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Aligning with OSHA’s Heat Stress National Emphasis Program


We may be headed for fall soon, but the heat has not yet passed us. The OSH Act requires employers to provide workers a safe workplace, including protection from extreme heat.

In support of this effort, in April 2022, OSHA established a National Emphasis Program (NEP) for heat hazards to help employers confront the heat head-on. They developed policies and procedures for identifying or reducing worker exposures to occupational heat-related illnesses and injuries. The NEP for heat hazards focuses on general industry, construction, agriculture, and maritime, where employees have the highest exposure to elevated heat.

The Centers for Disease Control and Prevention estimates that 658 people die each year, despite knowing heat-related injuries and illnesses are preventable. Certain conditions such as physical exertion or fluctuating outdoor temperatures can put employees at risk, even in ambient temperatures. Employers must recognize heat stressors, understand how to protect workers properly, plan for battling heat hazards, and train workers to recognize signs of heat stress.

Understanding heat hazards

The NEP outlines the need to understand hazards imposed by heat to effectively manage heat-related stressors. A recent poll from J.J. Keller’s Center for Market Insights highlighted what many employers found to contribute to heat stress. Poll respondents from various parts of the country in manufacturing, construction, agriculture, and similar industries agree with OSHA that the following are major contributors to heat stress:

  • Exposure to outdoor temperatures, humidity, and sun;
  • Working inside warehouses;
  • Production in non-climate-controlled areas; and
  • Physical exertion from underground and overhead work.

Respondents pinpointed their two most significant heat-related stressors that enhance the risk of heat stress:

  • Radiant heat from machinery and equipment, and
  • The wearing of required personal protective equipment (PPE).

These two stressors spanned all industries in the poll.

Employers can ensure they understand heat hazards in their workplace by monitoring OSHA’s inspection focus areas — incidents, employee perspective, written programs, and employee training. In addition to understanding the work environment, one of the best ways to understand heat hazards is to investigate heat-related illnesses on OSHA 300 Logs. Previous incidents are windows into the future if heat-related exposures aren’t corrected. As OSHA compliance officers would, employers can also interview employees to determine if they have had heat-related symptoms such as headaches, dizziness, and dehydration. Employees have a bird’s-eye view of which workplace heat safety controls would be most effective and how to implement.

Mitigating heat hazards

Along with understanding heat hazards, employers are well-served to follow OSHA’s inspection process as a way to mitigate heat hazards. Employers should review their heat illness and prevention program to ensure they are effectively aligning with the NEP by addressing hazards, implementing workplace heat safety controls, and training workers. Employers should be able to answer the following questions about their written heat safety plans:

  • How are ambient temperatures and employee work exertion levels being monitored?
  • Are additional breaks required and scheduled during extreme heat conditions?
  • Is unlimited cool water easily accessible to workers?
  • Do employees have access to shaded or air-conditioned areas?
  • Are employees provided additional cooling aids, such as bandanas, portable fans, etc.?
  • Are employees provided an opportunity to acclimate properly to increased heat loads?
  • Has a buddy system been established, especially for lone workers, during extreme heat
  • Are engineering controls in place, such as ventilation, air-conditioning/fans, reflective shields, etc.?
  • Are administrative controls in place? (job rotation, working during cooler parts of the workday, etc.)
  • When administrative or engineering controls are insufficient, is protective and cooling PPE provided for supplemental protection?
  • Are employees appropriately trained to recognize the signs of heat-related illness and know how to response to these emergencies?

Employers should also target heat safety efforts to focus on the ultimate goal of protecting workers from exposure to extreme heat. More often than not, where heat-related injuries or illnesses have occurred, employers didn’t provide employees with:

  • Cool water,
  • Rest in cool areas,
  • Opportunity to acclimate to the heat, or
  • Training to recognize hazards.

Analyzing and filling these gaps will move your heat safety program in the right direction.

Key to Remember

OSHA’s National Emphasis Program (NEP) for heat provides exceptional guidance for protecting workers from extreme heat. Employers should develop their personalized strategies for approaching heat-related exposures that align not only with OSHA’s NEP but with specific processes, operations, and work environments at their facilities.