OSHA's Heat Stress National Emphasis Program: What Every Employer Needs to Know in 2026

OSHA’s Heat Stress National Emphasis program has been revised and renewed on April 10, 2026, effective through April 10, 2031 for heat-related hazards in the workplace. 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?

The 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. 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, and heat-related illness and injury.

What is the OSHA Heat Stress National Emphasis Program?

The OSHA Heat-Stress National Emphasis program is the administration’s newest approach to preventing illnesses and deaths among workers during high heat conditions, such as working outdoors in a local area experiencing a heat wave, as defined by the National Weather Service. It replaces the 2022 directive CPL-03-00-024.

The OSHA heat stress national emphasis program (NEP) describes policies and procedures for implementation and sets forth a targeted enforcement component, alongside offering compliance assistance and outreach efforts. 

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 expand an existing visit when they observe a heat hazard on site.

What Changed in OSHA’s Heat NEP in 2026?

The 2026 update to OSHA’s heat stress NEP changes industry targeting, reorganizes the heat program’s evaluation and citation guidance, revises the inspection goal, and adds tracking parameters for outreach and enforcement. While it updates an enforcement program, it is separate from OSHA’s proposed federal heat standard.

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. Employers should check their four-digit NAICS code against the official list rather than assume that every business in a broad sector is selected for programmed inspections.

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.

What Triggers an OSHA Heat Inspection?

An OSHA heat inspection can follow a local NWS heat advisory or warning, a complaint or referral, a severe incident, or evidence of heat hazards during another inspection or while an officer is traveling. A heat priority day prompts assessment of potential heat hazards; it does not establish a universal employer stop-work threshold.

What workplace heat laws and regulations apply during an inspection?

Workplace heat laws, heat stress regulations, and applicable OSHA standards establish employer obligations during a heat inspection. The OSHA Heat NEP directs inspection targeting and procedures; it does not independently create new heat stress standards.

Under the General Duty Clause, OSHA must establish the elements of a violation before issuing a heat-related citation. Appendix J in OSHA’s Heat NEP also identifies existing standards that may apply, including sanitation and drinking water, PPE, medical services and first aid, recordkeeping, and construction safety training. A heat inspection can evaluate an organization’s existing obligations in this area.

State heat protections differ in scope and requirements. Appendix H lists heat-related standards in California, Colorado, Maryland, Minnesota, Nevada, Oregon, and Washington, but it should not be read as a uniform heat stress standard for every employer in those states. State Plans are strongly encouraged, but not required, to adopt the updated federal NEP.

The OSHA heat standard proposal is a separate rulemaking from the Heat NEP. The proposal would establish a federal standard for heat injury and illness prevention, while the NEP directs enforcement of existing obligations. Employers should distinguish proposed requirements from the rules that currently apply to their workplace. Read our guide to current workplace heat laws and OSHA requirements for detailed legal context, and check OSHA’s heat rulemaking page for updates.

What Do Inspectors Evaluate under the Heat NEP?

Inspectors evaluate how an employer identifies and controls heat hazards, communicates its heat program, and documents conditions. Appendix I contains 11 heat program evaluation questions; Appendix J explains citation guidance and the evidence relevant to heat exposure. This OSHA heat stress NEP chart shares what every employer in a targeted industry should have in place under the OSHA heat stress NEP.

Appendix I heat program evaluation

The evaluation covers the following areas. These are inspector evaluation questions, not a new standalone federal heat standard.

• A heat program, written or verbal, effectively communicated to employees.
• Monitoring ambient temperature and levels of work exertion at the worksite.
• Sufficient cool water easily accessible to employees.
• Additional breaks for hydration.
• Scheduled rest breaks.
• Access to a shaded area.
• Acclimatization time for new and returning workers.
• Administrative controls, such as earlier starts, workload adjustments, and job rotation.
• Training on heat illness signs, reporting, first aid, emergency contact procedures, prevention, and hydration.
• Employee and supervisor understanding of the heat program.
• Proper implementation and management by a designated heat safety representative.

Download the OSHA Heat NEP Employer Compliance Checklist — 12 sections adapted from Appendix I, with an additional recordkeeping section based on Appendix J and applicable OSHA requirements.

Appendix J exposure documentation

Appendix J explains how OSHA evaluates heat stress exposure when developing a potential citation. Inspectors document environmental conditions alongside workload, clothing, and equipment, including conditions at the time of a previous incident. The documentation includes:

• Heat index and NWS heat alerts.
• Relative humidity and observed wind speed.
• Dry bulb temperature at the workplace and shaded rest area.
• Wet bulb globe temperature (WBGT) at the workplace.
• Cloud cover, recorded as none, 25%, 50%, 75%, or 100%.
• Workload and heavy or bulky clothing or equipment.
• Relevant heat-generating operations or radiant heat sources.

The OSHA heat NEP describes WBGT sampling as a more accurate indicator of heat effects on individuals than dry bulb temperature alone. Site-specific monitoring and records of protective actions can help employers explain actual worksite conditions, including when an inspector reviews a prior incident. Records support an evaluation; they do not guarantee compliance.

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.

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

See Why Holder Trusts Perry Weather for Weather Monitoring

See how a construction site uses weather monitoring to support worksite decisions.

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.

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