The Occupational Safety and Health Administration (OSHA) has revised its National Emphasis Program (NEP) addressing indoor and outdoor heat-related hazards, effective April 10, 2026. The updated directive is designed to focus inspections and outreach on industries and workplaces where heat-related risks are most likely to occur.
Primary Differences
Although the revised NEP formally cancels and replaces the previous April 8, 2022, directive, it continues OSHA’s enforcement emphasis on heat hazards in general industry, construction, maritime, agriculture, and other targeted industries. Compared to the prior version, the revised NEP uses more recent data to identify these target industries. It also removes outdated background material and references, updates links, revises the inspection goal, and adds reorganized appendices addressing heat-program evaluation and citation guidance.
Program Framework and Scope
OSHA states that the program’s overarching goal is to reduce worker exposure to heat-related hazards that may result in illness, injury, or death by targeting industries or worksites where employees may lack adequate protections.
According to the U.S. Department of Labor, the program relied on OSHA and Bureau of Labor Statistics data from 2022 through 2025 to establish inspection priorities for 55 high-risk industries. OSHA removed 46 target industries from the prior list, retained 33, and added 22 industries.
The NEP also authorizes compliance officers to expand the scope of inspections where there is evidence of heat-related hazards or when inspections occur during “heat priority days,” defined as days when the heat index is expected to reach 80 degrees Fahrenheit or higher. In addition, programmed inspections are directed to occur on any day that the National Weather Service has announced a heat warning or advisory for a local area.
While OSHA does not currently require employers to adopt a formal heat illness prevention program at the federal level, the revised NEP instructs compliance officers to assess whether employers have implemented effective heat related controls when evaluating potential hazards. In doing so, compliance officers are directed to consider a range of programmatic and operational factors, including whether the employer has:
- Monitored environmental conditions and work exertion;
- Provided access to cool potable water, rest, shade, and acclimatization opportunities;
- Utilized administrative controls to limit heat exposure;
- Trained employees on heat illness recognition and response; and
- Designated oversight for managing heat related safety measures.
Enforcement
In the absence of a federal heat illness standard, citations issued under the NEP generally rely on the Occupational Safety and Health Act’s general duty clause, which requires OSHA to establish the existence of a recognized hazard and feasible means of abatement. In addition, OSHA may rely on existing standards that address related requirements, such as sanitation standards that require employers to provide potable water. For agricultural operations, OSHA’s field sanitation standard further requires employers to provide employees with cool potable water.
Next Steps and Key Takeaways
The updated program is effective immediately and will remain in place for five years unless otherwise canceled or superseded by another directive.
While the NEP indicates that State Plans are not required to adopt the revised program, OSHA strongly encourages them to do so. Employers should also be aware of a growing number of state-level laws and regulations addressing workplace heat exposure, with additional measures pending in other jurisdictions.
Employers should consider reviewing their heat illness prevention practices in light of OSHA’s updated inspection priorities and enforcement focus, as well as applicable state-level standards. If you have questions about workplace heat hazards or OSHA’s revised NEP and how it could affect your organization, contact a Jackson Lewis attorney.
