ASAP
OSHA Updates and Extends its Heat Program for Five More Years
While OSHA has not yet finalized its pending heat regulation, the agency has signaled that targeting heat-related hazards will nonetheless remain an enforcement priority. On April 10, 2026, OSHA issued an updated National Emphasis Program (NEP) for outdoor and indoor heat-related hazards: CPL 03-00-024 NEP - Outdoor and Indoor Heat-Related Hazards. The previous NEP, first published in 2022 and extended in 2025 for an additional year, expired on April 8, 2026.
According to an OSHA press release, the updated Heat NEP will “direct agency resources where they can make the biggest impact—focusing inspections and outreach in industries and workplaces where heat stress risks are most likely to occur.” Specifically, the NEP sets forth a “target list” of 55 “high-hazard” industries. While 33 of these industries were part of the previous NEP, OSHA has added 22 new industries to its list. New targeted industries include, but are not limited to, plastic product manufacturing, metalworking machinery manufacturing, department stores, general freight trucking, animal slaughtering/processing, and electric power generation/transmission/distribution. Per the NEP, OSHA will create a list of employer establishments based on its target list and “shall” conduct random heat inspections on any day that the National Weather Service has announced a heat warning or advisory for the local area.
In addition, the NEP directs OSHA to focus on heat-related hazards even during non-heat-related inspections in the following scenarios:
- For inspections opened for other purposes that occur on “heat priority days,” the NEP states that Certified Safety and Health Officials (CSHOs) should inquire about the existence of a heat-related hazard prevention program. “Heat priority days” are defined by the NEP as days where the heat index is 80 degrees or more.
- In addition, the NEP states that OSHA “shall” expand non-heat inspections to include an inspection of hazardous heat conditions where there is evidence that such hazards are present, such as information from OSHA 300/301 log entries, employee statements, or plain view observations.
The updated NEP also removes outdated background information, updates internal document links to other heat-related resources, removes a previous inspection goal, and adds two revised appendices (one for evaluating heat programs and another for citation guidance).
The 2026 updated NEP is effective immediately and will be in place for five years (through 2031). Although there is no federal heat plan, OSHA can still issue heat citations under the OSH Act’s general duty clause, and many states are adopting their own heat rules. With summer approaching, or for geographic areas already experiencing warmer temperatures, employers should be prepared to address heat-related hazards and consider consulting experienced workplace safety counsel on ways to do so.