Key Provisions of OSHA’s Proposed Rule to Protect Indoor/Outdoor Workers from Extreme Heat

July 10, 2024 | American Society of Safety Professionals | Blog | Colorado | Danger | OSHA

Here are the key provisions of this proposed rule:

1. Heat Exposure Assessment and Planning
• Worksite Analysis: Employers must conduct thorough assessments of their workplaces to identify potential heat hazards. This includes evaluating the physical environment, the nature of work tasks, and the specific conditions that contribute to heat stress.
• Heat Safety Plan: Employers are required to develop and implement a written heat safety plan. This plan should outline specific procedures for preventing heat-related illnesses and injuries, incorporating both preventative measures and emergency response protocols.

2. Heat Illness Prevention Measures
• Rest Breaks: The rule mandates regular rest breaks for workers in high-heat environments. The frequency and duration of these breaks depend on the temperature and the intensity of the work being performed.
• Hydration: Employers must provide an adequate supply of cool, potable water. Workers should have easy access to drinking water throughout their shifts, with guidelines suggesting at least one quart per hour per worker.
• Acclimatization: New workers, or those returning after an absence, must be gradually acclimated to high-heat conditions. The rule specifies a period of adjustment, typically ranging from 7 to 14 days, to allow workers’ bodies to adapt to the heat.

3. Training and Education
• Worker Training: Employers must provide training on heat-related illnesses and their prevention. This includes recognizing symptoms of heat stress, understanding the importance of hydration, and knowing how to respond to heat-related emergencies.
• Supervisor Training: Supervisors receive additional training on monitoring workers for signs of heat stress, implementing heat safety plans, and conducting emergency procedures if a worker exhibits symptoms of heat illness.

4. Monitoring and Recordkeeping
• Environmental Monitoring: Employers are required to monitor environmental conditions, such as temperature and humidity, to assess heat risks continuously. This data should be used to adjust work practices and protective measures in real time.
• Recordkeeping: Detailed records of heat exposure incidents, preventive measures taken, and training sessions conducted must be maintained. This helps ensure compliance and provides data for evaluating the effectiveness of heat safety programs.

5. Emergency Response
• First Aid and Medical Services: The rule mandates that employers provide prompt first aid and medical services for workers showing signs of heat-related illnesses. This includes having trained personnel on-site and ensuring quick access to medical facilities if needed.
• Emergency Action Plan: A clear, concise emergency action plan must be in place, outlining steps to take if a worker suffers from heat stress. This plan should be communicated to all workers and supervisors.

Pros and Cons of the Proposed Rule


1. Enhanced Worker Safety: The primary benefit of OSHA’s proposed rule is the increased protection of workers from the dangers of extreme heat. High temperatures can cause heat stress, heat exhaustion, and heatstroke, which can be fatal. By establishing clear guidelines and preventive measures, the rule aims to reduce the incidence of heat-related illnesses and fatalities.

2. Comprehensive Coverage: The rule is designed to cover both indoor and outdoor workers, acknowledging that extreme heat can affect various industries and environments. This comprehensive approach ensures that workers in construction, agriculture, manufacturing, and other sectors receive adequate protection.

3. Preventive Measures: The proposed rule emphasizes preventive measures such as hydration, rest breaks, and shaded areas. These measures are crucial in mitigating the effects of extreme heat on workers. Employers would be required to implement heat illness prevention plans, including acclimatization procedures for new workers or those returning from extended absences.

4. Increased Awareness and Training: The rule would mandate training for both employers and employees on recognizing and responding to heat-related illnesses. Increased awareness can lead to quicker responses and better outcomes when heat-related incidents occur. Training also empowers workers to advocate for their safety.

5. Economic Benefits: While there are upfront costs associated with implementing the rule, the long-term economic benefits could be significant. Reduced heat-related illnesses and fatalities can lead to lower healthcare costs, decreased absenteeism, and higher productivity. Healthy workers are more efficient and contribute positively to the overall economy.

6. Legal Clarity: The proposed rule would provide clear legal standards for employers to follow, reducing ambiguity and ensuring consistent enforcement. This clarity helps employers understand their responsibilities and legal obligations, potentially reducing the risk of litigation.


1. Implementation Costs: One of the main drawbacks of the proposed rule is the cost of implementation. Employers, especially small businesses, might face financial challenges in meeting the new requirements. These costs include providing adequate hydration, rest breaks, shaded areas, and training programs.

2. Operational Disruptions: Implementing the rule could lead to operational disruptions. For example, mandatory rest breaks and hydration schedules might slow down productivity, particularly in industries with tight deadlines and high demands. Adjusting to these new requirements could be challenging for some businesses.

3. Enforcement Challenges: Ensuring compliance with the new rule might be difficult. OSHA would need to allocate significant resources to inspect and enforce the regulations, which could strain their existing capabilities. Additionally, monitoring and enforcing compliance in remote or less accessible areas might pose logistical challenges.

4. Potential for Over-Regulation: Some stakeholders argue that the proposed rule could lead to over-regulation. They believe that existing guidelines and industry standards are sufficient and that additional regulations might be unnecessary and burdensome. This perspective is particularly prevalent among businesses that already have effective heat illness prevention programs in place.

5. Resistance from Employers: There might be resistance from employers who view the rule as an overreach of regulatory authority. This resistance could lead to pushback and legal challenges, potentially delaying the implementation of the rule. Employers might also be concerned about the potential impact on their competitiveness and profitability.

6. Adaptation Period: The proposed rule would require a period of adaptation for both employers and employees. Adjusting to new procedures and practices takes time, and there might be a learning curve involved. During this period, there could be confusion and inconsistencies in the application of the rule.

OSHA’s proposed rule to protect workers from extreme heat is a well-intentioned initiative aimed at improving worker safety and health. While it offers numerous benefits, including enhanced safety, comprehensive coverage, and economic advantages, it also presents challenges such as implementation costs, operational disruptions, and enforcement difficulties. Balancing these pros and cons will be crucial in shaping a rule that effectively safeguards workers while considering the practical realities faced by employers.