Quick Hits
- FIFA has introduced mandatory hydration breaks during all matches at the 2026 World Cup to prioritize player welfare amid hot and humid conditions.
- The hydration breaks may also serve as a reminder for U.S. employers of their legal obligations to prevent heat-related illnesses in outdoor workers, particularly as OSHA increases enforcement efforts.
- OSHA’s renewed emphasis on heat-hazard prevention suggests increased inspections into heat-related hazards in outdoor and indoor work environments, particularly during “heat priority days” or following heat-related injuries.
FIFA, the international governing body for the sport of soccer, has mandated that all 104 matches at the 2026 World Cup take a three-minute hydration break midway through each half to prioritize “player welfare.” But while FIFA has instituted hydration breaks in past tournaments, the 2026 World Cup marks the first time they are required at every match, regardless of weather conditions or whether the match is played in an indoor stadium.
Soccer fans and pundits are debating how these changes will impact play and strategy in matches, as matches have traditionally used a continuously running ninety-minute clock, split into two forty-five–minute halves, with no formal clock stoppages other than the halftime and full-time whistles. Regardless, the hydration breaks address a real risk to player safety in hot, humid summer conditions, which are likely to exist in many host cities across North America.
More broadly, the World Cup’s hydration breaks may serve as a reminder of such heat-related risks for all workers laboring outdoors, and U.S. employers’ legal obligations to address them—including providing hydration breaks on hot days—as the Occupational Safety and Health Administration (OSHA) ramps up enforcement of outdoor and indoor heat-hazard prevention obligations.
Heat-Related Risks
OSHA has warned that physical activity in high temperatures, humidity, and sun exposure, together with limited air movement, can increase the risk of heat-related illnesses, such as dehydration, heat exhaustion, and heat stroke. Those risks are increased for individuals who are pregnant or who have obesity or heart disease. Data from the U.S. Department of Labor’s (DOL) Bureau of Labor Statistics (BLS) indicates that between 2021 and 2024, environmental heat exposure resulted in an average of forty-eight worker fatalities per year. However, these statistics likely do not capture the true magnitude and prevalence of heat-related injuries, illnesses, and fatalities.
Further, dangerous outdoor heat levels may be lower than some employers might expect. OSHA emphasizes that when the heat index reaches 80°F or higher, as measured by the National Weather Service (NWS), “serious occupational heat-related illnesses and injuries become more frequent.” Risks can be exacerbated by the type of labor with intense, strenuous work, such as lifting, carrying heavy loads, or digging.
Compliance Obligations and Shifting U.S. Regulations
In recent years, OSHA has increased its focus on the risks associated with heat exposure. OSHA has pursued rulemaking to establish a permanent federal standard for heat injury and illness prevention, most recently publishing a notice of proposed rulemaking in August 2024. While that rulemaking effort has stalled, OSHA has continued to emphasize employers’ obligations to prevent outdoor and indoor heat hazards under the General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health (OSH) Act. Between calendar years 2022 and 2025, Federal OSHA conducted on average approximately 2,400 heat-related hazard inspections each year.
In April 2026, OSHA updated and renewed its National Emphasis Program (NEP) for outdoor and indoor heat-hazard prevention, replacing its expiring program with a new, aggressive directive that will be operative “for no more than five years” from its effective date (April 10, 2026) and will likely run until April 2031. The NEP notes that heat-related inspections accounted for 6 percent of all federal occupational safety and health inspections during the last five years, and targets fifty-five high-risk industries and worksites with heat-related hazards.
The NEP introduces the concept of “heat priority days,” which occur when the heat index is expected to reach 80°F or higher. On such days, area officers are directed to assess the potential for serious heat-related illnesses at both outdoor and indoor worksites. That means an inspector already present at an employer’s facility for an unrelated matter may expand the scope of that inspection if heat hazards are visible or alleged. Moreover, “programmed inspections shall occur on any day that the NWS has announced a heat warning or advisory for the local area.”
Employers that have previously been cited for heat-related violations face heightened scrutiny under the revised NEP. Initial follow-up inspections must be conducted for establishments cited following a heat-related fatality to verify that abatement has been implemented. Additional follow-up inspections are required for any establishment that received serious violations for heat-related hazards.
Key Takeaways
The NEP’s Appendix I provides a checklist that OSHA compliance safety and health officers (CSHOs) will use to evaluate employer heat programs during each inspection and that employers may want to note to help prevent and mitigate heat illnesses and injuries. The checklist’s areas of inquiry and emphasis suggest an approach for employers.
- Establish a written heat illness plan. The NEP states that inspectors will ask whether an employer has a written or verbal heat program and whether it has been effectively communicated to employees.
- Designate a heat safety representative. OSHA inspectors will specifically ask whether the heat program is “properly implemented and managed by a designated heat safety representative.”
- Implement water, rest, shade, and acclimatization measures. The NEP states that inspectors will examine whether “sufficient amounts of cool water [were] easily accessible” to workers, whether hydration and rest breaks were provided, whether shaded or cool areas were available, and whether workers were given periods to acclimate to the heat.
- Train staff. The NEP suggests that workers must be educated on recognizing and reporting the signs and symptoms of heat exhaustion and heat stroke, as well as on rendering basic first aid.
- Monitor conditions. The NEP indicates that inspectors will look at how an employer monitored ambient temperatures and levels of work exertion at the worksite.
