As the sun climbs higher and afternoon shadows fade, the temperature rises, making it the perfect time to review your business’s Heat Illness Prevention Program. In April 2026, OSHA introduced a new National Emphasis Program (NEP) for Heat (1), broadening its scope to include more indoor and outdoor industries. This article outlines the industries, activities, and incidents that significantly increase your risk of inspections, along with strategies to safeguard your employees.
According to the U.S. Department of Labor’s Bureau of Labor Statistics (BLS), from 2021 to 2024, there was an average of 48 heat-related fatalities annually. Most of these deaths result from heat stroke, when the body’s core temperature reaches 104°F or higher. Heat-related illnesses and injuries can occur even at ambient temperatures, especially when workers engage in strenuous activities while wearing PPE that restricts movement or breathing. When any two of these factors—high temperatures, strenuous activity, or PPE that hinders heat dissipation—are present, employers must implement a Heat Illness Prevention Program. It is crucial to consider these external factors during job hazard analysis to ensure proper PPE selection and assignment.
An effective Heat Illness Prevention Program informs employees about the serious risks associated with high temperatures and outlines strategies to mitigate them. These strategies should at least include monitoring ambient temperatures, ensuring ample access to cool water, allowing new employees time to acclimate, and providing designated cooling areas. Most outdoor heat-related fatalities, ranging from 50% to 70%, happen within the first few days of exposure because the body needs to acclimate. Acclimatization involves gradually increasing exposure to hot conditions, enabling physiological adjustments that help maintain body temperature.
Youth and seasonal workers are particularly susceptible to heat injuries and illnesses, with twice the risk of on-the-job injury compared to experienced workers. Increased body heat causes physical and mental stress, and those not acclimated often struggle to perform basic tasks. High temperatures can impair cognitive and physical functions, increasing the risk of second- and third-order accidents caused by fatigue. Hot weather can even turn a routine task deadly due to mental and physical exhaustion.
Workplace deaths and inpatient hospitalizations must be reported to your regional OSHA offices. Most self-reported incidents will trigger an in-person inspection. However, the Heat NEP considers heat inspection as important as construction falls and confined space activities. This means OSHA will likely conduct an in-person inspection when it receives a heat complaint. This is a significant change, as previously heat complaints were handled by phone or mail to request more information from the employer. During a National Weather Service heat warning, if an OSHA inspector passes a worksite that lacks drinking water or adequate shade, they are required to stop and conduct an inspection. Heat inspections enable OSHA to identify additional safety hazards. The key point is to have multiple high-visibility water coolers and portable shade or easily identifiable shaded areas for employees to cool off.
In addition to employer complaints and in-plain-view-triggered inspections, OSHA is creating a Heat high-hazard industry list to guide targeted unannounced inspections. The previous Heat NEP focused on the usual suspects for outdoor work, including construction, landscaping, and agriculture. The current Heat NEP includes these industries and also adds package delivery, bakeries, foundries/mills, warehousing, concrete plants, and miscellaneous wholesalers.
As temperatures rise, businesses must evaluate their Heat Illness Prevention Programs, especially after OSHA’s April 2026 NEP for Heat. Prevention includes monitoring temperatures, providing cool water, allowing acclimatization, and ensuring cooling areas. Young and seasonal workers are especially vulnerable. OSHA now emphasizes in-person heat inspections based on complaints, targeting more industries like delivery and warehousing. Employers must stay compliant to protect workers.
If you have questions or need help creating your program, the Illinois On-Site Safety and Health Consultation Program can supply a sample Heat Prevention Program. The Illinois Department of Labor provides free consultation for small and medium-sized businesses, including on-site visits, program creation, training, and even air and noise testing. This free service, mainly funded by a federal grant through the 21(d) On-Site Consultation Cooperative Agreement, aims to help you develop a safer, more compliant workplace and may even reduce your workers’ compensation costs. For more details, visit https://worksafe.illinois.gov or contact Harry “Hap” Hileman at 217-993-2111 or harry.hileman@illinois.gov.
Note: This program is 90% federally funded, with 10% provided by the State of Illinois.
