As temperatures rise across the U.S., OSHA is taking aggressive steps to protect workers from heat-related injuries and fatalities.
On June 16, 2025, OSHA will hold an informal public hearing on its proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings standard—a sweeping rule aimed at holding employers accountable for preventing hazardous heat exposure.
With environmental heat causing an estimated 40 deaths and 33,890 serious workplace injuries annually, OSHA is signaling that voluntary guidance is no longer enough. The new rule would require mandatory heat protection protocols, especially in work settings where air conditioning and ventilation are limited or nonexistent.
Let’s break down what the proposed rule includes, key compliance questions, challenges, and how employers can prepare—before it’s too hot to handle.
Why OSHA Is Cracking Down on Heat Exposure
Heat is an invisible killer.
According to OSHA, heat-related deaths are increasing, particularly in the wake of climate change. A 2024 report in The Journal of the American Medical Association found that heat-related deaths in the U.S. rose 117% between 1999 and 2023, peaking at 2,325 deaths in 2023.
While 80% of heat-related fatalities occur outdoors, nearly two-thirds of nonfatal cases happen indoors, such as warehouses, boiler rooms, and industrial plants.
Five Key Questions About OSHA’s Proposed Heat Rule
1. Who Is Covered?
The rule would apply to employers in all general industry, construction, maritime, and agriculture sectors. Some exemptions include:
- Short exposure (<15 minutes/hour)
- Consistently climate-controlled indoor areas
- Firefighting and emergency response roles
- Telework and sedentary office work
2. What’s in the Required HIIPP (Heat Injury and Illness Prevention Plan)?
Employers with 10+ employees must create a site-specific HIIPP that includes:
- Work activities covered
- Heat hazard monitoring methods
- Names of designated heat safety coordinators
- Emergency response protocols
- Annual review or post-incident updates
3. When Do “Heat Triggers” Apply?
- Initial Heat Trigger (HI of 80°F): Requires basic protections
- High Heat Trigger (HI of 90°F): Requires stricter measures like mandatory breaks and symptom monitoring
These thresholds must be monitored continuously across work zones.
4. What Are Employers Required to Do?
At 80°F heat index:
- Provide cool drinking water
- Offer shaded or cooled break areas
- Allow paid rest breaks (if needed)
- Begin employee acclimatization protocols
- Establish two-way communication systems
At 90°F heat index:
- Require 15-minute breaks every 2 hours
- Monitor employees for symptoms (via buddy system or designated observer)
- Post warning signs in areas exceeding 120°F
- Maintain contact with lone workers every 2 hours
5. What Recordkeeping Is Required?
Employers must:
- Maintain temperature logs for at least six months
- Document exposure times and protective measures
- Record symptom reports and responses
This data supports compliance and helps identify trends in worker heat exposure.
Top 3 Challenges for Employers to Comply
1. Monitoring Real-Time Indoor Temperatures
OSHA expects employers to actively track environmental conditions across multiple zones.
But critics call this “economically and administratively burdensome,” especially for large or complex indoor operations.
Smart Solution: Use real-time heat and humidity sensors to avoid manual tracking and reduce errors.
2. Tracking Worker Exposure Minutes
To comply, employers must log:
- Time spent in hot zones
- Heat index values during that time
- Appropriate control measures activated
Missing just one interval could trigger a citation.
Smart Solution: Use RFID or wearable tech to track entry/exit times from heat zones and link to heat index monitoring.
3. Monitoring for Symptoms in Real Time
The rule mandates peer or supervisor monitoring for heat illness symptoms—raising concerns about liability and capability.
Smart Solution: Provide wearable biometric devices or enable voice/text alerts through mobile safety platforms to quickly identify symptoms and trigger emergency responses.
What Employers Should Do Now
Even though the final rule could still change (or be delayed depending on political shifts), proactive preparation will reduce risk and help meet existing General Duty Clause obligations.
Here are a few steps employers can take now:
- Review current heat illness prevention plans
- Train employees on heat stress signs and emergency procedures
- Invest in smart safety monitoring tools (humidity/temperature sensors, break timers, communication devices)
- Identify high-risk work zones and job functions
- Join the public hearing on June 16, 2025 to voice concerns or support
CNS OccMed Can Help Employers Stay Cool and Compliant
The heat isn’t going away—and OSHA knows it.
Whether or not the proposed standard is finalized in its current form, employers should treat heat as a serious workplace hazard now.
Start your customized health plan to meet your business needs and keep your employees healthy and safe.
Our Occupational Medicine Team will develop a custom plan for your company. You may need a combination of services related to:
We understand the impact that lost time, limited duty, and medical costs have on the company and the employee. So, work with an occupational medicine provider that can be staffed on-site or have a mobile health clinic come to reduce employee downtime away from the office.
We also have a strong understanding of the OSHA recordkeeping rule and how certain medical diagnosis and treatments impact your OSHA 300 log.
For more information, contact us at 800.551.9816 or info@cnsoccmed.com.
