OSHA Directives for Heat-Related Jobsite Inspections
Insights provided by Barry Rice.
The Status: Federal OSHA issued a National Emphasis Program for Outdoor and Indoor Heat-Related Hazards that took effect April 10, 2026. The Directive (CPOL 03-00-024) provides instruction for their inspectors to check jobsites for high-heat conditions and heat illness risks.
The Requirement: Federal OSHA only has heat risk recommendations and does not currently have heat risk regulations. However, their recommendations can be enforced through the General Duty Clause to protect employees.
Some states have independently created their own heat regulations that apply to restorers working in those states. These regulations are separate from Federal OSHA and enforced by state agencies.
Click here to learn more about the Federal and State heat requirements.
Federal OSHA identifies heat illness risks as heavy physical work, lack of acclimatization, hot environments, and heat-retaining protective clothing as heat illness risk factors. The agency recommends training, hydration, shorter initial shifts, breaks, workload controls, and temperature monitoring. Note that some states have their own heat standards, which can be more restrictive than Federal OSHA.
Restoration crews can be at risk of heat illness from:
- Strenuous restoration activities, including demolition,
- Use of respirators and protective clothing,
- Work in unconditioned buildings,
- Work in high humidity,
- Additional heat from generators and drying equipment,
- Working long shifts, and,
- Workers who are not acclimatized.
Restoration work can therefore create both heat illness risk and regulatory violations.
Recommended actions include:
- Create a corporate written heat program.
- Issue heat safety bulletins during high heat periods and before CAT deployments.
- Create job-specific written heat plans based on local conditions and applicable Federal/State regulations.
- Train supervisors on acclimatization, hydration, work/rest cycles, emergency response, and recognizing heat stroke.
- Use available resources for daily temperatures, heat index, and precautions; those resources can include local weather forecasts and the NIOSH/OSHA heat app.
- Include high-heat responsibilities in subcontractor agreements.
- If you work in the following states, verify you are following their specific requirements:
- Arizona
- California
- Colorado
- Minnesota
- Oregon
- Washington