Stay Cool: Top Tips for Managing Heat Stress from Proposed OSHA Rule
With record-breaking temps hitting the country from coast to coast, OSHA has proposed a new rule designed to keep workers safe from excessive heat, which caused an average of 40 deaths and 3,389 illnesses and injuries per year from 2011-2022. OSHA held informal public hearings from June 16, 2025, through July 2, 2025.
The proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings rule would apply to all employers in both indoor and outdoor settings, including general industry, construction, maritime, and agriculture sectors covered by OSHA. (Short-duration heat exposure, sedentary jobs, indoor worksites kept under 80°F, remote work, emergency response teams, and government employers are exempt.)
While it’s unsure when or if this rule will be finalized in the future, it’s clear that the actions it outlines provide several benefits for employers. Not only will it help protect your workforce, but it has the potential to improve productivity and decrease turnover.
How hot is too hot?
The rule activates when the heat index is 80°F for more than 15 minutes during any 60-minute period. Even more stringent requirements go into effect when temps reach 90°F. Industries that use heat-generating processes, machinery, and equipment can also cause heat hazards without appropriate cooling measures.
Here are the recommended actions included in the proposed rule:
Analysis, Strategy, and Training
Assess heat risk: Identify the high-risk areas and tasks where workers are likely to be exposed to high heat at your workplace.
Monitor temperatures: Install systems to continually monitor the temperature and humidity levels throughout your work site. OSHA recommends using wet bulb globe temperature (WBGT) devices to track workplace heat.
Create a Heat Injury and Illness Prevention Plan (HIIPP): Include site-specific information to evaluate and control heat hazards in your workplace, available to each employee in a language that they understand. The plan should specify what the employer's responsibilities are when an employee experiences a heat-related illness or emergency.
Develop a heat illness and emergency response plan: Train supervisors and workers to provide the appropriate first aid and contact emergency services when needed. A list of emergency phone numbers should be available at each site, and workers should know how to contact a supervisor and emergency medical services when needed even if they do not have access to a phone.
Conduct heat safety training: Before starting work in high heat conditions, both supervisors and employees should be trained on heat-related hazards, how to identify signs and symptoms of heat-related illnesses, and what the employer's heat-related policies and procedures are.
Record data: Maintain accurate and complete written or electronic records of indoor monitoring data, along with all heat-related incidents.
Employee Protection Measures
When temperatures rise to 80°F for more than 15 minutes, the proposed rule requires employers to:
Provide drinking water: Give workers unlimited access to water and encourage regular hydration – OSHA recommends 4 to 6 ounces every 15 to 20 minutes. If water fountains or taps are not nearby, water coolers, food grade jugs, or bottled water can be used.
Schedule rest breaks: Plan regular breaks in areas with shade, air conditioning, or fans so workers can escape the heat, remove PPE to cool off, and hydrate. These should be close enough to the worksite that people can access them easily to cool down when needed, and large enough to accommodate all workers who need them. As temperatures rise, longer or more frequent breaks may be needed (see below).
Implement acclimatization programs: Evidence shows that new and returning workers are at higher risk for heat-related incidents. The rule requires employers to acclimatize workers over one to two weeks, using methods like limiting work time or heat exposure.
Implement a two-way communication plan: Employers and employees should check in with each other every two hours to monitor or report heat-related illnesses on the job.
Provide cooling PPE: Evaporative headbands, hard hat liners, and vests are some examples of cooling technology.
When temperatures reach 90°F for more than 15 minutes, employers should also:
Provide additional paid rest breaks. In high heat, the minimum rest time is 15 minutes in shade every two hours.
Monitor employees: On high heat days, assign someone at each worksite to watch workers for symptoms of heat stress and respond as needed.
Share a heat hazard alert. This should inform workers about heat hazards, preventive measures, and emergency procedures, along with information on hydration, rest breaks, and emergency responses.
The actions listed above apply only to the proposed OSHA rule for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. Note that several states and municipalities have their own heat safety standards, so be sure to review those to ensure full compliance.
How We Can Help
We know that staying on top of changing regulations can be a challenge. If you want help interpreting the regulations and navigating the changes, reach out. Our team will help you make sense of the new rules, support you implementing the right measures to protect your workers, and navigate the growing complexities of regulatory compliance.