OSHA Updates Heat NEP: What Employers Should Know Before the Next Heat Priority Day

Author: Joe Grosse

NEP Update for Outdoor and Indoor Heat-Related Hazards

The Occupational Safety and Health Administration (OSHA) has issued an updated National Emphasis Program (NEP) for Outdoor and Indoor Heat-Related Hazards, continuing the agency’s focus on heat illness prevention across general industry, construction, maritime, and agriculture. The revised directive, CPL 03-00-024, became effective on April 10, 2026, through April 10, 2031, and replaces the prior 2022 Heat NEP. The updated NEP is intended to help OSHA identify and reduce employee exposures to heat-related hazards that may result in serious illness, injury, or death.

This update is important because OSHA is not required to wait for a final federal heat standard to continue enforcement activity. The revised NEP includes a list of 22 new and 33 retained high-risk industries (including plastic product manufacturing, cement and concrete product manufacturing, department stores, etc.), additional guidance for evaluating employer heat illness and injury prevention programs, and citation guidance for OSHA compliance officers. OSHA will continue outreach and compliance assistance while expanding inspections where heat-related hazards are identified on heat priority days.

What Changed?

The revised Heat NEP includes several important changes for employers. OSHA updated the target industry list using current Bureau of Labor Statistics (BLS) and OSHA data, revised the inspection goal, and added reorganized appendices for evaluating heat programs and issuing citations. Specifically, Appendix I now provides a framework for evaluating an employer’s heat program, while Appendix J provides citation guidance. OSHA also added coding for worksite assistance and “Unprogrammed Emphasis Hazard” inspections.

From a practical standpoint, this means employers should expect OSHA to look beyond whether a written heat plan exists. OSHA will evaluate how the program is implemented in the field, including whether employees have access to cool water, rest breaks, shaded or cooled areas, training, and acclimatization. The NEP identifies these measures as key strategies for controlling heat-related hazards.

When Will OSHA Look for Heat Hazards?

Under Section XII.A of the revised NEP, a heat priority day occurs when the heat index for the day is expected to be 80°F or higher. During inspections opened for other purposes on heat priority days, compliance officers are instructed to ask whether the employer has a heat-related hazard prevention program. OSHA may also expand an inspection if there is evidence of heat-related hazards, such as employee complaints, injury and illness records, employee statements, or plain-view observations.

Programmed inspections may occur on days when the National Weather Service has issued a local heat warning or advisory. The revised NEP also states that OSHA will use Appendix A target industries to conduct programmed inspections in industries known to have heat-related hazard incidents. Under Section XII.A of the revised NEP, OSHA states that establishment lists derived from Appendix A will be used for programmed inspections during days with locally issued heat warnings or advisories. Appendix A also explains that OSHA updated its target industries based on BLS heat illness data, OSHA severe injury reports, and prior heat-related inspections, resulting in 55 target industries, including 22 newly added industries.

Why Should Employers Act Now?

OSHA’s background section states that serious heat-related illnesses become more frequent when the heat index reaches 80°F or higher, especially where unacclimatized workers perform strenuous work without easy access to cool water or shaded/cool areas. The NEP also recognizes that heat illnesses can occur below 80°F when aggravating factors are present, such as heavy work, direct sunlight, radiant heat sources, humidity, or bulky clothing and personal protective equipment (PPE).

This is especially relevant for employers with both indoor and outdoor heat exposures. Indoor operations such as foundries, bakeries, warehouses, manufacturing areas, commercial kitchens, boiler rooms, and other spaces with radiant heat sources may fall within the same enforcement framework as outdoor work. Our previous article on the Heat Illness and Injury Prevention Rulemaking similarly notes that high-risk settings may include construction sites, agricultural fields, warehouses, manufacturing plants, commercial kitchens, refineries, and foundries.

OSHA published its proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings rule in the Federal Register on August 30, 2024. OSHA’s informal public hearing on the proposed rule was held from June 16 through July 2, 2025, and the post-hearing comment period ended on October 30, 2025. If finalized, the proposed standard would create more specific federal requirements for employers to evaluate and control heat hazards in outdoor and indoor work settings.

Heat Illness Prevention Program Necessities

Employers should review their existing programs against the elements OSHA is likely to evaluate during an inspection. At a minimum, employers should consider whether their program addresses the items in the following table.

These elements align closely with OSHA’s stated focus areas in the revised NEP, including cool water, rest, shaded/cool areas, training, and acclimatization. They also overlap with the federal heat rulemaking discussion, where the proposed standard would require employers to evaluate and control heat-related hazards through a written plan, if finalized.

What’s Next?

The revised Heat NEP should be treated as an active enforcement roadmap. While OSHA’s proposed Heat Injury and Illness Prevention Standard remains in the post-hearing phase, the NEP provides insight into how OSHA will inspect, document, and evaluate heat hazards now. OSHA states that the proposed Heat Injury and Illness Prevention standard would apply to outdoor and indoor work in general industry, construction, maritime, and agriculture where OSHA has jurisdiction, and would require employers to create a plan to evaluate and control heat hazards in the workplace.

Employers should not wait for a final rule to evaluate their current heat illness prevention practices. Facilities should review written procedures, confirm field implementation, verify supervisor and employee training, and ensure heat controls are in place before the next heat priority day.

ALL4’s Health and Safety team can assist with evaluating heat illness prevention programs, identifying indoor and outdoor heat exposure risks, developing written procedures, and preparing employee and supervisor training. If you have questions about OSHA’s revised Heat NEP or need assistance reviewing your heat illness prevention program, please contact Joe Grosse at jgrosse@all4inc.com or John Kelleher at jkelleher@all4inc.com.