Adam Bouka
By Adam Bouka
With summer temperatures rising and OSHA’s heat hazard enforcement intensifying, Human Resources and SHEA (Safety, Health, Environmental, and Awareness) teams play a critical role in keeping their organizations compliant—and employees safe. On January 16, 2025, OSHA extended its National Emphasis Program (NEP) on Outdoor and Indoor Heat-Related Hazards through April 2026. This renewed focus underscores OSHA’s commitment to preventing heat-related illnesses and fatalities—and puts businesses squarely in the agency’s sights.
Adding urgency to these requirements, the National Weather Service reports that a dangerous “early-season heat dome” has already gripped large portions of the eastern U.S., bringing the highest temperatures seen in years. These extreme heat events are becoming more frequent—and more deadly—making employer compliance with OSHA’s heat protections both a legal and practical imperative.
The Heat NEP: What HR and SHEA Professionals Should Know
Originally launched in April 2022, the NEP targets industries with the highest risk of heat exposure—both outdoors and indoors—and expands OSHA’s authority to conduct heat-related inspections. OSHA’s directive makes clear that heat illness prevention is not optional—and failure to comply can result in citations under the OSH Act’s General Duty Clause.
HR and SHEA’s Role in Compliance and Prevention
Regardless of your industry, HR and SHEA leaders should ensure their organizations are meeting the following requirements:
- Heat Illness Prevention Programs: Ensure that basic protections are in place, including water, rest breaks, shaded or cooled rest areas, and acclimatization procedures for employees exposed to heat.
- Employee Training: Ensure employees receive effective training on heat illness symptoms, prevention protocols, and reporting procedures.
- Policy Updates: Review employee handbooks and safety policies to ensure they address heat illness prevention and whistleblower protections.
- Onboarding and Return-to-Work Protocols: HR and SHEA teams should work with supervisors to ensure new hires and returning employees are properly acclimatized to heat conditions.
- Incident Documentation: Ensure accurate injury and illness recordkeeping, particularly for heat-related incidents, in compliance with OSHA requirements.
Industries Under Enhanced Scrutiny
OSHA is prioritizing inspections in agriculture, construction, landscaping, warehousing, manufacturing, and other high-risk industries. However, indoor environments like warehouses, foundries, and kitchens are also under review—and all employers can face inspection if heat hazards exist.
Why HR and SHEA Should Act Now
- OSHA aims to double heat-related inspections.
- Whistleblower protections for employees reporting heat concerns are actively enforced.
- Extreme weather events, like the current heat dome, increase the likelihood of inspections and worker complaints.
- Failure to implement preventive measures increases the risk of citations, legal exposure, employee turnover, and reputational damage.
Key Takeaways for HR and SHEA
HR and SHEA teams are on the front lines of ensuring compliance, protecting employees, and mitigating organizational risk. Review policies, update training, and work across departments to ensure your organization is prepared—before the heat, and OSHA, show up at your door.
If you need assistance developing compliant heat programs, revising policies, or preparing for an OSHA inspection, consult legal counsel experienced with OSHA’s latest heat hazard directives.
