National Emphasis Program – Outdoor and Indoor Heat-Related Hazards

U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration
DIRECTIVE NUMBER: CPL 03-00-024
SUBJECT: National Emphasis Program – Outdoor and Indoor Heat-Related Hazards
DIRECTORATE: Directorate of Enforcement Programs
SIGNATURE DATE: April 10, 2026 EFFECTIVE DATE: April 10, 2026
ABSTRACT
Purpose: This Instruction describes policies and procedures for the continued
implementation of a National Emphasis Program (NEP) to protect
employees from heat-related hazards and resulting injuries and illnesses
in outdoor and indoor workplaces in general industry, construction,
maritime, and agriculture. This NEP sets forth a targeted enforcement
component and reiterates compliance assistance and outreach efforts.
This approach is intended to encourage early interventions by employers
to prevent illnesses and deaths among workers during high heat
conditions, such as working outdoors in a local area experiencing a heat
wave, as announced by the National Weather Service.
Scope: This Instruction applies OSHA-wide.
Ref
erences: Section 5(a)(1) of the Occupational Safety and Health Act (OSH Act), 29
U.S.C. § 654.
OSHA Instruction, CPL 02-00-164, Field Operations Manual (FOM), April
14, 2020.
(See Section III for additional references.)
Cancellations: CPL 03-00-024, National Emphasis Program – Outdoor and Indoor Heat-
Related Hazards, April 8, 2022.
State Impact: Notice of Intent Required, Adoption Encouraged. See Section VI.
Action Offices: OSHA Regional and Area Offices, State Plan and OSHA On-Site
Consultation programs
Or
iginating Office: Directorate of Enforcement Programs, Office of Health Enforcement

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Contact: Office of Health Enforcement
Directorate of Enforcement Programs
200 Constitution Avenue, NW, Room N3119
Washington, DC 20210

By and Under the Authority of

DAVID L. KEELING
Assistant Secretary

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Executive Summary

This Instruction describes policies and procedures for the continued implementation of a
National Emphasis Program (NEP) to identify and eliminate or reduce worker exposures to
occupational heat-related illnesses and injuries in general industry, construction, maritime, and
agriculture. It targets specific industries expected to have the highest exposures to heat-
related hazards and resulting illnesses and deaths.

Significant Changes

This revised Instruction describes an update to the original Heat NEP, CPL 03-00-004, April 8,
2022. The following list highlights differences between this revised NEP and the original NEP:
• Updated target industries using current data from BLS and OSHA (Appendix A)
• Removed outdated background information and references
• Updated links
• Revised inspection goal
• Reorganized and Added Appendix I: Evaluation of a Heat Program
• Reorganized and Added Appendix J: Citation Guidance
• Added coding for Worksite Assistance
• Added coding for Unprogrammed Emphasis Hazards

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Table of Contents

I. Purpose. ................................................................................................................................... 1
II. Scope. ...................................................................................................................................... 1
III. References. .............................................................................................................................. 1
IV. Cancellations. .......................................................................................................................... 2
V. Action Offices. ......................................................................................................................... 2
A. Responsible Office. ......................................................................................................... 2
B. Action Offices. ................................................................................................................ 2
C. Information Offices. ....................................................................................................... 2
VI. Federal Program Change. ........................................................................................................ 2
VII. Expiration................................................................................................................................. 3
VIII. Significant Changes. ................................................................................................................. 3
IX. On-Site Consultation Programs. .............................................................................................. 3
X. Background. ............................................................................................................................. 4
XI. NEP Goal. ................................................................................................................................. 5
XII. Program Procedures. ............................................................................................................... 6
A. General. .......................................................................................................................... 6
B. Site Selection. ................................................................................................................. 7
C. Inspection Scheduling..................................................................................................... 9
D. Inspection Procedures and Case File Documentation. ................................................ 13
E. CSHO Protection. .......................................................................................................... 17
F. OSHA Information System (OIS) Coding Instructions. .................................................. 17
G. Outreach. ...................................................................................................................... 19
H. Coordination. ................................................................................................................ 21
I. Program Review. .......................................................................................................... 21

Appendix A: Target Industries for the Heat NEP
Appendix B: CSHO Pre-Inspection Checklist
Appendix C: Sample Heat-Related AVD
Appendix D: Sample Heat Hazard Alert Letter
Appendix E: Sample Employer Letter to Corporate Offices for Heat-Related Hazards
Appendix F: Description of Serious Heat-Related Illnesses and Common Symptoms
Appendix G: Warnings, Alerts, and Advisories Issued by the National Weather Service
Appendix H: Additional Resources
Appendix I: Evaluation of a Heat Program
Appendix J: Citation Guidance

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I. Purpose.
This Instruction describes policies and procedures for continuing OSHA’s National
Emphasis Program (NEP) to ensure that employees in high-hazard industries are
protected from heat-related hazards, both indoors and outdoors, that may lead to
serious illnesses, injuries, or death (see Appendix F for a list of heat illnesses). This NEP
augments OSHA’s efforts addressing unprogrammed-related activities, e.g., complaints,
referrals, and severe incident reports, by adding an enforcement program targeting
specific high-hazard industries or activities in workplaces where this hazard is prevalent
during high heat conditions, such as working outdoors in a local area experiencing a
heat wave, as announced by the National Weather Service, or working indoors near
radiant heat sources, such as iron and steel mills and foundries. This NEP focuses on
workers in outdoor and indoor environments in general industry, construction,
maritime, and agriculture, and may involve coordinating efforts with other regulatory
agencies, such as the Department of Labor Wage and Hour Division (WHD). More
information on this effort is in Section XII.A, Program Procedures.
II. Scope.
This Instruction applies OSHA-wide.
III. References.
A. Section 5(a)(1) of the Occupational Safety and Health Act (OSH Act), 29 U.S.C. §
654.
B. OSHA Instruction, ADM 03-00-008, OSHA Clearance Process for Non-Policy and
Policy Issuances, April 1, 2024.
C. OSHA Instruction, ADM 03-01-005, OSHA Compliance Records, August 3, 1998.
D. OSHA Instruction, ADM 04-00-003, OSHA Safety and Health Management
System, May 23, 2011.
E. OSHA Instruction, CPL 02-00-025, Scheduling System for Programmed
Inspections, January 4, 1995.
F. OSHA Instruction, CPL 02-00-170, Enforcement Exemptions and Limitations under
the Appropriations Act, July 18, 2024.
G. OSHA Instruction, CPL 02-00-164, Field Operations Manual (FOM), April 14, 2020.
H. OSHA Instruction, CPL 02-01-067, Site-Specific Targeting (SST), May 20, 2025.
I. OSHA Memorandum, Establishment-Targeting Lists for Emphasis Programs,
November 12, 2014.
J. OSHA Instruction, FAP 01-00-008, Federal Agency Targeting Inspection Program,
February 11, 2019.
K. OSHA Instruction, CPL 02-00-155, Inspection Scheduling for Construction,
September 6, 2013.
L. OSHA Instruction CPL 02-03-011, Whistleblower Investigations Manual, April 29,

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2022.
M. OSHA Instruction, TED 01-00-015, OSHA Technical Manual (OTM), Section III,
Chapter 4 – Heat Stress, September 15, 2017 (and OSHA’s intranet for additional
technical guidance).
N. OSHA-NIOSH Heat Safety Tool (smartphone App): Heat Safety Tool Application.
O. OSHA Memorandum of Understanding, Between OSHA and the Wage and Hour
Division (WHD), May 4 , 2023.
P. NIOSH, Criteria for a Recommended Standard: Occupational Exposure to Heat
and Hot Environments, DHHS (NIOSH) Publication Number 2016-106, February
2016.
Q. American Conference of Governmental Industrial Hygienists (ACGIH®), Action
Limit (AL) for un-acclimatized workers and a Threshold Limit Value (TLV®) for
acclimatized workers, see Heat Stress and Strain: TLV® Physical Agents 2022 (or
latest edition). See ACGIH® website, here.
[Note, TLV® Booklets are available through OSHA’s Technical Data Center.]
R. U.S. Department of Commerce’s National Oceanic and Atmospheric
Administration (NOAA), National Weather Service (NWS), Types of warnings,
alerts, and advisories.
See Appendix H for Additional Resources.
IV. Cancellations.
CPL 03-00-024, National Emphasis Program – Outdoor and Indoor Heat-Related Hazards,
April 8, 2022.
V. Action Offices.
A. Responsible Office.
Directorate of Enforcement Programs, Office of Health Enforcement.
B. Action Offices.
OSHA Regional and Area Offices, State Plan and OSHA On-Site Consultation
Programs.
C. Information Offices.
OSHA National Office.
VI. Federal Program Change.
Notice of Intent Required, Adoption Encouraged. This Instruction describes a federal
program change that updates the NEP to identify and eliminate or reduce exposures to
heat-related hazards, both indoors and outdoors, resulting in illnesses, injuries, and
deaths, through inspection targeting, outreach, and compliance assistance. State Plans
are strongly encouraged, but are not required, to adopt this updated Instruction, and

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State Plans that adopt this Instruction should implement it in an at least as effective
manner.
Within 60 days of the effective date of this Instruction, a State Plan must submit a notice
of intent indicating whether they already have a similar policy in place, intend to adopt
new policies and procedures, or do not intend to adopt this Instruction. If a State Plan
does not adopt at first, but at some later point decides to adopt this Instruction or an at
least as effective version of this Instruction, the State Plan must notify OSHA of this
change in intent. Within 60 days of adoption, the State Plan must provide an electronic
copy of the policy or a link to where their policies are posted on the State Plan’s
website. The State Plan must also provide the date of adoption and identify differences,
if any, between their policy and OSHA’s. OSHA will provide summary information on the
State Plan responses to this instruction on its website, here.
OSHA’s Office of Statistical Analysis (OSA) will work with the State Plans to provide the
data as requested to develop targeting lists in accordance with the instructions in
Section XII.B. OSHA will make the list(s) of establishments available to the State
Plans. See coding instructions for the OSHA Information System (OIS) in Section XII.F.
This Instruction describes a change that may affect federal agencies. Federal agencies
that are subject to inspection and have employees exposed to hazards covered by this
emphasis program are also included in this NEP. See FOM Chapter 13, Federal Agency
Field Activities and OSHA Instruction, FAP 01-00-008, Federal Agency Targeting
Inspection Program, February 11, 2019.
VII. Expiration.
This Instruction shall be operative for no more than five years from the effective date,
unless canceled or extended by a superseding directive.
VIII. Significant Changes.
A. Updated target industries using current data from BLS and OSHA (Appendix A)
B. Removed outdated background information and references.
C. Updated links.
D. Revised inspection goal.
E. Reorganized and Added Appendix I: Evaluation of a Heat Program.
F. Reorganized and Added Appendix J: Citation Guidance.
G. Added coding for Worksite Assistance.
H. Added coding for Unprogrammed Emphasis Hazards.
IX. On-Site Consultation Programs.
On-Site Consultation Programs are encouraged to develop their own strategic
approaches for addressing heat-related illness and injuries resulting from body heat
generated by physical work that is performed in conditions of high ambient and/or

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radiant heat, especially when combined with humidity and inadequate cooling. See
coding instructions for the OIS in Section XII.F.
X. Background.
The U.S. Department of Labor’s Bureau of Labor Statistics (BLS) reports that between
2021 and 2024, exposure to environmental heat resulted in an estimated average of
3,793 days away, restricted and transfer (DART) cases per year. BLS data also indicates
that between 2021 and 2024, exposure to environmental heat resulted in an average of
48 fatalities per year. These statistics likely do not capture the true magnitude and
prevalence of heat-related injuries, illnesses, and fatalities (see 89 Fed. Reg. 70702,
8/30/2024). Heat-related illnesses range from heat cramps to heat stroke, which can
potentially lead to death. See Appendix F for a list of heat illnesses. Between calendar
years 2022 and 2025, Federal OSHA conducted on average approximately 2,400 heat-
related hazard inspections each year, which included approximately 50 heat-related
fatality inspections annually. In 2024, OSHA proposed a new standard to address the
hazards posed by occupational heat exposure, titled Heat Injury and Illness Prevention
in Outdoor and Indoor Work Settings, 89 Fed. Reg. 70698 (Aug. 30, 2024).
This Heat NEP prioritizes on-site (in person) response for complaints and for all
employer-reported hospitalizations (i.e., severe injury reports) related to heat hazards.
Performance of rapid response investigations is reserved for limited circumstances and
subject to Area Director’s (AD) approval, as described in Section XII.C.1.
The National Weather Service (NWS) uses a heat index to classify environmental heat.
When the heat index0F
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is 80°F or higher, serious occupational heat-related illnesses and
injuries become more frequent, especially in workplaces where unacclimatized workers
are performing strenuous work (e.g., intense arm and back/lifting work, carrying,
shoveling, manual sawing, pushing and pulling heavy loads, and walking at a fast pace),
without easy access to cool water, or cool/shaded areas, when working in direct sunlight
or areas where other radiant heat sources are present.
Acclimatization is a process by which a person gradually increases their exposure time to
hot environmental conditions, causing beneficial physiological changes by properly
regulating body temperature that minimizes heat-related illnesses. It is therefore
essential for employers to train new or returning workers on heat-related hazards
including heat stress, gradually increase their workloads, ensure more frequent breaks
as they acclimatize to ambient conditions, and monitor them for signs of heat illness.
Heat-related fatalities have occurred with a heat index below 80°F, particularly when
aggravating factors are present.
Heat-related fatalities are usually the result of exertional heat stroke, where physical
activity in hot environments causes the body temperature to reach 104°F or higher
(normal body temperature is around 98.6°F).
2
Appendix F of this Instruction provides a

1
According to the National Weather Service, the Heat Index, sometimes referred to as the apparent temperature,
is given in degrees Fahrenheit and is a measure of how hot it really feels when relative humidity is factored in with
the actual air temperature.

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list of serious heat-related illnesses, along with common signs and symptoms of
exposure.
Heat-related illnesses and injuries can happen at almost any ambient temperature,
especially in cases where workers perform moderate or higher physical activity, or wear
heavy or bulky clothing or equipment, including personal protective equipment. Heat-
related illnesses and injuries also generally occur when body heat generated by physical
work is performed in conditions of high ambient heat, especially when combined with
humidity and inadequate cooling. As mentioned above, combinations of heat and
humidity are used to determine the commonly used “feels like” temperature (i.e., heat
index, or HI). The OSHA-NIOSH Heat Safety Tool App is a resource for finding the
forecasted and current heat index. The App indicates the hazard levels using the heat
index as: Caution less than 80°F HI, Warning 80°F to 94°F HI and Danger at 95°F HI or
higher.
The National Institute for Occupational Safety and Health (NIOSH) has published
recommended occupational exposure limits and controls for heat stress. A NIOSH
publication, Criteria for a Recommended Standard: Occupational Exposure to Heat and
Hot Environments, outlines recommended environmental limits for physical work at
which point engineering controls, preventative work, hygienic practices, and
administrative or other control procedures should be implemented in order to reduce
the risk of heat-related illnesses. NIOSH has a Recommended Alert Limit (RAL) and
Recommended Exposure Limit (REL) based on the Wet-Bulb-Globe Temperature
(WBGT).
1F
2

For a listing of best practices on worker acclimatization visit the American Conference of
Governmental Industrial Hygienists (ACGIH®) Action Limit (AL) for unacclimatized
workers and a Threshold Limit Value (TLV®) for acclimatized workers, see Heat Stress
and Strain: TLV® Physical Agents, 2026 Edition or latest edition, available at
www.acgih.org.
The above criteria can help to identify days in which a maximum heat temperature can
result in increased risks of heat-related hazards. These criteria vary across the country.
Particularly in areas of the United States that are not usually subject to elevated
dangerous heat conditions, unacclimatized workers may suffer serious heat-related
illnesses even in cases when the heat index is not high enough to trigger NWS heat
advisories or warnings.
XI. NEP Goal.
OSHA heat-related inspections have accounted for 6 percent of all Federal inspections
during the last five years and included both unprogrammed (43 percent) and
programmed (57 percent) inspections. The number of unprogrammed activities makes
clear the continued need for heat-related outreach and compliance assistance activities,

2
For resources discussing heat-related illnesses and common symptoms, see NIOSH Criteria for a Recommended
Standard: Occupational Exposure to Heat and Hot Environments, DHHS (NIOSH) Publication Number 2016-106,
February 2016.

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as well as On-Site Consultation visits and programmed enforcement to lower reported
fatalities, hospitalizations, and complaints or referrals to OSHA.
The goal of this NEP is to reduce or eliminate worker exposures to heat-related hazards
that result in illnesses, injuries, and deaths, by targeting industries and worksites,
including worksites with radiant heat sources, where employees are exposed to heat-
related hazards and have not been provided adequate protection that includes cool
water, rest, cool areas, training, and acclimatization. These mitigation strategies are key
in controlling the health hazards associated with heat exposures. OSHA’s goal will be
accomplished by a combination of enforcement (which includes inspection targeting),
outreach to employers, and compliance assistance.
To ensure abatement and to monitor the effectiveness of OSHA’s enforcement and
guidance efforts, certain follow-up inspections for worksites previously inspected and
cited for heat-related hazards will be included as part of the program procedures, as
outlined in Section XII.C.2.
XII. Program Procedures.
A. General.
To increase the likelihood of preventing heat-related illnesses and deaths and
make efficient use of OSHA resources, compliance safety and health officers
(CSHOs) who are investigating for other purposes shall expand their inspection
or refer a heat-related inspection for any hazardous heat conditions where there
is evidence (e.g., injuries or illnesses recorded in both OSHA forms 300 and 301,
employee statements, or “plain view” observations) of violative conditions. For
example, if an employee brings a heat-related hazard(s) to the attention of the
CSHO (such as, employees or temporary workers being exposed to high
temperature conditions without adequate training, acclimatization or access to
water, rest, and shade), CSHOs shall expand the inspection to cover heat-related
hazards. Expansion of inspections shall be conducted in accordance with the
FOM, Chapter 3, Section III.B, Partial Inspections.
Additionally, during inspections opened for other purposes occurring on heat
priority days, CSHOs should inquire regarding the existence of any heat-related
hazard prevention programs. A heat priority day occurs when the heat index for
the day is expected to be 80°F or more. On heat priority days, the AO will assess
the potential for serious heat-related illnesses and injuries where such hazards
may exist in indoor or outdoor work areas or provide worksite assistance.
Furthermore, programmed inspections shall occur on any day that the NWS has
announced a heat warning or advisory for the local area. See Appendix G for a
description of these types of alerts, for which affected employers should be
aware and take appropriate actions to protect their workers from heat hazards.
Appendix A has a list of both outdoor and indoor industries that are known to
have heat-related hazard incidents. During days of locally-issued heat warnings
or advisories, establishment lists derived from Appendix A will be used for

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programmed inspections, see Section XII.C.1.
Another source for heat inspections are referrals from the Wage and Hour
Division (WHD) of the U.S. Department of Labor. When the weather is hot or a
heat alert is issued for an area where the WHD is investigating, WHD is
encouraged to coordinate with OSHA by providing information on heat-related
hazards by making timely referrals, per the Memorandum of Understanding
between OSHA and WHD, dated May 4, 2023.
OSHA’s Appropriations Act has placed exemptions and limitations on
enforcement activities for those employers who employ 10 or fewer employees,
commonly referred to as small employers. Small farming operations and small
employers in low-hazard industries are most affected by the exemptions and
limitations of the Appropriations Act.
Before initiating any health enforcement activities for a farming operation or
non-farming with 10 or fewer employers, the CSHO should review CPL 02-00-
170, Enforcement Exemptions and Limitations under the Appropriations Act, and
FOM Chapter 2, Section IV.D, for more details.
A farming operation with 10 or fewer employees at all times during the previous
12 months and that has not had an active temporary labor camp during the
preceding 12 months is exempt from OSHA enforcement, e.g., programmed
health or safety inspections, referrals, or complaints. CSHOs should be aware
that immediate family members of farm employers are not counted when
determining the number of employees.
A non-farming employer with 10 or fewer employees listed in the Low-Hazard
Industries Table of CPL 02-00-170 has some enforcement exemptions and
limitations under the Appropriations Act (e.g., programmed safety inspections
are not permitted), but programmed health inspections are permitted. Please
note the Low Hazard Industries Table is updated yearly by OSHA using statistics
provided by BLS.
B. Site Selection.
1. Scheduling/Site Selection. Targeting establishments for a programmed
inspection must use neutral selection criteria.
Any inspection that meets the conditions for a heat inspection and any heat-
related severe injury report or referral from WHD shall initiate an inspection,
unless a physical inspection is not feasible. For example, the construction
operation was temporary and work has ended, or the report is from an area
that is difficult to reach (e.g., mountain area, gorge, swamp). The list of
industries in Appendix A, Table 1 (non-construction), of this Heat NEP will be
used to create a master list of targeted establishments within the North
American Industrial Classification System (NAICS). NAICS is a systematic way
to classify businesses by the products or services they provide. A list of
establishments that are in the local jurisdiction of each AO will be generated

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by the Office of Statistical Analysis (OSA) ListGen application. The AO will
inspect establishments in the Random Number order as provided on the list
to ensure neutrality. OSA will provide each AO with access to software and a
database that includes the establishments with the NAICS codes covered
under this NEP.
Appendix A, Table 2, lists construction industries that are likely to have heat-
related hazards. The AO should use C-Target procedures to find active
construction sites to add to their list of heat inspections for programmed
inspections during days of locally issued heat warnings or advisories (see
Appendix G). (Note that if a construction project from the C-Target list is
inspected, the AO must account for all projects from that list by either
conducting an inspection or deletion in accordance with CPL 02-00-155).
While traveling to work sites, CSHOs should be vigilant of circumstances
where employees in the industries listed in Appendix A, Table 2, are exposed
to heat-related hazards.
Appendix A, Table 3, lists non-construction industries with a history of heat-
related incidents that are not in ListGen. For industries in Table 3, alternative
sources may be utilized (e.g., Reference USA, a business and residential
information database). The AO should use local knowledge to add these
industries to the inspections list.
2. Additions. AOs may also add establishments to the ListGen Master List based
on current activity at a construction site, or other non-construction
establishments, based on local evidence that heat exposures have occurred
in the five years preceding the effective date of this Instruction for industries
not included in ListGen. The local evidence may be based on OIS incident
data, employer-reported heat-related illness or fatalities, regardless of
NAICS, and workers’ compensation data. Other sources of local information
may include but are not limited to: (a) commercial directories (e.g.,
Reference USA); (b) telephone listings; (c) local knowledge of establishments;
(d) information from other government agencies with joint jurisdictions, such
as Wage and Hour Division, U.S. Department of Agriculture (USDA),
Environmental Protection Agency (EPA), Health Department; and (e) media
referrals. The AO must retain documentation of every addition made to the
Master List and, prior to use, the revised List must be re-randomized either
by OSA or by the AO using the RANDBETWEEN function in Microsoft Excel.
ListGen assigns random numbers and provides the establishment lists in
random number order. Acceptable methods for generating cycles can be
found in the memorandum dated November 12, 2014, Establishment-
Targeting Lists for Emphasis Programs. Subsequent cycles will be created in
the same manner until such time that this NEP is cancelled or until all
establishments on the list have been assigned to a cycle. Cycles may be
created all at once or as necessary and need not be of the same size.
Targeted Federal locations can be added when appropriate.

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3. Deletions. AOs may delete from their target list establishments known to be
out of business, documenting the basis for such determinations. AOs shall
not delete establishments with 10 or fewer employees from the
establishment list except as indicated in XII.D.14. below of this instruction.
AOs may delete from their target list any establishment that does not have
an exposure to heat-related hazards or that has had a comprehensive or
partial health inspection that addressed heat hazards, with an Opening
Conference date occurring within the twelve (12) previous months and
resulting in one of the following outcomes:
a) Serious citations issued related to heat hazards which are under
contest or for which the abatement period has not yet expired; or
b) No serious citations were issued for hazards related to exposure to
heat-related hazards; or
c) Serious citation(s) were issued for hazards related to exposure to
heat-related hazards, but a follow-up inspection documented
appropriate and effective efforts by the employer to abate the
serious hazards cited (e.g., work practice or administrative controls in
place, engineering controls installed).
Note: The AD may use discretion in scheduling a heat inspection at a
previously cited establishment inspected within the previous twelve (12)
months, even where related other-than-serious citations, Hazard Alert
Letters, or Notification Letters were issued.
The AO shall maintain documentation supporting any deletions made under
this paragraph (see below).
4. Maintaining Inspection List/Cycles and Documentation: The AD is responsible
for maintaining documentation necessary to demonstrate that the AO has
used the NEP inspection list and cycles in accordance with this Instruction,
including documenting all deletions, deferrals, or other modifications. The
AO shall maintain all such inspection lists, cycles, and documentation for a
period of three years following the completion of all inspections conducted
under this NEP plan. See CPL 02-00-025, Scheduling System for Programmed
Inspections; and ADM 03-01-005, OSHA Compliance Records. For
construction, see CPL 02-00-155, Inspection Scheduling for Construction.
C. Inspection Scheduling.
Within a specified cycle, heat-related health inspections shall be scheduled, in
accordance with the FOM, with the highest priority given to fatality inspections,
and then to other unprogrammed inspections (i.e., complaints and referrals)
alleging employee exposure(s) to heat-related hazards. The Area Office (AO)
may schedule follow-up inspections related to heat-related hazards to meet the
goals of this NEP where unprogrammed activities have decreased sufficiently to
allow that.

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1. Scheduling. The AO must schedule inspections by establishing a cycle. A
"cycle" is a subset of establishments from the Master List that allows the
Area Office to use its enforcement resources more efficiently, including
arranging establishments’ order within a cycle. See OSHA Memorandum,
Establishment-Targeting Lists for Emphasis Programs, November 12, 2014,
page 3.
The AO may schedule inspections one of the following ways:
a) If the AO intends to inspect the entire Master List, they may schedule
the inspections in any order. If the AO uses this method, they must
account (through inspections and deletions) for the entire list. The AO
cannot inspect off a new list until the entire previous list is
completed.
b) The AO may inspect the facilities in the random number order
provided. If the AO uses this method, it does not need to complete
the entire Master List.
c) The AO may create cycles by choosing a set number of establishments
from the Master List, sorted in random number order. For example, it
can select the first 10 establishments on the Master List, sorted by
ascending random number as a first cycle of 10 establishments. The
AO can then inspect those establishments in any order but must finish
the cycle prior to beginning a second cycle. Once the first cycle is
complete, the AO can inspect the next ten establishments on the
randomized Master List as its second cycle.
Some establishments selected for inspection under this NEP may also be
selected under other NEPs and/or LEPs, or under the current Site Specific
Targeting (SST) Plan. Whenever possible, inspections under this NEP should
be carried out concurrently with other programmed inspections.
2. Unprogrammed Inspections.
Fatalities/catastrophes, complaints, or referrals for any general industry,
maritime, construction, or agriculture operation alleging hazardous
exposures to heat (outdoors and/or indoors), regardless of whether they fall
within a targeted industry of this NEP, shall be handled in accordance with
the hierarchy of initiating inspections as outlined in FOM Chapter 9,
Complaint and Referral Processing, and Chapter 11, Imminent Danger,
Fatality, Catastrophe, and Emergency Response, and in accordance with the
specific procedures listed below:
a) Fatalities/Catastrophes.
Fatality incidents shall be prioritized for inspections.
b) Complaints and Referrals.
Allegations of potential worker exposures to heat (e.g., insufficient

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controls in place such as access to water, rest, and/or shade), or
involving workers suspected or confirmed to have a heat-related
illness, shall be given priority for on-site inspections.
During all inspections, CSHOs must document the information required in
Section XII.D, Appendix I and Appendix J.
3. Follow-up Inspections.
Initial follow-up inspections should be conducted for establishments that
were previously inspected as a result of a heat-related fatality and were
issued citations, to determine if abatement was implemented for heat-
related hazards. Additional follow-up inspections should be conducted for
any establishment receiving serious violations for heat-related hazards or in
some cases, other-than-serious citations.
The AD may also select establishments for follow-up inspections where any
of the following applies:
a) The establishment previously received an other-than-serious
recordkeeping violation for failure to record a heat-related illness or
injury, and other circumstances at AD discretion.
b) A previously inspected employer continues to expose employees to
heat-related hazards, or has not fully and properly implemented
required engineering controls, administrative controls, work
practices, and personal protective equipment noted in the abatement
certification, within the time period specified; or
c) If there are any violations for which abatement verification has not
been provided.
Follow-up inspections are to be conducted in accordance with FOM, Chapter
3, Section XII.K. Follow-up and Monitoring Inspections, based on available
resources and using either on-site, remote, or a combination of on-site and
remote methods.
For situations where follow-up onsite inspections cannot be performed (e.g.,
where CSHOs are unable to conduct an on-site inspection), the AD, when
possible, may require that the employer provide written updates
documenting the progress of abatement efforts, per 29 CFR § 1903.19. The
AO does not need to send abatement verification to the National Office, but
such documentation shall be available to the National Office on request.
4. Programmed Inspections.
a) High-hazard Industries.
Appendix A lists high hazard industries with NAICS codes having
among the highest numbers of BLS heat cases, incidence rates and
BLS median days away from work for the years 2021-2024, OSHA

12
severe injury reports from calendar years 2021-2024, and OSHA heat-
related inspections of establishments resulting in General Duty Clause
violations or Hazard Alert Letters from calendar years 2022 to 2025.
(See Appendix A for more detailed information about the sources
OSHA used to identify affected industries.). Appendix A, Table 1, has
a list of targeted industries in ListGen to be used for programmed
Heat NEP inspections during days of locally-issued heat warnings or
advisories (see Appendix G).
b) Site-Specific Targeting (SST).
If an establishment selected for inspection under this NEP is also
selected under the current SST plan, where possible the NEP and SST
plan inspections should be conducted concurrently. Refer to OSHA
Instruction, CPL 02-01-067, Site-Specific Targeting (SST) (or current
version).
5. Protections.
Workers requesting inspections, complaining of heat-related exposure, or
reporting illnesses or retaliation, may be covered under one or more
whistleblower protection statutes. Inform the workers of their protections
from retaliation and refer them to the OSHA website, here, for more
information, including how to file a retaliation complaint. If the worker is
alleging some form of retaliation, the AO must submit a referral to the
Regional Whistleblower Protection Program using the appropriate intake
form and regional referral process.
6. Coordination with Wage and Hour Division.
Workers complaining of inadequate working or living conditions or wages
may be protected by one or more statutes enforced by the WHD. WHD and
OSHA offices are encouraged to initiate referrals and exchange appropriate
information relating to complaints, inspections, or investigations and related
matters to support the enforcement activities of the agencies.
If OSHA discovers information relating to a possible violation of the laws and
regulations enforced by WHD, OSHA offices are encouraged to provide timely
information to WHD by making a referral, per the MOU, dated May 4, 2023.
Workers with questions or concerns should contact WHD at 1-866-487-9243
or visit their website, here, to be directed to the nearest WHD office for
assistance.
7. Cooperative Programs.
Employers participating in select cooperative programs may be exempt from
programmed inspections. After inspection lists are generated, the AO should
contact the Cooperative and State Programs office in their Regional Office to
determine if any company on the list should be exempted. The CSHO should
follow the procedures outlined in FOM Chapter 2, Program Planning, for

13
further guidance if an On-Site Consultation visit is in progress, or if the
establishment is a participant in OSHA’s Voluntary Protection Programs (VPP)
or the Safety and Health Achievement Recognition Program (SHARP) or Pre-
SHARP. Even if an employer is exempt from a programmed inspection, the
AO should notify the employer in writing that they are required to comply
with all applicable OSHA standards and the General Duty Clause. In such
cases, the Regional Consultation Program Officer shall follow up with the
responsible Consultation Program Manager.
D. Inspection Procedures and Case File Documentation.
All inspections shall be conducted in accordance with the general provisions of
the FOM. Other procedures related to scheduling and conducting inspections
include the following:
1. OSHA Area Offices shall assess the potential for heat-related illnesses,
injuries, and deaths where heat-related hazards may exist in indoor work
areas or at outdoor work areas on heat priority days, i.e., when the heat
index is expected to be 80°F or higher. CSHOs should use internal guidance
material for assistance in performing heat investigations. The procedures to
assess heat conditions and workload are described in the OSHA Technical
Manual (OTM) Section III: Chapter 4), and OSHA’s intranet for additional
technical guidance. Inspections under this NEP shall only be conducted by
CSHOs who have reviewed the appropriate safety and health precautions as
outlined in the FOM Chapter 3, Inspection Procedures. A review of any
potential heat-related hazards should be included in any programmed or
unprogrammed inspection, as mentioned above.
Inspections should be completed and citations, or hazard alert letters, if any,
should be issued expeditiously to facilitate prompt abatement. After any
type of inspection initiated under this NEP, where evidence of a violation is
not present, an intervention with the employer should be conducted to
identify and prevent potential heat-related illnesses. Heat hazard
interventions are informational in nature and should include discussions with
employers regarding taking proactive employee protection measures (e.g.,
easy access to cool water, cooling areas, and acclimatization) and providing
heat posters and other outreach materials to mitigate the hazard.
Note: In cases where it is geographically infeasible to expeditiously initiate
an inspection of an unprogrammed activity, the Area Office will initiate
contact with the employer using non-formal procedures to encourage speedy
interventions to prevent the potential for heat-related illnesses.
2. During heat-related inspections, CSHOs shall:
a) Review OSHA 300 Logs and 301 Incident Reports for any entries
indicating heat-related illness(es),
b) Review any records of heat-related emergency room visits and/or

14
ambulance transport, even if hospitalizations did not occur, [this may
require the use of a Medical Access Order],
c) Interview workers for symptoms of headache, dizziness, fainting,
dehydration, or other conditions that may indicate heat-related
illnesses, including both new employees and any employees who
have recently returned to work,
d) Ensure documentation of the information required in this Section
XII.D, as well as in Appendix I and Appendix J, as applicable.
e) Identify activities relevant to heat-related hazards. These can include,
but are not limited to:
• Potential sources of heat-related illnesses (e.g., working in direct
sunlight, a hot vehicle, or areas with hot air, near a gas engine,
furnace, boiler, or steam lines);
• The use of heavy or bulky clothing or equipment, including
personal protective equipment;
• Workload exertions, which can be estimated by observing the
types of job tasks performed by employees and whether those
activities can be categorized as moderate, heavy, or very heavy
work, considering both average workload and peak workload; and
• Duration of exposure during which a worker is continuously or
repeatedly performing moderate to strenuous activities.
3. OSHA Area Offices shall instruct CSHOs to be vigilant, during their travels to
and from job sites , and stop to conduct compliance assistance or self-
referral inspections of outdoor work environments in plain view (e.g.,
construction worksites, highway and bridge work, lawn care, and
maintenance workers, etc.) on any day that the NWS announced a heat
warning or advisory for the local area where employees may be performing
moderate or more strenuous work or working in direct sunlight (or other
radiant heat sources) for extended periods of time. Observing potential
heat-related hazards while traveling is particularly important for early
intervention and prevention of heat-related incidents on construction sites,
see Appendix A, Table 2. When stopping at such sites, the CSHO should make
note of any obvious signs of heat stress to workers and ask the employer
representative basic questions about the employer’s efforts to address heat
exposure hazards to help determine whether compliance assistance or an
inspection is appropriate. Where the CSHO determines there is no heat
hazard present or where the employer has an adequate heat illness
prevention program, the CSHOs should provide any additional relevant
information such as best practices for managing heat exposure hazards.
Where an inspection is conducted, it shall be appropriately coded as
“Unprogrammed Emphasis Hazard,” per Section XII.F of this Instruction.

15
4. Once an inspection has been scheduled for an identified establishment, and
prior to opening the inspection, CSHOs shall conduct a search of the
employer’s citation and fatality/accident history in OSHA’s Establishment
Search Page or by using the OIS to determine any prior heat-related issues.
5. The CSHO shall also determine whether the identified establishment is
scheduled for any other programmed inspection (e.g., SST, NEP, LEP).
Whenever possible, inspections under this NEP should be carried out
concurrently with other programmed inspections.
6. At the opening conference, the CSHO will verify the correct NAICS code for
the establishment with the employer and determine whether conditions or
activities that may result in worker exposures to heat-related hazards are
present at the facility or worksite. The CSHO shall review the establishment’s
injury and illness logs (OSHA 300 and OSHA 300A) for three calendar years
prior to the inspection and the current year to date to identify any work-
related cases of heat illness.
Note 1: Not all industries covered by the Heat NEP are required to maintain
OSHA records, and CSHOs should check to see if the industry of the
establishment being inspected is in Appendix A to subpart B of Part 1904. If
the establishment is exempt from maintaining OSHA records, either because
of size (per 29 CFR § 1904.1) or industry classification (per § 1904.2), it cannot
be cited for failing to record an injury or illness.
Note 2: CSHOs shall always verify an employer’s assertions regarding
workplace conditions or worker exposures to heat by interviewing
employee(s) at the site.
7. If the inspection is initiated by an unprogrammed or follow-up activity, or the
establishment is targeted under another NEP or LEP, the CSHO shall proceed
to determine any additional alleged items or those covered by another
emphasis program. The CSHO will also inform the employer and interviewed
employees of their rights and responsibilities under Section 11(c) of the OSH
Act. If the unprogrammed activity that initiated this inspection included an
allegation of retaliation, the CSHO shall refer this allegation to the Regional
Whistleblower Protection Program.
If the CSHO determines during the walkaround or background research that
workers may be performing tasks which include exposure to heat-related
hazards, then they shall proceed with the inspection following the
procedures in this NEP.
8. A review of any potential heat-related hazards should be included in any
programmed or unprogrammed inspection where radiant heat
sources exist in indoor work areas or at outdoor work areas inspected on
heat priority days. CSHOs may provide worksite assistance where heat-
related hazards are unrelated to an apparent violation.

16
9. CSHOs can use the OSHA-NIOSH Heat Safety Tool App as a resource. This
App provides current and projected heat indices for that day at the current
location. The App indicates the hazard levels as: Caution (less than 80°F HI),
Warning (80°F – 94°F HI), Danger (95°F HI or higher), and offers
recommended actions to protect workers. When conditions for previous
days are needed, the NWS provides certified historic weather data to
document past conditions. CSHOs should use nationally available tools
assembled on the CSHO Resources intranet webpage to reconstruct data
when appropriate on a particular day.
10. If inspections occur on days different from the incident triggering the
complaint, referral, SIR, or fatality, CSHOs should obtain historic WBGT
logs/records, if available. If records are not available, DTSEM has provided a
method for estimating WBGT values using historic weather data available on
the internet. Guidance for this method is available on the DEP Heat intranet
page.
11. Report heat-related inspections to the regional heat coordinator as soon as
possible. Area Offices should work with the Regional Office to contact the
Office of Occupational Medicine and Nursing early in the inspection
(especially in fatality or hospitalization cases) to obtain Medical Access
Orders, if needed. For technical assistance, contact the Health Response
Team and/or the OSHA Technical Center on the use of WBGT
instrumentation. Contact DEP’s Office of Health Enforcement for assistance
with enforcement policy.
12. During any inspection, where other health or safety hazards have been
alleged in a complaint or observed in plain view during the walkaround,
CSHOs shall investigate as appropriate. Safety or health referrals may be
made, subject to any current exemptions or limitations on such activity.
13. Ensure CSHOs are aware of the annual appropriations exemption list issued
each year in the Low-Hazard Industries Table of CPL 02-00-170, Enforcement
Exemptions and Limitations under the Appropriations Act. Several exempt
industries listed in the February 2026 Low-Hazard Industries Table (by 6-digit
NAICS) are included within the target industries (4-digit NAICS) in Appendix A
of this NEP.
14. The CSHO will inform workers of their right to file a whistleblower complaint
if they experience retaliation for providing assistance to OSHA during an
inspection, such as filing a safety and health complaint with OSHA, reporting
a work-related injury or illness, or complaining about exposure to heat-
related hazards or any other workplace hazards to management. Any
complaint of alleged retaliation shall be promptly referred to the Regional
Whistleblower Protection Program.
15. Establishments with more than one location engaged in the same or similar
types of operations may also have employees who are potentially exposed to

17
heat-related hazards at other work sites. Compliance Officers should consult
with Area and Regional Offices to provide a letter to the corporate entities of
such establishments, informing them of any heat-related OSHA inspection(s),
including sending relevant information on protective measures. Refer to
Appendix E of this Instruction for a sample letter to employers.
E. CSHO Protection.
1. When performing an on-site inspection, CSHOs must observe all appropriate
precautions to protect themselves from heat-related illnesses. CSHOs should
ensure that they have protected themselves from the dangers of heat
exposure prior to performing any enforcement actions in the field in
accordance with the job hazard analysis for that worksite, and immediately
stop the inspection if they or an employee has symptoms of heat illness.
Supervisors shall ensure CSHOs comply with all safety and health
management system (SHMS) guidance and requirements developed as part
of the ADM 04-00-003, OSHA Safety and Health Management System.
Additional safety precautions will be needed if the CSHO believes other
hazards may exist in the workplace. CSHOs should review and follow the
Regional SHMS policies and procedures to be prepared for foreseeable
hazards which may arise during the inspection. Appendix B of this
Instruction provides a CSHO pre-inspection checklist.
2. CSHOs shall also protect themselves against other hazards during an
inspection and must use additional personal protective equipment as
necessary to protect themselves from hazards (e.g., gloves, goggles).
Additional CSHO precautionary guidance and inspection tools are provided in
Appendix B of this Instruction. See FOM Chapter 3, Section II.C, Safety and
Health Issues Relating to CSHOs. See also ADM 04-00-003, OSHA Safety and
Health Management System.
F. OSHA Information System (OIS) Coding Instructions.
All enforcement activities (i.e., inspections, complaints, and referrals, etc.) and
consultation requests/visits conducted under this NEP shall be coded with the code,
“HEATNEP.” The existing heat codes, “N-02-HeatGI, N-02-HeatCON, N-02-HeatMI,
N-02-HeatAG,” are also required in the Additional Code field for Federal
inspections, as well as for inspections by State Plan offices that adopt this NEP.
However, technical assistance activities (including worksite assistance specifically
related to heat) should also be captured in the OIS Compliance Assistance module
using the N-02 heat codes, above, by industry. These codes must be applied even if
the establishment was not among the targeted NAICS listed in Appendix A, as long
as heat-related hazardous conditions were addressed. Federal OSHA and
Consultation Program compliance assistance activities related to heat illness
prevention should also continue to be coded with the topic “Heat Illness
Prevention.” Programmed heat inspections will be conducted when the NWS has
announced a heat warning or advisory for the local area and shall be coded as Heat

18
NEP inspections. Unprogrammed heat inspections should also be coded as a Heat
NEP inspection.
Additionally, any inspection initiated under this NEP via observed heat-related
illness hazards on any day that the NWS announced a heat warning or advisory for
the local area while the CSHO is traveling to/from/between worksites (not directed
to a site from a targeting list) shall be an “Unprogrammed Emphasis Hazard”
inspection type. This inspection type distinguishes it from “Programmed Planned/
Related,” initiated from a targeting list, and “Referral” inspections conducted at
work sites due to a compliance officer referral (i.e., observations of a specific
hazardous condition).
Worksite Assistance: During an OSHA inspection, CSHOs may provide assistance to
an employer while on-site and afterward prior to issuance of any citations. When
this assistance is unrelated to evidence gathering or to feasible abatement for
hazards being investigated, it is referred to as Worksite Assistance. It is important
that CSHOs capture all worksite assistance activities in OIS following internal
guidance.
Further, inspections conducted under this NEP are to be coded under Inspection
Category as a “Health” inspection unless the inspection was initiated as an
unprogrammed safety inspection where no heat-related hazards were initially
alleged but were later found during the course of the inspection. In such a case,
the inspection should be coded under Inspection Category as a “Safety” inspection.
Table 1, below, provides a summary of all heat related OIS codes.
Table 1. List of OIS codes for heat-related inspections and activities - see also Appendix J.
OIS Field OIS Codes Activity Type
NEP HEATNEP
All enforcement and consultation activities
conducted under this NEP (e.g., complaints,
fatalities, referrals, inspections, visits).
Additional
Code
N-02-HEATGI, N-02-
HEATCON, N-02-
HEATMI, N-02-HEATAG
These existing codes will continue to be
used to track industry groups for all
enforcement activities, and now also for
compliance assistance.
Compliance
Assistance
Activity Topic
Heat Illness Prevention
Existing topic for all heat-related compliance
assistance activities will continue to be used.
In addition, for task type “technical
assistance” add additional codes as directed
above.
Inspection
Type
Unprogrammed
Emphasis Hazard
The initiating inspection type is based on
CSHO observation in the field and not from a
targeting list (mobile work sites such as work
performed at height, work involving

19
OIS Field OIS Codes Activity Type
trenching/ excavation, etc.)
Inspection
Type
Program Planned
The initiating inspection type was from a
targeting list.
Inspection
Type
Programmed Related
An inspection related to a Program Planned
initiating inspection and opened to expand
to address heat-related illness hazards
Inspection
Type
Referral
Inspections initiated by referrals from
external or internal stakeholders.

G. Outreach.
1. Offices.
Each Regional Office or A rea Office must implement a 90-day outreach program
for the industries within their jurisdiction that were not previously targeted by
the 2022 Heat NEP ( see NAICS codes with † mark in Appendix A) prior to any
programmed inspections in those industries. OSHA will continue to conduct
outreach throughout the NEP’s course of implementation while responding to
complaints, referrals, hospitalizations, and fatalities related to heat, and shall
code such activities in accordance with Section XII.F.
Each Regional Office and Area Office shall continue conducting outreach
programs concerning heat illnesses, including as it pertains to new guidance and
this revised NEP, which is generally in accordance with OSHA Memorandum on
Procedures for Local and Regional Emphasis Programs, December 3, 2014. The
National Office shall continue to conduct nationwide outreach on heat illness
prevention upon issuance of this NEP.
2. Suggested Local Outreach.
Outreach activities may include the following:
a) Sharing information on the Heat NEP and available compliance assistance
tools and resources, including no-cost On-Site Consultation services
available to small businesses. This information may be distributed in
written form (e.g., via letter or email), or conveyed in webinars or
presentations at conferences and other events to employers, employee
groups, and unions in heat hazard industries such as, but not limited to
those in Appendix A.
b) Enhancing collaborations with national and regional offices of federal
agencies with similar outreach goals, such as the USDA, EPA, and the
WHD, to conduct outreach on the Heat NEP and heat illness prevention.
c) Collaborating with agency stakeholders, including OSHA cooperative
program participants, to share information on the NEP and best practices

20
or effective means of reducing or eliminating worker exposure to heat-
related hazards.
d) Building new stakeholder relationships with organizations that can help
disseminate information to workers and employers in heat hazard
industries.
e) Working with On-Site Consultation Programs, local Small Business
Development Centers (SBDCs), and other organizations to reach small
businesses in heat hazard industries.
f) Sharing information on the rights of workers and responsibilities of
employers, including whistleblower protections and anti-retaliation
principles. The Recommended Practices for Anti-Retaliation Programs can
be used as a resource and outreach tool, see Appendix H.
3. Targeted Audiences for Outreach.
a) Local employers in high-hazard industries. See also targeted industries in
Appendix A.
b) Unions, worker centers, COSH groups (Councils for Occupational Safety
and Health), and other organizations committed to advancing protections
for underserved worker populations.
c) Local companies and employer associations (e.g., trade associations,
contractor groups, farm bureaus, local chambers of commerce) in
industries such as, but not limited to, those in Appendix A.
d) Insurance companies.
e) Local professional associations (e.g., local safety councils, local
agriculture extensions).
f) Temporary employment agencies providing employees to targeted
employers.
g) Local newspapers, TV stations, and trade magazines (these can help
inform the public and hard-to-reach employers).
h) Local government (e.g., health departments, departments of correction,
emergency services, construction permitting agencies, and departments
of transportation).
i) Local suppliers of materials or services, equipment transportation
companies, such as landscapers, and delivery services.
4. Online Materials.
OSHA online resources may be of assistance in this outreach effort. A variety
of these information sources can be accessed through OSHA’s public
webpage, including OSHA’s webpage for the Heat Illness Prevention

21
Campaign, and Safety and Health Topics webpage on Heat Exposure.
Internal resources for heat are also available on the OSHA intranet.
H. Coordination.
1. National Office.
This NEP will be coordinated by the DEP Office of Health Enforcement (OHE).
All questions and comments regarding this NEP should be directed to OHE.
For inspection support, Area and Regional Offices may also coordinate, as
needed, with the Directorate of Technical Support and Emergency
Management’s (DTSEM), Office of Occupational Medicine and Nursing
(OOMN), the OSA, the OSHA Technical Center (OTC), the OTC’s Health
Response Team, and other offices. For questions about outreach support
and resources, contact the Directorate of Cooperative and State Programs’
(DCSP) Office of Outreach Services and Alliances.
2. Regional Office.
Each Regional Administrator is required to identify a coordinator for this NEP
who will work with DEP’s Office of Health Enforcement.
I. Program Review.
To assess the effectiveness of this NEP, DEP will review the NEP within 12
months of issuance, per ADM 03-00-008, to determine whether the policy
contained herein will be continued, and take steps to assure its replacement
with a cleared Instruction, if needed, as soon as possible. The program review
reports shall, at a minimum, address the NEP goal (see Section XI), in accordance
with established agency procedures. Data on effectiveness may include:
1. The number of employers covered by the inspections.
2. The number of workers removed from hazards.
3. Abatement measures implemented.
4. Number of violations related to specific targeted hazards.
5. Any indices that relate directly to measures that may be included in the DOL
Strategic Plan and/or the OSHA Agency Management Plan.
6. Total number of prosecutable, heat-related violations of OSHA standards
(including final citations resulting from the settlement or litigation of
contested cases).

A-1
Appendix A. Target Industries for the Heat NEP

Area Offices shall use establishment lists derived from this Appendix to conduct programmed
inspections under this NEP on days that the NWS has announced a heat warning or advisory for
the local area (see Appendix G for a description of these types of alerts). This appendix includes
three tables of industries (NAICS codes at the 4-digit level) with the following: 1) High numbers
or high incidence rates of heat related illnesses from the Bureau of Labor Statistics (BLS) data
from calendar years 2021 to 2024; 2) Elevated number of days away, restricted, or transferred
(BLS) from calendar years 2021 to 2024; 3) High numbers of severe cases of heat-related
illnesses, as indicated by death or hospitalization, from OSHA severe injury reports made
by employers for calendar years 2021 to 2024; or 4) OSHA heat related inspections of
establishments with issued heat-related General Duty Clause 5(a)(1) violations and hazard alert
letters (HALs) from calendar years 2022 to 2025. Table 1 lists non-construction industries in
ListGen, Table 2 lists construction industries, and Table 3 lists non-construction industries not
found in ListGen.
Compared to the 2022 Heat NEP, the data update resulted in 46 target industries removed from
the tables, 22 industries added, and 33 industries retained, for a total of 55 target industries.
The 22 new industries added to the target list in Appendix A are noted with † mark.

Note: It should not be assumed that employee exposure to heat occurs in all establishments
within the industries listed in the tables below. The AO may delete from their target list any
establishment that does not have an exposure to heat-related hazards or an establishment that
has had a comprehensive or partial health inspection that addressed heat hazards with an
Opening Conference date occurring within the twelve (12) previous months, see Section XII B3,
Site Selection Deletions.

Table 1. Non-construction industries in ListGen that are likely to have heat-related hazards.
2017 4-Digit
NAICS Code 2017 NAICS Industry Sector Title
1121  Cattle Ranching and Farming
1122† Hog and Pig Farming
1151  Support Activities for Crop Production
3115† Cheese manufacturing
3116† Animal Slaughtering and Processing
3118 Bakeries and Tortilla Manufacturing
3211  Sawmills and Wood Preservation
3241  Petroleum and Coal Products Manufacturing
3261† Plastic Product Manufacturing
3271† Clay Product and Refractory Manufacturing
3273† Cement and Concrete Product Manufacturing
3312† Steel Product Manufacturing from Purchased Steel
3314  Nonferrous Metal (except Aluminum) Production and Processing
3315 Foundries
3323  Architectural and Structural Metals Manufacturing

A-2
3335† Metalworking Machinery Manufacturing
3353† Electrical Equipment Manufacturing
3362  Motor Vehicle Body and Trailer Manufacturing
3379† Other Furniture Related Product Manufacturing
4238† Machinery, Equipment, and Supplies Merchant Wholesalers
4244  Grocery and Related Product Merchant Wholesalers
4522† Department Stores
4811† Scheduled Air Transportation
4841† General Freight Trucking
4881  Support Activities for Air Transportation
4882  Support Activities for Rail Transportation
4883  Support Activities for Water Transportation
4884  Support Activities for Road Transportation
4921  Couriers and Express Delivery Services
4922  Local Messengers and Local Delivery
4931  Warehousing and Storage
5617
Services to Buildings and Dwellings (includes landscaping services, tree
removal and tree trimming services)
5621  Waste Collection
6242† Community Food and Housing, and Emergency and Other Relief Services
8111  Automotive Repair and Maintenance

The AO should use C-Target to find active construction sites to add to their programmed
inspection list on any day that the NWS has issued a heat warning or advisory for the local
area. (Note that if a project from the C-Target list is inspected, the AO must account for all
projects from that list by either inspection or deletion in accordance with CPL 02-00-
155). Where OSHA is conducting an inspection for other purposes, a heat-related inspection
shall be opened for all hazardous conditions observed in plain view (such as employees or
temporary workers in high exposure areas without adequate training, acclimatization or access
to water, rest, and shade).

Table 2. Construction industries that are likely to have heat-related hazards.*
2017 4-Digit
NAICS Code 2017 NAICS Industry Sector Title
2361 Residential Building Construction
2362 Nonresidential Building Construction
2371  Utility System Construction
2373  Highway, Street, and Bridge Construction
2381  Foundation, Structure, and Building Exterior Contractors
2382  Building Equipment Contractors
2383  Building Finishing Contractors
2389  Other Specialty Trade Contractors

A-3
* Note: Construction inspections (C-Target) should be scheduled from a list of construction
worksites rather than construction employers, due to the mobility of the construction industry,
the transitory nature of construction worksites, and work that frequently involves more than
one construction employer on the site.

For certain industries not included in ListGen, alternative sources may be used (e.g.,
ReferenceUSA). The AO should use local knowledge to add these industries in Table 3 to the
inspections list.

Table 3. Industries not included in ListGen or Construction that are likely to have heat-related
hazards.
2017 4-Digit
NAICS Code 2017 NAICS Industry Sector Title
1112 Vegetable and Melon Farming
1114† Greenhouse, Nursery, and Floriculture Production
2211† Electric Power Generation, Transmission, and Distribution
4412 Other Motor Vehicle Dealers
4832† Inland Water Transportation
4911 Postal Service
5173† Wired and Wireless Telecommunications Carriers
5413† Architectural, Engineering, and Related Services
5416† Management, Scientific, and Technical Consulting Services
5613 Employment Services*
6241† Individual and Family Services
7225 Restaurants and Other Eating Places
* Note: Establishments within the Temporary Help Services (NAICS 5613) industry should not be
automatically included in the targeting list for programmed inspections. Although this industry
has been among the top industries with OSHA enforcement activities related to heat, this has
primarily occurred where services occurred at a high-hazard host. Therefore, to effectively
address heat-illness hazards for Temporary Help Services, where OSHA is conducting an
inspection for other purposes, a heat-related inspection shall be opened for all hazardous
conditions observed in plain view (such as, for example, temporary employees working in high
exposure areas without adequate training, acclimatization or access to cool water, rest, and
shade). See also, OSHA Temporary Worker Initiative (TWI) Bulletin No. 12, Exposure to Outdoor
and Indoor Heat-Related Hazards, OSHA 4185-07-2022.

Sources for injury and illness data:
A. Bureau of Labor Statistics (BLS) Nonfatal Occupational Injuries and Illnesses from
exposure to environmental heat resulting in days away, restricted activity, or job
transfer (DART) cases due to exposure to heat, 2021-2024.
B. BLS Nonfatal Occupational Injuries and Illnesses incidence rates from exposure to
environmental heat resulting in days away, restricted activity, or job transfer (DART) and
high number of median DART, 2021-2024.

A-4
C. OSHA severe injury reports fatalities and hospitalizations 2021-2024. Hospitalization
reports include all employer-reported referrals with Event Title “Exposure to
Environmental Heat.” Fatality reports include all fatality investigations with victim
type “Fatality-OSHA Covered” and any of the following public page keywords: Heat
Stroke, Heat Exhaustion, Heat-Related Illness, High Temperature, Overheated, Heat.
D. OSHA heat-related inspections resulting in a General Duty Clause violation or Hazard
Alert Letter (using “Heat” as keyword), April 8
th
2022-2025.

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Appendix B. CSHO Pre-Inspection Checklist

Below follows some protective measures for CSHOs to consider prior to any heat-
related inspection:
A. Ensure the availability and use of all necessary and appropriate personal protective
equipment (PPE).
B. Ensure all PPE, calibrated inspection equipment, and supplies are retrievable and ready
for use.
C. Review any relevant cleaning procedures for equipment and the vehicle, government
(GOV) or personal (POV).
D. For all heat inspections, the manager/supervisor/CSHO, in consultation with designated
regional office staff, will develop and document a risk assessment that includes an
exposure control plan, Job-Hazard Analysis, and PPE hazard assessment prior to
entry and update it as necessary for each inspection, to include individual inspection
risks that may not otherwise be captured in a general or overall worksite
assessment. Individual inspection risks may be based on factors such as industry type,
on-site hazard location, and acclimatization.
E. Ensure GOV or POV is road-ready to include gas/fuel, first aid kit, hand sanitizer,
disinfecting wipes, or other cleaning and/or disinfecting agents (as required), and bags
to dispose of contaminated PPE and used disinfecting wipes.
F. Ensure there is enough cool water available to drink, while performing an inspection on
a heat priority day and in accordance with the JHA in d. above; (NIOSH recommends a
cup of water every 15 minutes). Ensure the air conditioning in the GOV or POV is
adequate to provide a cool place to rest during inspections on heat priority days. ADs
are to provide addition items as needed (such as cooler, umbrella).
G. Develop a document request letter in advance of the opening conference
(e.g., programs, OSHA Form 300/300A, and summaries) to be provided to the employer
during the opening conference, if needed.

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Appendix C. Sample Heat-related AVD

The alleged violation description (Alleged Violation Description (AVD) language for heat-related
hazard violations of Section 5(a)(1) must specify the heat-related hazard with particularity, such
as listing all sources of heat (e.g., environmental temperature measurements and information
on any heat-generating equipment), all specific workplace conditions, activities or practices that
expose employees to a likelihood of heat-related illnesses including related work exertions
(e.g., performing moderate to very heavy roofing work, dumping heavy refuse bins while
running behind a sanitation truck, and wearing impermeable protective clothing), as applicable.
The alleged heat-related hazard descriptions should not include the employer’s failure to
implement any specific abatement measures, such as acclimatizing workers to the heat; failure
to provide cool drinking water, a cool shaded area, or air conditioning; or training workers on
heat stress.

Example AVD:

On or about and at times prior to [the date of the incident or employee exposure], employees
were exposed to the hazard of high heat from [list sources of and conditions of ambient heat,
such as direct sun, boiler, steam, furnace, combustion engine] during the performance of their
job duties, including [describe specific task(s), type(s) of strenuous activities, and duration of
exposure, and any personal protective equipment (PPE) worn by workers on this day, (list the
specific types of PPE such as heavy and/or bulky clothing) which could intensify heat-related
exposure]. [List the high temperatures or heat indexes for the days at issue (include days prior
to day of incident if employees exposed on prior days), relative humidity, list levels and/or WGBT
measurements and calculations, and any aggravating factors such as heavy or bulky clothing,
direct sunlight, and level of workload activities. Include any National Weather Service heat
advisory, warning, or alert’s specified temperature(s) that supports a high ambient hazardous
heat conditions and WBGT if known]. Such exposures are likely to lead to the development of
serious heat-related illnesses such as, but not limited to, heat cramps, heat exhaustion, and
heat stroke. [Describe any heat-related incidents/illnesses, any heat-related injuries,
hospitalizations, visits to urgent care centers medical clinics, or signs and symptoms that may
have occurred].

The inspection case file should document any NWS local heat alerts, the reading on the OSHA-
NIOSH Heat Safety Tool App (use the camera screenshot function to save the image of the
reading), WBGT temperature if available, wind speed and /direction, radiant heat, cloud cover,
length of time the work was performed, and other sources of heat in the workplace.
Additionally, document if any of the exposed employees were temporary workers, new hires, or
employees returning from prolonged leave periods who were not acclimatized to the heat
environment. See Section XII.D for more details.

When listing availability of feasible abatement methods, document all potential measures
that would have materially reduced or eliminated the heat-related hazard, such as providing

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cool water, frequent rest breaks, cooling or cool shaded areas, gradually acclimatizing workers
to heat, and access to first aid/prompt medical attention.

Any water or other fluids provided by the employer should be cool and provided in a location
that is familiar to the employees, readily accessible to the work, easy to access, and in sufficient
quantity for the duration of the work.

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Appendix D. Sample Heat-related Hazard Alert Letter

SAMPLE HAZARD ALERT LETTER
Note: This letter must be adapted to the specific circumstances noted in each inspection. The
letter below is an example of the type of letter that may be appropriate in some circumstances.
If the employer has implemented, or is in the process of implementing, efforts to address
hazardous heat conditions, those efforts should be recognized as appropriate. CSHOs should
tailor the recommended controls outlined below to the specific needs of the employer. Italicized
and bracketed text are for OSHA compliance use only and should not be included in the
letter. Please also check all links to ensure they are the most current.

RE: OSHA Inspection No. [ ]
Dear Employer:
An inspection of your workplace and evaluation of your OSHA recordkeeping logs at [location]
on [date] disclosed the following workplace condition(s) which have been associated with the
development of heat-related illnesses in workers:
[Describe the work performed for each task or job, including the type of PPE worn, the source of
heat, WBGT and duration of the heat exposure, reading on the OSHA-
NIOSH Heat Safety Tool App during the inspection, any heat notifications from the National
Weather Service, and any other information relevant to workers' exposure to the risk of heat-
related illness].
In the interest of workplace safety and health, I recommend that you voluntarily take the
necessary steps to materially reduce or eliminate your workers' exposure to the conditions
listed above, including, but not limited to, the following:
1. General Controls:
General controls include training, personal protective equipment (PPE), engineering,
work practice, and administrative controls, and heat alert programs (see also NIOSH
Criteria Document, Criteria for a Recommended Standard: Occupational Exposure to
Heat and Hot Environments, February 2016, page 7, available at:
www.cdc.gov/niosh/docs/2016-106
).
2. Training: inform workers of the following (Modify this list as appropriate for the specific
situation):
a. Hazards of heat-related illnesses.
b. How to avoid heat-related illnesses by recognizing and avoiding situations that can
lead to heat-related illnesses.
c. Recognition of signs and symptoms of heat-related illnesses.

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d. First aid procedures.
e. Employer's program to address heat-related illnesses.
f. Advise workers that certain medications and medical conditions can increase risk of
heat stress. These may include, but are not limited to:
1) Amphetamines – sometimes prescribed for narcolepsy or attention deficit
hyperactivity disorder (ADHD),
2) Diuretics - water pills,
3) Antihypertensives - blood pressure medication,
4) Anticholinergics - for treatment of chronic obstructive pulmonary disease
(COPD), and
5) Antihistamines - allergy medications
g. In addition, alert workers to the dangers of using illegal drugs and alcohol in hot
work environments. Illegal amphetamines, such as methamphetamine, are
particularly hazardous when heat stress is present.
h. Some conditions, such as pregnancy, fever, gastrointestinal illness, heart disease,
and obesity, may increase the risk of heat-related illness. Advise workers to check
with their doctors if they have any questions. (Please note: the employer is NOT
entitled to know whether workers have these conditions, but only whether workers
have any health conditions that limit their ability to perform their job duties. In
some instances, workers with chronic conditions may need extra time to become
acclimatized or may need other accommodations, such as more frequent breaks or
restricted work.)
i. Encourage workers to consult a doctor or pharmacist if they have questions about
whether they are at increased risk for heat-related illness because of health
conditions they have and/or medications they take.
3. Personal Protective Clothing and Equipment: (CSHOs should recommend
the appropriate PPE).
a. Hats for work outdoors in the sun.
b. For indoor work, loosely worn reflective clothing designed to deflect radiant heat,
such as vests, aprons, or jackets.
c. Cooling vests and water-cooled/dampened garments may be effective under high
temperature and low humidity conditions. However, be aware that cooling vests can
become an insulator when they reach the body's temperature.

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d. In environments where respirator usage is necessary, consult with an industrial
hygienist to determine the appropriate clothing to prevent heat stress while still
protecting the workers.
4. Engineering Practice Controls: (CSHOs should consult the OSHA Technical
Manual, Section III Chapter 4, for additional information).
a. Use air conditioning
b. Increase general ventilation
c. Provide cooling fans
d. Run local exhaust ventilation where heat is produced (e.g., laundry vents)
e. Use reflective shields to block radiant heat
f. Insulate hot surfaces (e.g., furnace walls)
g. Stop leaking steam
h. Provide shade for outdoor work sites.
5. Administrative and Work Practice Controls: (CSHOs should consult the OSHA Technical
Manual, Section III Chapter 4, for additional information).
a. Schedule hot jobs for cooler parts of the workday; schedule routine maintenance
and repair work during cooler seasons of the year when possible.
b. Provide adequate, cool drinking water on the worksite that is easily accessible
and permit employees to take frequent rest and water breaks.
c. Use relief workers and reduce physical demands of the job.
d. Use work/rest schedules.
g. Allow new workers and workers returning from extended absences to get used to
hot working environments by gradually increasing their workload.
You may voluntarily provide this Area Office with progress reports on your efforts to address
these heat-related conditions in your workplace. OSHA may return to your worksite to further
examine the conditions noted above.
Sincerely,
[AD name]
Area Director

Additional Resources:
1. OSHA-NIOSH InfoSheet:  Protecting Workers from Heat
Illness, www.osha.gov/sites/default/files/publications/osha-niosh-heat-illness-
infosheet.pdf.

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2. CDC Workplace Safety and Health Topics: Heat
Stress, www.cdc.gov/niosh/topics/heatstress.
3. NIOSH Criteria Document: Criteria for a Recommended Standard: Occupational
Exposure to Heat and Hot Environments, February
2016, www.cdc.gov/niosh/docs/2016-106/.
4. American Conference of Governmental Industrial Hygienists (ACGIH®) Action Limit (AL)
for un-acclimatized workers and a Threshold Limit Value (TLV®) for acclimatized
workers, see Heat Stress and Strain: TLV® Physical Agents 2026 or
latest edition. See ACGIH® website at https://www.acgih.org/.
5. NOAA/NWS Heat Safety webpage, www.weather.gov/safety/heat.

E-1
Appendix E. Sample Employer Letter to Corporate Offices for Heat-related Hazards

Bracketed comments are for OSHA compliance use only and should be removed when
appropriately completed with the case-specific information. Please also check all links to
ensure they are the most current.

RE: OSHA Inspection No. [ ]
Dear Employer:
On [Date], the Occupational Safety and Health Administration (OSHA) conducted an inspection
and evaluation of your worksite at [Location] for hazards related to potential exposure to heat-
related hazards.
During the inspection, OSHA determined that hazards were found in violation of the OSHA
standards, resulting in [a violation of section 5(a)(1) of the OSH Act or a Hazard Alert Letter]
to [Company]. A copy of the [citations and/or letter] is attached.
Based on the guidelines listed below, it is recommended that employers take the necessary
precautions to materially reduce employees' exposure to heat-related hazards.
Because you have other establishments that could present similar hazards, the Occupational
Safety and Health Administration is recommending that you conduct a hazard assessment for
potential hazards in your other establishment(s). To ensure that heat-related hazards are
promptly identified and addressed at your other locations, please facilitate immediate
corrective action where needed. OSHA recommends that you also institute additional heat-
illness measures and review the safety and health practices of your worksites to ensure
consistency with OSHA recommendations and compliance with applicable OSHA
standards, including:
1. The Recordkeeping regulation at 29 CFR § 1904.7(b)(5), which requires that employers
record certain work-related injuries and illnesses. If a worker requires medical
treatment beyond first aid, the worker's illness or injury must be recorded. However, if
a worker merely requires first aid treatment for the worker's condition, the employer is
not required to record the condition. For example, if a worker becomes unconscious,
the worker's condition must be recorded. However, if a worker is only instructed to
drink fluids for relief of heat stress, the worker's condition is not recordable. Refer to 29
CFR § 1904.7(b)(5) for an explanation of the difference between medical treatment and
first aid. Recordkeeping issues must be handled in accordance with OSHA
Instruction, CPL 02-00-172, Part 1904 Recordkeeping Policies and Procedures Directive.
2. The Sanitation standards at 29 CFR § 1910.141, 29 CFR § 1915.88, 29 CFR § 1917.127, 29
CFR § 1918.95, and 29 CFR §1926.51, which require employers to provide potable
water. The Field Sanitation standard at 29 CFR § 1928.110 requires employers to
provide cool potable water.

E-2
3. The general construction safety training and education standard for construction at 29
CFR § 1926.21 and 29 CFR § 1926.20, which require a Safety and Health Program, as well
as frequent and regular safety and health inspections.
4. Section 5(a)(1), General Duty Clause of the Occupational Safety and Health Act (OSH
Act), which requires that employers furnish their employees employment and a place of
employment which are free from recognized hazards that are causing or are likely to
cause death or serious physical harm.
OSHA’s website, www.osha.gov, offers a wide range of safety and health-related guidance in
response to the needs of both employers and employees.
1. OSHA’s Heat Illness Prevention Campaign, www.osha.gov/heat
2. OSHA Safety and Health Topics: Heat, www.osha.gov/heat-exposure
We strongly urge you to share this letter with all worksites within your corporation, as well as
with representatives of any recognized employee union or safety committee that may exist at
your facilities.
Please note that Section 11(c) of the OSH Act protects employees against retaliation or adverse
action because of their involvement in protected safety and health related activity.
If you have questions regarding this issue, you may contact me at the address in the letterhead.
I appreciate your personal support and interest in the safety and health of your employees.
Sincerely,
[AD name]
Area Director

Additional Resources:
1. OSHA-NIOSH InfoSheet: Protecting Workers from Heat Illness,
www.osha.gov/sites/default/files/publications/osha-niosh-heat-illness-infosheet.pdf
2. CDC Workplace Safety and Health Topics: Heat Stress,
https://www.cdc.gov/niosh/topics/heatstress.
3. NIOSH Criteria Document: Criteria for a Recommended Standard: Occupational
Exposure to Heat and Hot Environments, February
2016, www.cdc.gov/niosh/docs/2016-106/.
4. American Conference of Governmental Industrial Hygienists (ACGIH®) Action Limit (AL)
for un-acclimatized workers and a Threshold Limit Value (TLV®) for acclimatized
workers, see Heat Stress and Strain: TLV® Physical Agents 20222026, or latest edition.
See ACGIH® website at https://www.acgih.org/.
5. NOAA/NWS Heat Safety webpage, www.weather.gov/safety/heat.

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Appendix F. Description of Serious Heat-related Illnesses and Common Symptoms

The table below describes serious heat-related illnesses and common signs and symptoms.
Please note that this list is not exhaustive.
Heat-Related Illnesses* Symptoms and Signs
Heat stroke • Confusion
• Slurred speech
• Unconsciousness
• Seizures
• Heavy sweating or hot, dry skin
• Very high body temperature
• Rapid heart rate
Heat exhaustion • Fatigue
• Irritability
• Thirst
• Nausea or vomiting
• Dizziness or lightheadedness
• Heavy sweating
• Elevated body temperature or fast heart rate
Heat cramps • Muscle spasms or pain
• Usually in legs, arms, or trunk
Heat syncope • Fainting
• Dizziness
Heat rash • Clusters of red bumps on skin
• Often appears on neck, upper chest, and skin folds
Rhabdomyolysis (muscle
breakdown)
• Muscle pain
• Dark urine or reduced urine output
• Weakness
Acute kidney injury (AKI) • Kidneys become damaged due to inadequate
blood flow or a second mechanism is
rhabdomyolysis of kidney muscle tissue.
• Diagnosed by elevated blood creatinine levels.
Urine output is also reduced.
• May lead to kidney failure
* Heat-related injury means an injury linked to heat exposure that is not considered one of the
typical symptoms of heat-related illness (with the exception of kidney injury), such as a fall or
cut.

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Appendix G. Warnings, Alerts, and Advisories Issued by the National Weather Service

The following types of warnings, alerts, and advisories may be issued by the U.S. National
Oceanic and Atmospheric Administration (NOAA), National Weather Service (NWS).
Note: The actions are paraphrased below to remove non-occupational content (e.g., “...check
on family and neighbors”).
 Extreme Heat Warning—Take Action! An Extreme Heat Warning is issued when
extremely dangerous heat conditions are expected or occurring. Avoid outdoor
activities, especially during the heat of the day. If you must be outside, be sure to drink
plenty of water and take frequent breaks in the shade. Stay indoors in an air-
conditioned space as much as possible.
 Extreme Heat Watch—Be Prepared! An Extreme Heat Watch is issued when conditions
are favorable for an extreme heat event but its occurrence and timing is still uncertain.
Plan to suspend all major outdoor activities if a warning is issued. If you do not have air
conditioning, locate the nearest cooling shelter.
• Heat Advisory—Take Action! A Heat Advisory is issued for dangerous heat conditions
that are not expected to reach warning criteria. Consider postponing or rescheduling
outdoor activities, especially during the heat of the day. If you must be outside, be sure
to drink plenty of water and take frequent breaks in the shade. Stay in a cool place,
especially during the heat of the day.

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Appendix H. Additional Resources

1. Federal Register, 89 FR 70698, 29 CFR § 1910, 1915, 1917, 1918, 1926, and 1928, Heat
Injury and Illness Prevention in Outdoor and Indoor Work Settings; Advance Notice of
proposed rulemaking (ANPRM), OSHA, August 30, 2024.
2. State Plans with Heat Standards: CA, CO, MD, MN, NV, OR, WA
• California – Heat Illness Prevention in:
o Title 8 §3395 Outdoor Places of Employment
o Title 8 §3396 Indoor Places of Employment
• Colorado - 7 CCR 1103-15 Heat Illness and Injury Protection
• Maryland - 09.12.32 Heat Stress Standards
• Minnesota - 5205.0110 Indoor Ventilation and Temperature in Places of
Employment
• Nevada - R131-24AP Heat Illness Prevention
• Oregon - 437-002-0156 Heat Illness Prevention
• Washington – Outdoor Heat Exposure Rules:
o General industry: WAC 296-62-095 through 09560
o Agriculture: WAC 296-307-097 through 09760
o Firefighters/Fire Departments: WAC 296-305-05004
o Wildland Firefighters: WAC 296-305-07004
Outreach
3. OSHA Memorandum, Procedures for Local and Regional Emphasis Programs,
December 3, 2014.
4. OSHA Publication 3905, Whistleblower: Recommended Practices for Anti-Retaliation
Program, 2017.
5. OSHA Webpage, Heat Illness Prevention Campaign.
6. OSHA Webpage, Safety and Health Topic Page: Heat (all webpages also available in
Spanish).
7. OSHA Poster, Prevent Heat Illness at Work (English), (Spanish).
8. OSHA Publications:  Heat Illness Prevention Fact Sheets, Wallet Cards, etc. (several
also available in Spanish).
9. OSHA-NIOSH Info Sheet, OSHA 3438 – 2011, Protecting Workers from Heat Illness.
10. OSHA Temporary Worker Initiative (TWI) Bulletin No. 12, Exposure to Outdoor and
Indoor Heat-Related Hazards, OSHA 4185-07-2022.

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Appendix I. Evaluation of a Heat Program

Determine if the employer has a heat illness and injury program addressing the following:
1. Is there a heat program (written or verbal) that is effectively communicated to
employees?
2. How did the employer monitor ambient temperature(s) and levels of work exertion
at the worksite?
3. Were there sufficient amounts of cool water easily accessible to the employees?
4. Did the employer allow additional breaks for hydration?
5. Were there scheduled rest breaks?
6. Was there access to a shaded area?
7. Did the employer provide time for acclimatization of new and returning workers?
8. Were administrative controls used (earlier start times, workload adjustments, and
employee/job rotation) to limit heat exposures?
9. Did the employer provide training on heat illness signs, how to report signs and
symptoms, first aid, how to contact emergency personnel, prevention, and the
importance of hydration?
10. Do employees and supervisors understand the heat program?
11. Is the heat program properly implemented and managed by a designated heat
safety representative?

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Appendix J: Citation Guidance

Citation Guidance: CSHOs shall consult this Instruction and its references, and any internal
guidance on heat enforcement available on the DEP intranet page, and guidelines in
evaluating whether there is sufficient evidence to issue a General Duty Clause (GDC),
Section 5(a)(1) citation for heat-related hazards. Any proposed citation for a heat-related
health hazard for both indoor and outdoor work activities shall be issued under the GDC
when all elements of a violation have been established. CSHOs should document the
relationship between the workplace operations and exposure(s) and the potential for heat-
related illness(es), specifically focusing on all ambient conditions and activities that present
heat-related hazards.
1. Ensure that the hazard is clearly and specifically set forth in the citation. Avoid solely
describing an employer’s failure to implement specific heat illness abatement
measures as the hazard. The Regional Solicitor office should be consulted
for assistance when developing these cases prior to issuing any heat-related 5(a)(1)
citations. A sample Alleged Violation Description (AVD) for a heat-related illness
5(a)(1) violation is located in Appendix C. A Hazard Alert Letter (HAL) may be sent
when all the elements of a GDC violation have not been established. A sample
HAL is located in Appendix D, and a corresponding letter template is in the OIS.
2. Document conditions relevant to heat-related hazards. See below and Appendix I:
a. The heat index and additional weather data from that day, e.g., heat alerts from
the NWS, data from the OSHA-NIOSH Heat Safety Tool App, saving a screenshot
on a mobile phone or tablet. Additional information may be needed or indoor
heat investigations
b. Observe and document current conditions and those at the time the incident
occurred (for unprogrammed inspections), including:
1) Observed wind speed,
2) Relative humidity,
3) Dry bulb temperature at the workplace and in the shaded rest area,
4) Wet-bulb globe temperature (WBGT) at the workplace, (ensure the
equipment has been properly calibrated prior to use),
[Note: WBGT readings will be determined in accordance with procedures on
conducting WBGT sampling and performing workplace assessments, OSHA
Technical Manual (OTM), Section III, Chapter 4. WBGT sampling is
considered a more accurate indicator of the effects of heat on individuals
than dry bulb thermometer readings. Dry bulb thermometer readings
measure air temperature only. As noted above, CSHOs should also conduct

J-2
workload assessments through direct observation of work
practices/operations and employee interviews. They should particularly note
if heavy or bulky clothing or equipment is used.]
5) Cloud cover (no clouds, 25%, 50%, 75%, 100%), and
6) The existence of any heat advisories, warnings, or alerts the previous days.
3. Several OSHA standards may also be applicable to address worker protection in hot
environments including, but not limited to, use of personal protective equipment,
sanitation, medical services and first aid, and recordkeeping.
a. The Recordkeeping regulation at 29 CFR § 1904.7(b)(5) requires that employers
record certain work-related injuries and illnesses. If a worker requires medical
treatment beyond first aid, the worker’s illness or injury must be recorded, such
as unconsciousness or use of oxygen. However, if a worker merely requires first
aid treatment for the worker’s condition, the employer is not required to record
the condition. For example, if a worker becomes unconscious, the worker’s
condition must be recorded. However, if a worker is only instructed to drink
fluids for relief of heat stress, the worker’s condition is not recordable. Refer to
29 CFR § 1904.7(b)(5) for an explanation of the difference between medical
treatment and first aid. Recordkeeping issues must be handled in accordance
with OSHA Instruction, CPL 02-00-172.
Note: Not all industries covered by the Heat NEP are required to maintain OSHA
records, and CSHOs should check to see if the industry of the establishment being
inspected is on Appendix A to subpart B of Part 1904. If the establishment is
exempt from maintaining OSHA records, either because of size (per 29 CFR §
1904.1) or industry classification (per § 1904.2), it cannot be cited for failing to
record an injury or illness.
b. The Sanitation standards at 29 CFR § 1910.141, 29 CFR § 1915.88, 29 CFR §
1917.127, 29 CFR § 1918.95, and 29 CFR § 1926.51 require employers to provide
potable water. The Field Sanitation standard at 29 CFR § 1928.110 requires
employers to provide cool potable water.
c. The general construction safety training and education standards for
construction at 29 CFR § 1926.21 and 29 CFR § 1926.20, require a Safety and
Health Program and frequent and regular safety and health inspections.
Note: Issuance of citations or HALs should be expedited so that proposed abatement
measures may be implemented earlier to protect employees exposed to heat hazards.
In all cases where the AD determines that a worksite condition exists warranting issuance of
a 5(a)(1) GDC citation for occupational exposure to the heat-related hazards, the Area Office
shall follow current National Office guidance regarding the level of review.

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Coding: CSHOs should identify any heat violations or HALs using the General Duty Keyword
in the violation screen.  CSHOs should enter “Heat” in the general duty keyword
section. The Heat keyword is in addition to the other required heat coding for violations,
such as Related Event Codes as applicable.
General Duty
Keyword
Heat All heat-related violations and HALs