Proposed Heat Injury and Illness Prevention Rule for 2025

In 2021, the Occupational Safety and Health Administration (OSHA) began working on a new safety standard for all general industry, construction, maritime, and agriculture sectors where OSHA has jurisdiction, with some exceptions. This new standard would require employers to create a plan to evaluate and control heat hazards in their workplace.

This proposed standard, “Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings,” more clearly sets forth employer obligations and the necessary means to effectively protect employees from hazardous heat and temperatures. OSHA held a public comment period for the standard, which closed on January 14, 2025. Currently, there is an informal hearing on the proposed standard scheduled for June 16, 2025.

Heat is the leading cause of death among all weather-related injuries in the US. Excessive heat in the workplace can cause a number of adverse health effects, including heat stroke and even death if not managed properly. OSHA is currently finalizing federal standards to address these extreme hazards posed by occupational heat exposure.

Workers in both outdoor and indoor work settings without adequate climate controls are at risk of hazardous heat exposure. Certain heat-generating processes, machinery, and equipment (e.g., hot tar ovens, furnaces, hot metal work) can also cause heat hazards when cooling measures are not in place.

OSHA has preliminarily determined that exposure to hazardous heat in the workplace poses a significant risk of serious injury and illness. While there is still no current mandate of specific temperature limits, protect your employees. PLAN AHEAD! Spring is here and the temperatures will be increasing as we head into the summer months.

NIOSH Heat Index Thresholds

Initial Heat Trigger: A heat index of 80 degrees Fahrenheit equals the National Institute for Occupational    Safety and Health (NIOSH) recommended alert limit. Temperatures in this range trigger the need for employers to provide drinking water and break areas.

High Heat Trigger: A heat index of 90 degrees Fahrenheit equals the NIOSH recommended exposure limit. Temperatures in this range trigger stricter rules, including mandatory 15-minute breaks every two hours.

The combination of a high-heat work environment, strenuous work activities, and personal risk factors can result in injury or death.

Staying Safe in the Heat

• Stay hydrated: drink at least one eight-ounce cup of water every 15–20 minutes, even if you don’t feel thirsty.
• Know your acclimation status: those who have been away from the job for a time and new employees will need to condition to the job tasks.
• Know the signs and symptoms of heat stress and educate your employees.
• Take rest breaks.
• Wear clothing that is safe but also minimizes heat stress if possible.
• Be a buddy.
• Know what to do in an emergency!!

Updates to the Proposed Standard

In January, President Trump issued a memorandum titled “Regulatory Freeze Pending Review,” which directed federal agencies to temporarily delay the implementation of pending regulations. The heat injury and illness rule is currently part of that pause on new rulemaking.

While this rule is unlikely to be advanced by the current administration, you should still make sure that your site has a heat stress prevention plan. Several states already have heat protection standards, and several more are in the process of developing them. Additionally, without a standard in place, OSHA can cite your company for failing to address a recognized hazard under the General Duty Clause.

How Can Walden Help?

Walden’s experienced EHS team is available to assist you with safety program development, risk assessment, and training. We can identify gaps in your existing safety programs to ensure they are keeping your employees safe in as cost-effective a manner as possible. If you need assistance, please contact Walden EHS Director, David Garner, at 860-846-4069 or dgarner@walden-associates.com.