Employers who build a program now are better prepared to protect their teams, document their efforts, and respond confidently as OSHA expectations continue to evolve.

When most people picture heat illness on the job, they imagine a construction crew under the midday sun. That picture is incomplete. Warehouses, service bays, quick lube service pits, and production floors can all reach unsafe temperatures long before anyone thinks to check. Heat builds up indoors from equipment, poor airflow, and trapped humidity. In warehouses, thin walls and uninsulated metal roofs let outside heat pour in and stay trapped. It can affect your team whether they ever step outside (1).

Heat illness is preventable when employers have a clear plan, trained supervisors, and practical controls in place. With a few well-documented steps, you can protect your people, stay ahead of evolving Occupational Safety and Health Administration (OSHA) expectations, and keep your operation running smoothly through the hottest months. The strongest approach is to build your program now, while there's time to assess your workplace, train your supervisors, and put practical controls in place before peak heat conditions arrive.

What's Actually Changing With OSHA

There has been a lot of discussion about OSHA's proposed heat rule. Here's the straight version, so you can plan with confidence.

The federal heat rule isn't final yet. OSHA published a proposed standard, "Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings," in August 2024. Public hearings wrapped up in 2025, but the rule has not been finalized (2). So employers are not required to follow the proposed federal rule today, unless similar requirements already apply under a state heat standard.

OSHA's enforcement focus, however, is very real and very current. In April 2026, OSHA updated and extended its National Emphasis Program (NEP) on indoor and outdoor heat hazards. This keeps heat hazards within OSHA's targeted inspection activity for the next 5 years (3).

The program directs inspectors toward 55 high-risk industries identified by industry code, including construction, warehousing and distribution, automotive repair, and manufacturing (4). On high-heat days, OSHA may conduct programmed or heat-related inspections, review injury logs and training records, and ask employees how heat is managed on-site (4).

Even without a final rule, OSHA can already cite heat hazards under the General Duty Clause, which requires every employer to provide a workplace free from recognized hazards likely to cause serious harm (4). In plain terms: OSHA already expects you to treat heat as a hazard and take reasonable steps to control it.

Some states go further. A handful of states, including California, Colorado, Maryland, Minnesota, Nevada, Oregon, and Washington, already have their own enforceable heat standards with specific requirements (5)(6)(7)(8). If you operate in more than one state, it's worth confirming what applies to each location, because state rules can be stricter than the federal baseline.

The simplest way to think about all this: the proposed rule shows where expectations are heading, and the NEP shows what OSHA is prioritizing right now. Employers who build a program now are better prepared to protect their teams, document their efforts, and respond confidently as OSHA expectations continue to evolve.

Where OSHA Expectations Are Heading

The proposed rule gives a clear preview of what a strong heat program looks like. It's built around 2 heat exposure triggers, generally based on the heat index or wet bulb globe temperature (WBGT):

Initial heat trigger, generally starting at a heat index of 80°F. This is when core protections kick in: cool drinking water within easy reach (at least 1 quart per worker per hour), shaded or cooled rest areas, indoor cooling measures like fans or air conditioning where feasible, acclimatization for new and returning workers, and paid rest breaks as needed (9).
High heat trigger, generally starting at a heat index of 90°F. At this level, the proposed rule adds more structure, including paid 15-minute rest breaks at regular intervals, active observation of workers for signs of heat illness, and clear hazard alerts (9).

The proposal would also call for a written, site-specific Heat Injury and Illness Prevention Plan (HIIPP), employee and supervisor training, and recordkeeping (9). In plain terms, this is the written system that tells supervisors and employees how heat will be monitored, when protections start, and what to do if someone shows signs of heat illness. Think of it like your lockout/tagout or hazard communication program: a documented, repeatable system, not a one-page policy that sits in a drawer.

What This Looks Like in Your Industry

Heat shows up differently depending on the work. Here's what matters most in the sectors we see every day. Of these, construction, automotive repair, and warehousing and distribution appear on OSHA's updated target list of high-risk industries, and quick lube shops fall under the same automotive repair code (4). Commercial printing isn't on the targeted list, but a heat hazard in plain view can still prompt an inspection (4), so the same preparation applies.

Construction. Direct sun, heavy exertion, hot surfaces, and protective gear all stack up fast. The fix is to build heat planning into the jobsite itself: stage water and shade at each active work area, schedule the heaviest tasks for cooler hours, and give foremen the authority to adjust the pace when conditions or symptoms call for it.

Auto service. Shops are easy to overlook because the work is indoors, but open bay doors, radiant heat from engines and exhaust, and limited airflow can push bay temperatures well past the outdoor reading. Keep water within reach in the bays, designate a cool-down area close by but out of the heat, add fans or spot cooling where it collects, and fold heat awareness into your existing safety training.

Distribution and warehousing. Loading docks, mezzanines, and high-bay storage can trap heat and humidity, and heat interacts with other risks like forklift traffic and fatigue. High-volume fans, better dock ventilation, worker rotation out of the hottest zones, and structured hydration and rest go a long way here.

Commercial printing. Print facilities can generate heat from several sources that are easy to overlook. Heatset presses and drying systems push high temperatures into the pressroom, and large equipment, motors, and curing units add radiant heat that builds through the day, often in buildings without full climate control. Higher temperatures can also affect how solvents, inks, and coatings behave, making ventilation and chemical handling part of the heat safety conversation. Focus on ventilation and spot cooling around presses and dryers, keep water and cool-down areas near the press lines rather than down the hall, and track indoor temperatures the way an outdoor crew watches the forecast.

Quick lube shops. Hot engines, enclosed service pits, open doors, and a fast summer pace mean workers can easily skip water and rest without realizing it. The key is designing breaks and hydration into daily operations, so heat protection becomes part of the service flow rather than an interruption to it.

A Practical Roadmap for Getting Ahead

You don't need to overhaul everything at once. A strong, defensible heat program comes down to a few clear moves:

Put your plan in writing. Create a site-specific heat illness prevention plan that names who's responsible, how heat conditions are monitored, and exactly what happens at each heat level. Connect it to the safety programs you already have.
Set clear triggers and actions. Use the heat index or WBGT to define action levels, then spell out the matching water, rest, and scheduling steps for each one.
Upgrade water, rest, and cooling. Make sure cool water is genuinely within reach all shift, and that cool-down areas are close and comfortable enough that people actually use them.
Plan for acclimatization. New hires, seasonal workers, and anyone returning from time off need to build heat tolerance gradually. A common approach is to start new workers at about 20 percent of the normal workload and increase steadily over 1 to 2 weeks (10).
Train and document. Teach workers and supervisors to spot early warning signs, respond quickly, and keep simple records of monitoring, training, and any incidents.
Prepare for heat-related emergencies. Make sure supervisors know when to stop work, how to cool an affected employee quickly, who calls emergency services, and how to document the response (10).

This is also where a compliance partner earns its keep. A focused site assessment of your hottest zones, a written program built for your operation, hands-on (and where needed, bilingual) training, simple supervisor checklists, and ongoing recordkeeping support can turn this list into a practical system your team can follow consistently.

Monitoring tools, from handheld WBGT meters to wearable sensors, can support all of this. Just remember that technology backs up a solid program; it doesn't replace water, rest, shade, training, and emergency response.

How GMG EnviroSafe Helps

Building and maintaining a heat program takes time that most operations can't spare in the middle of a busy season. That's where HealthAssure, GMG's comprehensive worker health and safety program, can support your team. It approaches heat the way it approaches any exposure: identify the hazard, put real controls in place, and make the safe way the standard way of working. The aim is a program that holds up under an inspection and, more importantly, keeps people healthy and on the job.

In practice, that means assessing where your facility actually runs hottest, writing a prevention plan around those findings, training supervisors to act on early symptoms, and keeping the records that prove the work was done. Handled this way, heat management stops being a seasonal scramble and becomes part of how the operation runs.

GMG EnviroSafe can assess your heat exposure, build the written plan, train your team, and document what regulators expect to see. With OSHA's heat focus set to continue through 2031, that groundwork helps employers stay prepared, protect their teams, and keep compliance moving in the right direction.

Ready to review your heat exposure? Schedule a free consultation with GMG EnviroSafe.

This article is for general informational purposes and reflects OSHA guidance and proposed rulemaking as of mid-2026. Requirements vary by state and can change. For guidance specific to your facility, reach out to GMG EnviroSafe.

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Sources

(1) National Institute for Occupational Safety and Health. (2026). Heat Stress and Workers. Retrieved from: https://www.cdc.gov/niosh/heat-stress/about/index.html

(2) Occupational Safety and Health Administration. (2024–2026). Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings Rulemaking. Retrieved from: https://www.osha.gov/heat-exposure/rulemaking

(3) Occupational Safety and Health Administration. (2026). US Department of Labor Updates National Emphasis Program to Protect Workers From Indoor, Outdoor Heat Hazards. Retrieved from: https://www.osha.gov/news/newsreleases/osha-national-news-release/20260410

(4) Occupational Safety and Health Administration. (2026). Directive CPL 03-00-024, National Emphasis Program – Outdoor and Indoor Heat-Related Hazards (Appendix A, Target Industries). Retrieved from: https://www.osha.gov/sites/default/files/enforcement/directives/CPL_03-00-024_0.pdf

(5) Occupational Safety and Health Administration. Heat – Standards (State Heat Standards). Retrieved from: https://www.osha.gov/heat-exposure/standards

(6) California Division of Occupational Safety and Health (Cal/OSHA). (2024). Heat Illness Prevention Guidance and Resources (CCR, Title 8, Sections 3395 and 3396). Retrieved from: https://www.dir.ca.gov/dosh/heatillnessinfo.html

(7) Maryland Occupational Safety and Health (MOSH). (2024). Heat Stress Standard (COMAR 09.12.32), effective September 30, 2024. Retrieved from: https://labor.maryland.gov/labor/mosh/moshheatstress.shtml

(8) Nevada Division of Industrial Relations, Occupational Safety and Health Administration (Nevada OSHA) / SCATS. (2025). Guidance for Regulation R131-24AP: Heat Illness Prevention (enforcement effective April 29, 2025). Retrieved from: https://www.4safenv.state.nv.us/news/guidance-on-nevada-heat-illness-regulation-finalized-r131-24ap/

(9) Occupational Safety and Health Administration. (2024). Proposed Rule Fact Sheet: Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. Retrieved from: https://www.osha.gov/sites/default/files/publications/heat-rulemaking-factsheet.pdf

(10) National Institute for Occupational Safety and Health. (2026). Workplace Recommendations: Heat Stress (acclimatization, hydration, rest, controls, and training). Retrieved from: https://www.cdc.gov/niosh/heat-stress/recommendations/

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