OSHA's heat rule may be stuck in rulemaking, but the enforcement that uses the same standard is not. The 2026 National Emphasis Program (NEP) for heat calls for 2,400 programmed heat inspections annually, targeting outdoor work and hot indoor work where the heat index is high.
What the NEP Expects You to Have
- Heat illness prevention plan: Written, with acclimatization for new and returning workers, scheduled rest, shade, and cool water.
- Training: Heat hazard, personal risk factors, and emergency response — documented by worker and date.
- Monitoring: Heat index checks, work/rest cycles, and supervisor monitoring, logged.
An inspector under the NEP will ask for those records, not just for a policy on a wall.
Bookkeeping That Proves Compliance
- Training log:
Date — Worker — Heat training — Hoursas a transaction note, retained. - Inspection log: Heat index at start of shift and at peak, rest breaks given, and any heat-related incident.
- Workers' comp and OSHA 300: Heat illnesses are recordable and affect experience modification. A single heat case that is not Acclimatized can raise the rate.
