OSHA Update: National Emphasis Program, Outdoor & Indoor Heat-related Hazards
Authored by: Mikhail Fradkin, CIH, CSP & Brian Hobbs, CIH, CSP
The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has updated its National Emphasis Program (NEP) for Outdoor and Indoor Heat-Related Hazards, which was originally issued in April of 2022. The update may increase compliance pressure for organizations that are already managing complex safety and operational demands.
The goal of this NEP update is to reduce or eliminate worker exposures to heat-related hazards that result in illnesses, injuries, and deaths by targeting industries and worksites, including worksites with radiant heat sources, where employees are exposed to heat-related hazards and have not been provided adequate protection that includes cool water, rest, cool areas, training, and acclimatization. To achieve this goal, the revised program is designed to strengthen enforcement, inspection targeting, and outreach in industries where heat stress poses the greatest risk to workers.
Who will this apply to?
This update is especially important for employers in one of the 55 target industries identified by OSHA within the NEP for Outdoor and Indoor Heat-Related Hazards. The list of target industries spans a wide range, including farming establishments, architectural and structural metal manufacturing, department stores, freight trucking, waste collection, construction, and many more, as referenced in the link above.
For employers who fall into one of the target industry categories, key items to consider include:
- Heat‑focused inspections can be triggered by National Weather Service heat advisories or warnings, even in the absence of worker complaints.
- There will be greater scrutiny of heat illness prevention programs.
- Increased risk of citations or hazard alert letters for employers lacking documented controls, training, and response procedures.
- Operational disruptions caused by compliance findings or unplanned enforcement actions.
- To ensure abatement and to monitor the effectiveness of OSHA’s enforcement and guidance efforts, certain follow-up inspections for worksites previously inspected and cited for heat-related hazards will be included as part of the program procedures.
What can Roux do to help?
Roux can help employers meet OSHA’s revised NEP-Outdoor and Indoor-Heat Related Hazard requirement by utilizing our team of experienced Certified Industrial Hygienist (CIH) professionals with practical knowledge of heat-related hazards and OSHA’s enforcement expectations. All of Roux’s safety professionals work closely with employers to evaluate indoor and outdoor heat exposures, assess current policies and practices, and identify gaps that could pose enforcement risks.
Roux supports the development and implementation of customized heat illness prevention programs, including acclimatization plans, work/rest schedules, training, monitoring, and emergency response procedures aligned with OSHA and National Institute for Occupational Safety and Health (NIOSH) guidance. We also provide site-specific audits, documentation support, and proactive compliance strategies to help employers demonstrate due diligence during inspections and reduce the likelihood of citations. As you navigate these regulatory shifts, we offer support and guidance tailored to your needs. Please contact our team with any questions or concerns below.
