OSHA has revised and renewed its National Emphasis Program for heat-related hazards. Here’s what changed, which industries are now targeted, and how your team can stay compliant ahead of an OSHA visit.
What Is a National Emphasis Program?
If you haven’t heard the term before, you’re not alone, but if your business operates in a hot environment, you need to understand it.
A National Emphasis Program (NEP) is a formal directive from OSHA that focuses the agency’s enforcement resources on a specific hazard or high-risk industry. Think of it as OSHA officially declaring: “We are going to actively look for this danger, and we are going to inspect far more often.”
NEPs are temporary programs that typically last up to five years, and they apply across all OSHA regions nationwide. They authorize compliance officers to conduct unannounced, programmed inspections of targeted businesses, without needing a prior complaint or incident report to justify showing up.
OSHA currently maintains several active National Emphasis Programs covering hazards such as combustible dust, silica, trenching and excavation, amputations in manufacturing, warehousing, and most relevant heading into summer, heat-related illness and injury.
What Is the OSHA Heat Stress National Emphasis Program?
The Heat NEP is OSHA’s enforcement push to prevent heat-related illness and death across general industry, construction, maritime, and agriculture for both outdoor and indoor workplaces. It was first launched on April 8, 2022, under Directive CPL 03-00-024.
After a one-year extension in January 2025, OSHA fully revised the program and relaunched it on April 10, 2026, for a new five-year term. The 2022 directive is cancelled. This version replaces it.
Here’s what the update means in practice: on any day the National Weather Service issues a heat warning or advisory in your area, OSHA can inspect a targeted business without warning, without a complaint, and without an incident. Inspectors can also expand any visit already in progress the moment they observe a heat hazard on site.
Download the official OSHA directive here.
CPL 03-00-024: National Emphasis Program — Outdoor and Indoor Heat-Related Hazards · Effective April 10, 2026
New Citation Guidance and Documentation Expectations
The 2026 update includes formalized citation guidance in Appendix J that significantly raises the bar for how heat exposure must be documented. When an inspector visits your site, they are now required to record a precise set of environmental conditions and tie those conditions directly to the workload and PPE worn by employees at the time.
This reflects a shift toward data-driven enforcement where conditions must be quantified, not just described.
What Inspectors Are Now Required to Document
Under Appendix J, compliance officers must observe and document all of the following at the time of the inspection or reconstruct them for prior incidents:
- Heat index
- Relative humidity
- Dry bulb temperature at the workplace
- Wind speed
- Wet Bulb Globe Temperature (WBGT) — noted in the directive as the more accurate indicator of heat effects on individuals than dry bulb temperature alone
- Radiant heat sources present at the worksite
- Environmental conditions tied directly to workload and PPE worn
- Cloud cover (documented as none, 25%, 50%, 75%, or 100%)
- Heat advisories, warnings, or alerts issued by the NWS on the day of the incident and previous days
Why This Matters for Employers
If an inspector’s on-site readings are the only record of what conditions were that day, you have no way to challenge or contextualize them. Inspectors are also explicitly instructed to reconstruct historical conditions when an incident occurred on a prior day, using nationally available weather data tools.
That means the data used to build a citation against you could come from a weather station miles away, during a time window you cannot verify. The employers who are best protected are the ones who already have their own continuous, site-specific record to present.
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OSHA Heat NEP Employer Compliance Checklist
12 sections drawn directly from OSHA Appendix I · Directive CPL 03-00-024 · PDF
Does OSHA’s Heat NEP Apply to Indoor Workplaces?
The NEP covers both outdoor and indoor workplaces. While outdoor workplaces may be an obvious target for inspection, indoor environments with radiant heat sources are explicitly named as priority inspection targets. On any high heat day (80°F+ heat index outside), inspectors conducting visits for any reason must assess indoor heat conditions and can expand the scope of any open inspection on the spot. Your facility does not need to be outdoors, and the weather outside does not need to be extreme, for a heat inspection to happen inside.
The practical implication: If your facility has equipment like foundries, boilers, or steam lines that drive the ambient temperature, you need the same monitoring, documentation, and response protocols as any outdoor employer under this NEP.
How employers can prepare for OSHA’s Heat Stress NEP
- Have continuous on-site heat stress monitoring of heat index, WBGT, ambient temperature, and humidity at your exact location both indoors and outdoors. Deploy weather stations or indoor heat sensors where employees are working whether indoors or outdoors
- Have a way to reliably record the data so historical conditions are available on demand. If an inspector reconstructs a prior incident, you can present your own site-specific heat index or Wet Bulb Globe temperature log from that exact day.
- Document the actions you take when conditions rise. Appendix I asks whether there was access to a shaded area, whether breaks were scheduled, and whether hydration was encouraged — so keep records showing workers had shade or cool indoor space, scheduled rest, and ready access to cool water during high-heat periods.
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What Changed in the 2026 Update?
The 2026 revision isn’t cosmetic. Several substantive changes make this update more impactful for employers than the original 2022 directive.
Which Industries Are Targeted by the OSHA Heat NEP?
The updated NEP covers 55 high-risk industries drawn from Bureau of Labor Statistics data and OSHA’s own enforcement history from 2021 through 2025. The list is broader than most employers expect, extending well beyond obvious outdoor jobs.
Outdoor and Construction
All residential and nonresidential construction, highway and bridge work, utility construction, foundation work, building finishing, and specialty trade contractors are included. Inspectors use OSHA’s C-Target system to identify active construction sites on heat advisory days.
Manufacturing and Industrial
Steel production, foundries, nonferrous metals, petroleum and coal products, bakeries, animal slaughtering and processing, cheese manufacturing, sawmills, plastic products, cement, and automotive repair facilities are all targeted. Indoor radiant heat sources are specifically covered under this NEP.
Transportation and Logistics
Warehousing and storage, couriers and delivery services, local messengers, trucking (general freight), air transportation and support activities, and support activities for rail and water transportation are all on the target list.
Agriculture
Cattle ranching, hog farming, support activities for crop production, vegetable and melon farming, and greenhouse and nursery operations are included in the target list.
Newly Added Industries in OSHA’s 2026 NEP Update
Among the 22 industries added in this update: department stores, hog and pig farming, cheese manufacturing, animal slaughtering and processing, plastic product manufacturing, scheduled air transportation, general freight trucking, community food and housing services, management consulting, architectural and engineering services, telecommunications carriers, inland water transportation, electric power generation, and individual and family services.
Not sure if your industry is on the list? The key question is whether your workers perform physically demanding tasks in warm environments, indoors or outdoors. If yes, assume you are in scope regardless of exact NAICS code.
When Can OSHA Show Up Under the Heat NEP?
Under the updated Heat NEP, there are multiple paths that can bring a compliance officer to your door.
On Heat Advisory Days
Whenever the NWS issues a heat warning or advisory for the local area, OSHA Area Offices are authorized to begin unannounced programmed inspections of targeted businesses. No prior complaint required.
Heat Priority Days (80°F+ Heat Index)
If an inspector is already on-site for any reason and the heat index is 80°F or higher, they are required to also assess heat hazards and can expand the scope of the inspection to cover them.
Drive-By Observations
Compliance officers are explicitly told to stop at outdoor worksites they observe while in transit on advisory days. Construction sites, roofing crews, landscapers, and highway workers are all fair game. These stops are coded as “Unprogrammed Emphasis Hazard” inspections — a new OSHA coding category added in the 2026 update.
Complaints, Referrals, and Fatalities
Any employee complaint about lack of water, rest, or shade is prioritized for an on-site inspection. So is any employer-reported heat hospitalization or fatality — rapid remote response is only permitted in limited cases with Area Director approval.
What Will Inspectors Look For?
The new Appendix I evaluation checklist gives a clear picture of what OSHA will assess when they arrive at your worksite. Here’s what every employer in a targeted industry should have in place.
What Should Companies Do Right Now?
| 1 |
Confirm Whether Your Industry Is Targeted by OSHA’s Heat NEPCheck whether your NAICS code appears in the 55 targeted industries. If you’re in construction, agriculture, warehousing, manufacturing, food service, or transportation, assume you are targeted for heat-related inspections. |
| 2 |
Audit Your Heat Illness Prevention Program Against OSHA’s Appendix I ChecklistAppendix I is OSHA telling you exactly what inspectors will check. Go through each item: Do you monitor ambient temperature? Is cool water accessible? Are rest breaks scheduled? Have new employees been acclimatized to heat conditions? |
| 3 |
Set Up Real-Time Heat Index Monitoring at Every WorksiteOSHA doesn’t require automated monitoring, but inspectors under Appendix J document heat index, WBGT, humidity, wind, and cloud cover when they arrive, and reconstruct conditions from public weather data if you don’t have your own records. Continuous, site-specific monitoring lets you produce that record on demand and alert teams the moment conditions cross the 80°F heat priority threshold. |
| 4 |
Know the Moment a National Weather Service Heat Advisory Is Issued for Your AreaOSHA’s programmed heat inspection trigger is a NWS heat warning or advisory for your local area. Knowing when one has been issued, before OSHA does, is your single biggest heat NEP compliance advantage. |
| 5 |
Document All Heat Safety Records to Demonstrate OSHA ComplianceInspectors will ask for OSHA 300 logs, training records, temperature monitoring logs, and incident documentation. Companies with organized, contemporaneous records are in a fundamentally stronger position when facing a heat-related OSHA inspection. |
How Perry Weather Helps Companies Stay OSHA Heat NEP Compliant
Perry Weather is the weather monitoring and alerting platform built specifically for workplaces that operate outdoors or demanding high heat environments. OSHA’s heat inspection triggers are tied directly to National Weather Service heat advisories and specific heat index thresholds, the exact same data Perry Weather monitors in real time at your specific worksite locations
Every row above is documented automatically. Perry Weather creates the timestamped records, alert logs, and historical reports that prove compliance if an inspector asks for them.
How Perry Weather Works
Perry Weather’s heat stress monitoring system runs automatically once installed. There are no manual readings, no tripods to set up, and no spreadsheets to maintain. Here is what it does:
- On-site heat stress monitoring. An on-site weather station measures heat index, WBGT, and ambient temperature alongside humidity at your exact location every 5 minutes. Readings come from your site, not a distant airport sensor.
- Automated alerts with custom instructions. When conditions cross a threshold you define, Perry Weather pushes an alert directly to your team’s phones with a custom message your team writes — whether that means hydrate, move to shade, or stop work entirely.
- Adaptive work/rest schedules. Perry Weather’s work/rest cycle feature automatically calculates safe work and rest intervals based on real-time conditions, adjusting for work intensity, PPE worn, and acclimatization status. A 72-hour forecast lets supervisors plan ahead before the day starts.
- Historical reporting. Every reading is stored automatically and available for export at any time. If an OSHA inspector needs to reconstruct conditions from a prior day, your site-specific record is ready.
Perry Weather does more than heat. The same platform handles lightning detection, severe weather alerts, air quality monitoring, and outdoor warning sirens and strobes — all from one on-site weather station and a single dashboard your whole team can access.
See why Holder Trusts Perry Weather for Weather Monitoring
Frequently Asked Questions
What is the OSHA National Emphasis Program?
A National Emphasis Program (NEP) is a temporary, formal enforcement initiative from the federal Occupational Safety and Health Administration (OSHA). NEPs direct the agency to focus its inspection resources on a specific hazard or set of high-risk industries. Under an NEP, OSHA compliance officers are authorized to conduct unannounced, proactive inspections of targeted businesses, without waiting for a complaint or incident. NEPs are evaluated using Bureau of Labor Statistics injury data, NIOSH reports, and OSHA’s own enforcement history, and they typically run for up to five years. Current active NEPs cover hazards including heat, silica, combustible dust, trenching, warehousing, and amputations in manufacturing.
What are National Emphasis Programs and how are they different from regular OSHA enforcement?
Regular OSHA enforcement is mostly reactive. An inspector shows up because someone filed a complaint, a worker was injured, or an employer self-reported a hospitalization. National Emphasis Programs change that model by authorizing proactive, scheduled inspections of businesses in targeted industries, even when no incident has occurred. Under an NEP, establishments are selected from randomized lists and can be inspected on any day that conditions meet the program’s trigger criteria. There are also Local Emphasis Programs (LEPs) at the regional or area office level, and Regional Emphasis Programs (REPs). NEPs are the broadest and most powerful, applying nationwide.
What is the national emphasis program for heat, and is it new?
OSHA’s Heat NEP was first launched on April 8, 2022, under Directive CPL 03-00-024. It was extended for one additional year in January 2025 before being fully revised and relaunched on April 10, 2026. The 2026 version replaces the 2022 version entirely and will remain active for up to five years. The updated program covers outdoor and indoor heat hazards in general industry, construction, maritime, and agriculture, and now targets 55 high-risk industries, including 22 newly added sectors.
What triggers an OSHA heat inspection under the NEP?
There are several triggers. The most common is a National Weather Service (NWS) heat warning or advisory for the local area. On those days, OSHA Area Offices are authorized to begin pulling target businesses from their lists for unannounced inspections. Any day with an expected heat index of 80°F or higher is designated a “heat priority day,” on which inspectors conducting visits for other purposes must also assess heat hazards. Inspectors are also instructed to stop at outdoor worksites they observe while traveling between other jobs on advisory days. Additionally, any employee complaint alleging inadequate heat protections, or any employer-reported heat-related hospitalization or fatality, will trigger a priority on-site inspection.
What is the national emphasis program for the month of March?
There is no OSHA National Emphasis Program specifically designated for the month of March. NEPs are not organized by calendar month. They target specific hazards or industries on an ongoing basis. However, the Heat NEP becomes especially active in spring and summer months when the National Weather Service begins issuing heat advisories. In areas like Texas, Florida, and the Southwest, heat advisories can begin as early as April or May, which means the Heat NEP’s programmed inspections can begin shortly after the spring season starts. Other active NEPs, such as those covering silica, trenching, warehousing, and amputations in manufacturing, run year-round.
Which industries are targeted by the OSHA heat stress NEP?
The 2026 Heat NEP identifies 55 target industries across three categories. Non-construction industries in OSHA’s system (ListGen) include cattle ranching, hog farming, sawmills, petroleum manufacturing, foundries, steel production, bakeries, warehousing, couriers, landscaping services, waste collection, and automotive repair. Construction industries include all major categories: residential and nonresidential building, utilities, highways, and specialty contractors. Industries not in ListGen include restaurants, vegetable farming, postal service, management consulting, electric power utilities, employment services, and individual and family services. The 22 newly added industries include trucking, department stores, scheduled air transportation, plastic product manufacturing, community food services, and telecommunications.
Does the OSHA heat NEP apply to indoor workplaces?
Yes. The full name of the directive is “National Emphasis Program: Outdoor and Indoor Heat-Related Hazards.” Indoor workplaces with radiant heat sources, such as steel mills, foundries, bakeries, laundries, and industrial kitchens, are specifically included. Inspectors are instructed to assess heat conditions in indoor work areas on heat priority days and to include a review of heat hazards in any inspection occurring at a facility with radiant heat sources, regardless of the original reason for the visit.
How long will the Heat NEP be in effect?
The updated Heat NEP took effect on April 10, 2026, and is active for up to five years from that date, unless cancelled or replaced by a superseding directive. Given that OSHA has renewed this program twice since 2022 and a permanent heat illness standard remains under development, employers should plan around the NEP being a long-term enforcement reality.
