ABSTRACT-1 

U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration 

DIRECTIVE NUMBER: CPL 03-00-024 EFFECTIVE DATE: April 8, 2022 

SUBJECT: National Emphasis Program – Outdoor and Indoor Heat-Related Hazards 

ABSTRACT

Purpose: This Instruction describes policies and procedures for implementing a 

National Emphasis Program (NEP) to protect employees from heat-related 

hazards and resulting injuries and illnesses in outdoor and indoor 

workplaces. This NEP expands on the agency’s ongoing heat-related 

illness prevention initiative and campaign by setting forth a targeted 

enforcement component and reiterating its 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. 

Early interventions include, but are not limited to, implementing water, 

rest, shade, training, and acclimatization procedures for new or returning 

employees. 

Scope: This Instruction applies OSHA-wide.

References: 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: None. 

State Plan Impact: Notice of Intent Required, Adoption Encouraged. Federal Program 

Change, Notice of Intent Required, Equivalency Required. See Section 

VI. 

Action Offices: OSHA Regional and Area Offices, State Plan and OSHA On-Site 

Consultation programs 

Originating Office: Directorate of Enforcement Programs, Office of Health Enforcement 
ABSTRACT-2

Contact: Directorate of Enforcement Programs 

Office of Health Enforcement 

200 Constitution Avenue, NW, Room N3119

Washington, DC 20210

By and Under the Authority of 

DOUGLAS L. PARKER

Assistant Secretary
ABSTRACT-3

Executive Summary

This Instruction describes policies and procedures for implementing 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 is a new Instruction.
i 

Table of Contents

Contents

I. Purpose. .................................................................................................................................1

I. Scope. ....................................................................................................................................1

III. References. ............................................................................................................................1

IV. Cancellations. ........................................................................................................................2

V. Action Offices. ......................................................................................................................2

A. Responsible Office. ...............................................................................................................2

VII. Expiration. .............................................................................................................................3

VIII. Significant Changes. ..............................................................................................................3

IX. On-Site Consultation Programs.............................................................................................3

X. Background. ..........................................................................................................................3

XI. NEP Goal...............................................................................................................................6

XII. Program Procedures. .............................................................................................................6

A. General.......................................................................................................................... 6

B. Site Selection. ............................................................................................................... 7

C. Inspection Scheduling. .................................................................................................. 9

D. Inspection Procedures. ................................................................................................ 13

E. CSHO Protection. ....................................................................................................... 19

F. OSHA Information System (OIS) Coding Instructions. ............................................. 20

G. Outreach. ..................................................................................................................... 21

H. Coordination. .............................................................................................................. 23

I. Program Review.......................................................................................................... 23

Appendix A: Target Industries for the Heat NEP

Appendix B: CSHO Pre-inspection Checklist 

Appendix C: Sample Heat 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 illnesses and common symptoms 

Appendix G: Warnings, Alerts, and Advisories Issued by the U.S. National Oceanic and 

Atmospheric Administration (NOAA), National Weather Service (NWS)

Appendix H: Additional Resources 
1 

I. Purpose. 

This Instruction describes policies and procedures for implementing a 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 highhazard 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 In addition, this NEP focuses on 

vulnerable workers in outdoor and indoor environments by coordinating efforts with 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. Executive Order (EO) 14008, January 27, 2021.Executive Order (EO) 14008, 

Tackling the Climate Crisis at Home and Abroad. 

B. U.S. Department of Labor Climate Action Plan, September 2021, pgs. 6-7. 

C. OSHA Memorandum, Inspection Guidance for Heat-Related Hazards, September 

1, 2021. 

[Note, this memorandum, which began OSHA’s enforcement Heat Initiative, is 

being incorporated into this OSHA Instruction, and the memorandum will be 

archived upon the effective date of this NEP.] 

D. Section 5(a)(1) of the Occupational Safety and Health Act (OSH Act), 29 U.S.C. 

§ 654. 

E. OSHA Instruction, ADM 03-00-003, OSHA Directives System, December 11, 

2000. 

F. OSHA Instruction, ADM 03-01-005, OSHA Compliance Records, August 3, 

1998. 

G. OSHA Instruction, ADM 04-00-003, OSHA Safety and Health Management 

System, May 6, 2020. 

H. OSHA Instruction, CPL 02-00-025, Scheduling System for Programmed 

Inspections, January 4, 1995. 

I. OSHA Instruction, CPL 02-00-051, Enforcement Exemptions and Limitations 

under the Appropriations Act, May 28, 1998 (including annually updated 

Appendix A). 

J. OSHA Instruction, CPL 02-00-164, Field Operations Manual (FOM), April 14, 

2020. 
2 

K. OSHA Instruction, CPL 02-01-062, Site-Specific Targeting (SST), December 14, 

2020.

L. OSHA Memorandum, Establishment-Targeting Lists for Emphasis Programs, 

November 12, 2014. 

M. OSHA Instruction, FAP 01-00-008, Federal Agency Targeting Inspection 

Program, February 11, 2019.

N. OSHA Instruction, CPL 02-00-155, Inspection Scheduling for Construction, 

September 6, 2013. 

O. OSHA Instruction, CPL 02-03-007, Whistleblower Investigations Manual,

January 28, 2016.

P. OSHA Instruction, CPL 02-00-135, Recordkeeping Policies and Procedures 

Manual, December 30, 2004.

Q. OSHA Instruction, TED 01-00-015, OSHA Technical Manual (OTM), Section 

III, Chapter 4 – Heat Stress, September 15, 2017 (or latest update). 

R. OSHA-NIOSH Heat Safety Tool (smartphone App): Heat Safety Tool 

Application. 

S. OSHA Memorandum of Understanding, Wage and Hour Division (WHD) – 

Coordination and Information Sharing, August 4, 2021. 

T. NIOSH, Criteria for a Recommended Standard: Occupational Exposure to Heat 

and Hot Environments, DHHS (NIOSH) Publication Number 2016-106, February 

2016. 

U. 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.]

V. 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. 

None

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. 
3 

C. Information Offices. 

OSHA National Office. 

VI. Federal Program Change. 

Federal Program Change, Notice of Intent Required, Adoption Encouraged. This 

Instruction describes a federal program change that establishes an 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 Instruction, and 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 three years from the effective date, 

unless canceled or extended by a superseding directive.

VIII. Significant Changes. 

None.

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 radiant heat, 

especially when combined with humidity and inadequate cooling. See coding 

instructions for the OIS in Section XII.F. 

X. Background. 
4 

The U.S. Department of Labor’s Bureau of Labor Statistics (BLS) reports that between

2015 and 2019, environmental heat cases resulted in an average of 35 fatalities per year 

and an average of 2,700 cases with days away from work. However, the total number of 

heat-related fatalities may be underreported and improperly diagnosed. The cause of 

death is often listed as a heart attack when the actual cause or aggravating cause may 

have been exposure to a heat-related hazard. 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 2015 and 2020, Federal OSHA conducted approximately 200 

heat-related hazard inspections each year, which included approximately 15 heat-related 

fatality inspections annually. 

This NEP is part of a broader Department of Labor response to President Biden’s 

Executive Order (EO) 14008, “Tackling the Climate Crisis at Home and Abroad.” EO 

14008 established an interagency effort and commitment to workplace safety, climate 

resilience, and environmental justice. In response, the U.S. Department of Labor 

developed the Climate Action Plan, where the Secretary of Labor established a goal of 

reducing heat-related illnesses. In addition, on September 20, 2021, the White House 

issued a statement encouraging interagency efforts and commitment to workplace safety, 

climate resilience, and environmental justice that included reducing heat-related illnesses 

(See White House statement, here). OSHA’s initial enforcement response to the 

President’s order was to issue a heat initiative memorandum on September 1, 2021, 

instructing the Regional Offices to prioritize heat complaints and referrals and to 

intervene when they become aware of possible heat hazard conditions. 

This Heat NEP incorporates and expands on the September 1, 2021, heat initiative 

memorandum to further focus on heat-related hazards in both the outdoor and indoor 

work environments and provides procedures for planned/programmed and follow-up 

inspections in targeted workplaces. The 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 are 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 

into four categories: Caution (80°F – 90°F HI), Extreme Caution (91°F – 103°F HI), 

Danger (103°F – 124°F HI), and Extreme Danger (126°F or higher HI), issued by the 

U.S. Department of Commerce’s National Oceanic and Atmospheric Administration 

(NOAA), National Weather Service (NWS). See NWS webpage, here. When the heat 

index1 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. 

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.
5 

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. Heatrelated 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).1

 Appendix F of this memorandum provides 

a 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. Heatrelated 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).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 2022 Edition, or latest edition, available at 

www.acgih.org. 

The above alerts, advisories, and 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 

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. 
6 

to elevated dangerous heat conditions, unacclimatized workers may suffer serious heatrelated 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 0.5 percent of all Federal inspections 

during the last five years and included both unprogrammed (75 percent) and programmed 

(25 percent) inspections (e.g., including regional emphasis programmed inspections). 

The number of unprogrammed activities makes clear the continued need for heat-related 

outreach and compliance assistance activities, 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 heatrelated 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. Each Region is expected to have a 

fiscal year goal of increasing their heat inspections by 100% above the baseline of the 

average of fiscal years 2017 through 2021. 

To ensure abatement and to monitor the effectiveness of OSHA’s enforcement and 

guidance efforts, certain follow-up inspections from worksites previously inspected 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 open or refer a heatrelated inspection for any hazardous heat conditions observed, recorded in the 

OSHA 300 logs or 301 Incident Reports, or where an employee brings a heatrelated 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). Expansion of inspections 

shall be conducted in accordance with the FOM, Chapter 3, Section III.B, Partial 

Inspections. 

Additionally, CSHOs should inquire during inspections regarding the existence of 

any heat-related hazard prevention programs on heat priority days. A heat 

priority day occurs when the heat index for the day is expected to be 80°F or 

more. The AO will assess the potential for heat-related serious illnesses and

injuries where such hazards may exist in indoor or outdoor work areas on heat 

priority days and provide compliance assistance where needed. 
7 

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 heatrelated hazard incidents. During days of locally-issued heat warnings or 

advisories, establishment lists derived from Appendix A will be used for

programmed inspections, see Section XII, C.3. 

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 August 4, 2021. 

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 nonfarming with 10 or fewer employers, the CSHO should review CPL 02-00-051, 

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 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 Appendix A of 

CPL 02-00-051 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 Appendix A of 

CPL 02-00-051 is updated yearly. 

B. Site Selection. 

1. Scheduling/Site Selection. Targeting establishments for a programmed 

inspection must use neutral and objective selection criteria. 

 Any inspection that meets the conditions for a heat inspection and any heatrelated 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 
8 

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 

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 heatrelated 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 travelling 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 heatrelated 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, EstablishmentTargeting 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 
9 

created all at once or as necessary and need not be of the same size. Targeted 

Federal locations can be added when appropriate. 

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 heatrelated 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 02-00155, 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 
10 

goals of this NEP where unprogrammed activities have decreased sufficiently to 

allow that. 

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 
11 

controls in place such as access to water, rest, and/or shade), or 

involving workers suspected or confirmed of a heat-related illness, 

shall be given priority for on-site inspections. 

During all unprogrammed inspections, CSHOs must document the 

information required in Section XII.D. 

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, otherthan-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 related 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.

If resources allow, follow-up inspections/investigations may also be initiated 

to verify abatement of any hazards identified in Hazard Alert Letters for heatrelated hazards.

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 
12 

BLS median days away from work for the years 2015-2020, OSHA 

severe injury reports, OSHA-recorded inspections, heat-related 

violations, and Hazard Alert Letters issued since January 2018. (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 02-01-062, Site-Specific Targeting (SST) (or current 

version). 

5. Whistleblower 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 

matter 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 August 

4, 2021. 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 

further guidance if an On-Site Consultation visit is in progress, or if the 

establishment is a participant in OSHA’s Voluntary Protection Programs 
13 

(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.

Programmed inspections under a new NEP are typically initiated after a 90-day 

outreach period, as required for LEPs and REPs in accordance with OSHA

Memorandum on Procedures for Local and Regional Emphasis Programs, 

December 3, 2014. However, OSHA has continually conducted outreach at the 

National, Regional, and Area Office levels throughout the heat campaign that was 

first initiated in 2011. In addition to the ongoing heat campaign, on September 1, 

2021, OSHA issued a heat initiative enforcement memorandum instructing the 

Regions to increase their efforts to prioritize heat complaints and referrals and 

conduct interventions when they become aware of possible heat hazard 

conditions. Therefore, the 90-day outreach goal for this enforcement initiative 

has been achieved. Regions may perform more outreach as needed. 

OSHA will include additional information in its outreach efforts on the Heat NEP 

through webinars and conferences at the national and regional levels. The 

Agency will continue to conduct outreach, per Section XII.G, 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. 

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 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 - Heat Stress. 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 potential 5(a)(1) 

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 
14 

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 

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) Determine if the employer has a heat illness and injury program 

addressing heat exposure, and consider the following: 

• Is there a written program? 

• 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 used (earlier start times, and 

employee/job rotation) to limit heat exposures? 

• 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? 

e) Document conditions relevant to heat-related hazards, including: 

• 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 

• Observe and document current conditions and those at the time the 
15 

incident occurred (for unprogrammed inspections), including: 

o Observed wind speed, 

o Relative humidity, 

o Dry bulb temperature at the workplace and in the shaded rest area, 

o Wet-bulb globe temperature at the workplace, (ensure the 

equipment has been properly calibrated prior to use), 

o Cloud cover (no clouds, 25%, 50%, 75%, 100%), and 

o The existence of any heat advisories, warnings, or alerts the 

previous days. 

f) 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, 

• Estimate workload exertions 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, 

• 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 

job sites, 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.) where 

employees may be performing moderate or more strenuous work during heat 

priority days or working in direct sunlight (or other radiant heat sources) for 

extended periods of time. Observing potential heat-related hazards while 

travelling is particularly important for early intervention and prevention of 

heat-related incidents on construction sites, see Appendix A, Table 2. Where 

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. 

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). 
16 

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 work practices 

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 on heat priority days. CSHOs 

should conduct compliance assistance and document it where heat-related 

hazards do no warrant issuing citations.

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 on. CSHOs should use nationally available tools assembled on the 

CSHO Resources intranet webpage to reconstruct data when appropriate on a 
17 

particular day. 

10. 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 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. 

11. 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, the OTM provides a 

method for calculating WBGT values using historic weather data available on 

the internet. 

12. 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 Cincinnati Technical Center on the use of WBGT instrumentation. 

Contact DEP’s Office of Health Enforcement, for assistance with enforcement 

policy. 

13. 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. 

14. Ensure CSHOs are aware of the annual appropriations exemption list issued 

each year as Appendix A of CPL 02-00-051, Enforcement Exemptions and 

Limitations under the Appropriations Act. Several targeted industries listed in 

Appendix A of the Heat NEP were listed in the March 2022 Appendix A of 

CPL 02-00-051. Section XI.B.4.b of CPL 02-00-051, provides: “Apparent 

safety violations noted during a health inspection of an establishment with 10 

or fewer employees exempted from programmed safety inspections shall not 

be cited or referred for later inspection unless such violations create an 

imminent danger.” Section XI.B.4 notes: “A Compliance Officer can discuss 

non-citable violations during the closing conference and provide information 

relating to On-Site Consultation services.” In addition, if the CSHO 

determines that the “farming operation” exemptions apply, then they should 

immediately close the inspection and take no further action. 

15. 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 
18 

hazards or any other workplace hazards to management. Any complaint of 

alleged retaliation shall be promptly referred to the Regional Whistleblower 

Protection Program. 

16. 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 heatrelated illness(es), specifically focusing on all ambient conditions and 

activities that present heat-related hazards. 

a) 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 

shall 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. 

b) 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. 

• 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 02-00-135. 

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 § 
19 

1904.1) or industry classification (per § 1904.2), it cannot be cited 

for failing to record an injury or illness.

• The Sanitation standards at 29 CFR § 1910.141, 29 CFR § 1915.88, 

29 CFR § 1917.127, 29 CFR § 1918.95, 29 CFR § 1926.51, and 29 

CFR § 1928.110 require employers to provide cool potable water.

• The general construction safety training and education standards for 

construction at 29 CFR § 1926.21 and 29 CFR § 1926.20, requiring a 

Safety and Health Program, as well as frequent and regular safety and 

health inspections may also be applicable. 

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) citation for occupational exposure to the heatrelated hazards, the Regional Office shall follow current National Office 

guidance in this NEP. Heat cases proposing a 5(a)(1) are novel cases and 

must be submitted to the National Office following novel case procedures, 

until otherwise instructed. 

17. Establishments with more than one location engaged in the same or similar 

types of operations, may also have employees who are potentially exposed to 

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 
20 

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 new 

code, “HEATNEP.” The existing heat codes, “N-02-HeatGI, N-02-HeatCON, N02-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, new for this NEP is that technical assistance activities related to 

heat should be captured on the compliance assistance Form 55 using the N-02 

heat codes, above, by industry, which is being added to the Form 55 in the OIS. 

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 

investigated. 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 NEP inspections. Unprogrammed heat 

inspections should also be coded as a Heat NEP inspection. 

Additionally, 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. 

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.

Table 1, below, provides a summary of all heat related OIS codes.
21 

Table 1. List of OIS codes for heat-related inspections and activities

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.

General Duty 

Keyword Heat All heat-related violations and HALs 

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. 

 

G. Outreach.

1. Offices. 

As discussed above, at the beginning of Section XII.D, each Area Office shall

continue conducting outreach programs concerning heat illnesses, including as 

it pertains to new guidance and this 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 
22 

or effective means of reducing or eliminating worker exposure to heatrelated 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 D. 

Targeted Audiences for Outreach. 

• Local employers in high-hazard industries. See also targeted 

industries in Appendix A. 

• Unions, worker centers, COSH groups (Councils for Occupational 

Safety and Health), and other organizations committed to advancing 

protections for underserved worker populations. 

• Local companies and employer associations (e.g., trade associations,

contractor groups, farm bureaus, local chambers of commerce) in 

industries such as, but not limited those in Appendix A. 

• Insurance companies.

• Local professional associations (e.g., local safety councils, local 

agriculture extensions).

• Temporary employment agencies providing employees to targeted 

employers. 

• Local newspapers, TV stations, and trade magazines (these can help 

inform the public and hard-to-reach employers). 

• Local government (e.g., health departments, departments of 

correction, emergency services, construction permitting agencies, and 

departments of transportation). 

• Local suppliers of materials or services, equipment transportation 

companies, such as landscapers, and delivery services. 

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 Campaign, and Safety and Health Topics webpage on Heat
23 

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 Cincinnati Technical Center, the Salt 

Lake Technical Center’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 03-00-003, 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).
Appendix A-1 

Appendix A: Target Industries for the Heat NEP

Programmed inspections under this NEP 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). 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; 2) Elevated number of days away from work (BLS) or high 

numbers of severe cases of heat-related illnesses, as indicated by death or hospitalization, from 

OSHA severe injury reports made by employers; or 3) the highest number of heat-related general 

duty clause 5(a)(1) violations and HALs over a 5 year period (1/1/2017 thru 12/31/2021), or the 

highest number of OSHA heat inspections since 2017. Table 1 lists non-construction industries 

in ListGen, Table 2 lists construction industries, and Table 3 lists non-construction industries not 

found in ListGen. 

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 B2 

Site Selection Deletions. 

Table 1. Non-construction industries that are in ListGen and are likely to have heat-related 

hazards.

2017 4-Digit 

NAICS Code 2017 NAICS Industry Sector Title

1121 Cattle Ranching and Farming

1151 Support Activities for Crop Production

2131 Support Activities for Mining

3118 Bakeries and Tortilla Manufacturing

3211 Sawmills and Wood Preservation

3241 Petroleum and Coal Products Manufacturing

3251 Basic Chemical Manufacturing

3272 Glass and Glass Product Manufacturing

3311 Iron and Steel Mills and Ferroalloy Manufacturing

3314 Nonferrous Metal (except Aluminum) Production and Processing

3315 Foundries

3323 Architectural and Structural Metals Manufacturing

3329 Other Fabricated Metal Product Manufacturing

3361 Motor Vehicle Manufacturing

3362 Motor Vehicle Body and Trailer Manufacturing

3363 Motor Vehicle Parts Manufacturing

3364 Aerospace Product and Parts Manufacturing

3365 Railroad Rolling Stock Manufacturing
Appendix A-2

3366 Ship and Boat Building

3369 Other Transportation Equipment Manufacturing

3371 Household and Institutional Furniture and Kitchen Cabinet Manufacturing

4239 Miscellaneous Durable Goods Merchant Wholesalers

4241 Paper and Paper Product Merchant Wholesalers

4242 Drugs and Druggists’ Sundries Merchant Wholesalers

4243 Apparel, Piece Goods, and Notions Merchant Wholesalers

4244 Grocery and Related Product Merchant Wholesalers

4245 Farm Product Raw Material Merchant Wholesalers

4246 Chemical and Allied Products Merchant Wholesalers

4247 Petroleum and Petroleum Products Merchant Wholesalers

4248 Beer, Wine, and Distilled Alcoholic Beverage Merchant Wholesalers

4249 Miscellaneous Nondurable Goods Merchant Wholesalers

4413 Automotive Parts, Accessories, and Tire Stores

4442 Lawn and Garden Equipment and Supplies Stores

4881 Support Activities for Air Transportation

4882 Support Activities for Rail Transportation

4883 Support Activities for Water Transportation

4884 Support Activities for Road Transportation

4889 Other Support Activities for Transportation

4921 Couriers and Express Delivery Services

4922 Local Messengers and Local Delivery

4931 Warehousing and Storage

5311 Lessors of Real Estate

5617

Services to Buildings and Dwellings (includes landscaping services, tree 

removal and tree trimming services)

5621 Waste Collection

5622 Waste Treatment and Disposal

5629 Remediation and Other Waste Management Services

6231 Nursing Care Facilities (Skilled Nursing Facilities)

7211 Traveler Accommodation

8111 Automotive Repair and Maintenance

8113 Commercial and Industrial Machinery and Equipment (except Automotive 

and Electronic) Repair and Maintenance

8114 Personal and Household Goods 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). 
Appendix A-3 

Table 2. Construction industries that are likely to have heat-related hazards.1

2017 4-Digit 

NAICS Code 2017 NAICS Industry Sector Title

2361 Residential Building Construction

2362 Nonresidential Building Construction

2371 Utility System Construction

2372 Land Subdivision

2373 Highway, Street, and Bridge Construction

2379 Other Heavy and Civil Engineering Construction

2381 Foundation, Structure, and Building Exterior Contractors

2382 Building Equipment Contractors

2383 Building Finishing Contractors

2389 Other Specialty Trade Contractors

For certain industries not included in ListGen alternative sources may be utilized (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 heatrelated hazards.

2017 4-Digit 

NAICS Code 2017 NAICS Industry Sector Title

1112 Vegetable and Melon Farming

1113 Fruit and Tree Nut Farming

2213 Water, Sewage and Other Systems (may be State or local jurisdiction)

4411 Automobile Dealers

4412 Other Motor Vehicle Dealers

4821 Rail Transportation (may be Federal jurisdiction)

4885 Freight Transportation Arrangement

4911 Postal Service

5611 Office Administrative Services

5612 Facilities Support Services

5613 * Employment Services

5614 Business Support Services

5616 Investigation and Security Services

5619 Other Support Services

6117 Educational Support Services

1 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.
Appendix A-4 

7225 Restaurants and Other Eating Places

8112 Electronic and Precision Equipment Repair and Maintenance

9281

National Security and International Affairs (includes Customs and Border 

Patrol, and Transportation Security Administration)

* 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). 

Sources for injury and illness data: 

A. Bureau of Labor Statistics (BLS) Fatality cases 2015-2019 due to exposure to heat 

B. BLS days away from work cases, incidence rates, and median days away from work 2015-

2019 due to exposure to heat 

C. OSHA severe injury reports fatalities and hospitalizations 2018-2020. 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 inspections 2018-Aug 2021, inspections with additional codes, HEATGI, 

HEATCON, HEATMI, HEATAG, or HOTDAYS 

E. OSHA Hazard Alert Letters and 5a1 violation, 2018-Aug 2021, violations with type “Heat” 

General Duty Clause keyword. 
Appendix B-1

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. 
Appendix C-1 

Appendix C: Sample Heat-related AVD

The 5(a)(1) 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, wearing impermeable protective clothing, and 

unacclimatized), 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], employees were exposed to the 

hazard of high ambient 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) and duration of exposure]. [List the high temperatures or 

heat indexes for the days at issue, relative humidity, WGBT measurements and calculations, and 

any aggravating factors such as heavy or bulky clothing, direct sunlight, and level of workload 

activities. Include any NOAA heat advisory or alert 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 stress, heat exhaustion, and 

heat stroke. [Describe any heat-related incidents/illnesses or signs and symptoms that may have 

occurred].

The inspection case file should document any NWS local heat alerts, the reading on the OSHANIOSH 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 hazard of heat-related illness, such as providing 

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. 
Appendix D-1 

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: 

General Controls: 

General controls include training, personal protective equipment (PPE), engineering, work 

practice, and administrative controls, health screening, 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.

1. 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.

d. First aid procedures.

e. Employer's program to address heat-related illnesses.

2. Personal Protective Clothing and Equipment: (CSHOs should recommend the appropriate 

PPE).

a. Hats for work outdoors in the sun.
Appendix D-2 

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.

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.

e. Consider the use of dermal patches for monitoring core temperature to better identify 

when workers need to be removed from the work area.

f. Consider the use of heart rate monitoring to better identify when workers need to be 

removed from the work area. Both sustained (180 bpm minus age) and recovery (120 

bpm after a peak work effort) heart rates are recommended guidelines for limiting heat 

strain.

3. 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.

4. 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.

5. Health Screening and Acclimatization:

a. Allow new workers to get used to hot working environments by using a staggered 

approach over 7-14 days. For example, new workers should begin work with 20% of the 

normal workload and time spent in the hot environment, and then gradually increase the 

time over a 7–14-day period. The same should be done for workers returning from an 

absence of three or more days, starting with 50% of the normal workload and time spent 

in the hot environment, then staging acclimatization over three consecutive days.

Advise workers that certain medications can increase risk of heat stress. These include:

1. Amphetamines – sometimes prescribed for narcolepsy or attention deficit 

hyperactivity disorder (ADHD),

2. Diuretics - water pills,
Appendix D-3 

3. Antihypertensives - blood pressure medication,

4. Anticholinergics - for treatment of chronic obstructive pulmonary disease (COPD), 

and

5. Antihistamines - allergy medications

b. 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.

c. 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.) 

d. 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. 

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.

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 2022 or latest edition. See

ACGIH® website at www.acgih.org/.

5. NOAA/NWS Heat Safety webpage, www.weather.gov/safety/heat. 
Appendix 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 heatrelated 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: 

 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. 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-

00-135, available at: www.osha.gov/enforcement/directives/cpl-02-00-135. 

 The Sanitation standards at 29 CFR § 1910.141, 29 CFR § 1915.88, 29 CFR § 1917.127, 

29 CFR § 1918.95, 29 CFR §1926.51, and 29 CFR § 1928.110 require employers to 

provide potable water. 

 The general construction safety training and education standard for construction at 29 

CFR § 1926.21 and 29 CFR § 1926.20 requiring a Safety and Health Program, as well as 

frequent and regular safety and health inspections. 
Appendix E-2 

 Section 5(a)(1), General Duty Clause of the Occupational Safety and Health Act (OSH 

Act). 

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,

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 2022, or latest edition. See

ACGIH® website at www.acgih.org/.

5. NOAA/NWS Heat Safety webpage, www.weather.gov/safety/heat. 

 

 
Appendix F-1

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 heatrelated illness (with the exception of kidney injury), such as a fall or cut.
Appendix G-1 

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) (see NWS 

webpage, here): 

• Heat Advisory—Take Action! A Heat Advisory is issued within 12 hours of the onset 

of extremely dangerous heat conditions. The general rule of thumb for this Advisory is that 

the maximum heat index temperature is expected to be 100°F or higher for at least 2 days, 

and nighttime air temperatures will not drop below 75°F. 

• Heat Wave—Take Action! A heat wave is forecast by NWS or a local news station. A 

heat wave is when the daily maximum temperature exceeds 95°F or when the daily maximum 

temperature exceeds 90°F and is 9°F or more above the maximum reached on the preceding 

days. 

• Excessive Heat Warning—Take Action! An Excessive Heat Warning is issued within 

12 hours of the onset of extremely dangerous heat conditions. The general rule of thumb for 

this Warning is that the maximum heat index temperature is expected to be 105°F or higher 

for at least 2 days and nighttime air temperatures will not drop below 75°F. 

• Excessive Heat Watches—Be Prepared! Heat watches are issued when conditions are 

favorable for an excessive heat event in the next 24 to 72 hours. A Watch is used when the 

risk of a heat wave has increased but its occurrence and timing is still uncertain. 

• Excessive Heat Outlooks—Be Prepared! Outlooks are issued when the potential exists 

for an excessive heat event in the next 3-7 days. An Outlook provides information to those 

who need considerable lead-time to prepare for the event.
Appendix H-1 

Appendix H: Additional Resources

1. White House Fact Sheet - interagency effort and commitment to workplace safety, climate 

resilience, and environmental justice, September 20, 2021. 

2. Federal Register, 86 FR 59309, 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), October 27, 2021.

State Plans with Heat Standards 

3. California, Heat Illness Prevention webpage, here. 

4. Minnesota, MNOSHA Compliance: Heat Stress webpage, here. 

5. Washington, State Department of Labor & Industries: Be Heat Smart webpage, here. 

Outreach 

6. OSHA Memorandum, Procedures for Local and Regional Emphasis Programs, December 

3, 2014. 

7. OSHA Publication 3905, Whistleblower: Recommended Practices for Anti-Retaliation 

Program, 2017. 

8. OSHA Webpage, Heat Illness Prevention Campaign. 

9. OSHA Webpage, Safety and Health Topic Page: Heat (all webpages also available in 

Spanish). 

10. OSHA Poster, Prevent Heat Illness at Work (English), (Spanish). 

11. OSHA Webpage, COVID-19 Guidance: The Use of Cloth Face Coverings while Working 

Outdoors in Hot and Humid Conditions, September 2020. 

12. OSHA Publications: Heat Illness Prevention Fact Sheets, Wallet Cards, etc. (several also 

available in Spanish). 

13. OSHA-NIOSH Info Sheet, OSHA 3438 – 2011, Protecting Workers from Heat Illness. 

14. CDC, COVID-19 and Cooling Centers. 

15. CDC, What Workers Need to Know about Heat Stress Prevention during the COVID-19 

Pandemic. 

16. U.S. Environmental Protection Agency, Climate Change and Social Vulnerability in the 

United States: A Focus on Six Impacts, EPA 430-R-21-003, September 2021.