On Safety: OSHA’s NEP on outdoor, indoor heat hazards

What will inspectors look for?

Although OSHA doesn’t yet have a regulation/standard in place to cover worker exposure to heat, it does have the General Duty Clause – Section 5(a)(1) of the Occupational Safety and Health Act of 1970. Citations for heat exposure would be cited under this clause. Per the NEP, OSHA inspections will include:

• Reviewing OSHA 300 logs and 301 incident reports for any entries indicating heat-related illness(es).
• Reviewing any records of heat-related emergency room visits and/or ambulance transport, even if hospitalizations didn’t occur (this may require the use of a medical access order).
• Interviewing workers – including new employees and anyone who has recently returned to work – for symptoms of headache, dizziness, fainting, dehydration or other conditions that may indicate a heat-related illness.
• Determining if the employer has a heat illness and injury program that addresses heat exposure. OSHA will consider the following:
  • Is a written program in place?
  • How did the employer monitor ambient temperature(s) and levels of work exertion at the worksite?
  • Was there unlimited cool water that was easily accessible to the employees?
  • Did the employer require additional breaks for hydration?
  • Were there scheduled rest breaks?
  • Was there access to a shaded area?
  • Did the employer provide time for acclimatization of new and returning workers?
  • Was a “buddy” system in place on hot days?
  • Were administrative controls (earlier start times and employee/job rotation) used to limit heat exposures?
  • Did the employer provide training on the signs of heat illness, how to report signs and symptoms, first aid, how to contact emergency personnel, prevention, and the importance of hydration?


• Documenting conditions relevant to heat exposure, which includes:
  • The heat index and additional weather data from that day (examples: heat alerts from the National Weather Service, data from the OSHA-NIOSH Heat Safety Tool App, and a screenshot on a mobile phone or tablet. Additional information may be needed for indoor heat investigations.)
  • Observing and documenting current conditions and those at the time the incident occurred (for unprogrammed inspections), including:
    • Observed wind speed
    • Relative humidity
    • Dry-bulb temperature at the workplace and in the shaded rest area
    • Wet-bulb globe temperature at the workplace (ensure equipment has been properly calibrated before use)
    • Cloud cover (no clouds, 25%, 50%, 75%, 100%)
    • The existence of any heat advisories, warnings or alerts the previous days


• Identifying activities relevant to heat-related hazards. These can include:
  • Potential sources of heat-related illnesses (examples: working in direct sunlight; a hot vehicle; or areas with hot air or near a gas engine, furnace, boiler or steam lines)
  • The use of heavy or bulky clothing or equipment, including personal protective equipment
  • Estimated workload exertions, which can be determined by observing the types of job tasks performed and whether those activities can be categorized as moderate, heavy or very heavy work, while considering average workload and peak workload
  • Duration of exposure during which a worker is continuously or repeatedly performing moderate to strenuous activities

OSHA notes that not all industries covered by the NEP are required to maintain OSHA records. Compliance officers should check to see whether 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 its size (per 1904.1) or industry classification (per 1904.2), it can’t be cited for failing to record an injury or illness.