHA’s On-Site Consultation Program remains available on a no-cost, confidential basis and separate from enforcement, helping employers identify hazards and strengthen safety and health programs before issues lead to injuries or enforcement action.

Source References

• OSHA – Press Release – US Department of Labor updates national emphasis program to protect workers from indoor, outdoor heat hazards (April 10, 2026)
• OSHA National Emphasis Program – Directive No. CPL 03-00-024 – Outdoor and Indoor Heat-Related Hazards (Update April 10, 2026)

Resources

• OSHA – Heat Illness Prevention

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