Rick Barton, CSP, ARM July 8, 2024 6 min read

OSHA's Heat Injury and Illness Prevention Standard

On July 2, 2024, the U.S. Department of Labor’s (DOL) Occupational Safety and Health Administration (OSHA) announced an unofficial version of the proposed standard to protect workers from heat injury and illness. If finalized, the new standard would apply to all employers conducting indoor and outdoor work in all general industry, construction, maritime, and agricultural sectors where OSHA has jurisdiction, subject to limited exceptions.



According to the Bureau of Labor Statistics, almost 500 workers have died from heat exposure in the United States from 2011-22, and there were nearly 34,000 estimated work-related heat injuries and illnesses resulting in days away from work. If finalized, the proposed rule would be the first federal regulation specifically focused on protecting workers from extreme heat. The official version of the proposed rule will soon be published in the Federal Register.


Employer Obligations

The unofficial version of the proposed rule includes a number of safeguards that employers would be required to implement. For example, the proposed standard includes requirements for:

  • Identifying heat hazards;
  • Developing heat illness and emergency response plans;
  • Providing training to employees and supervisors; and
  • Implementing work practice standards, including rest breaks, access to shade and water, and heat acclimatization for new employees.


Next Steps for Employers

Once published, the proposed rule will undergo a 120-day comment period and subsequent review before it is finalized. If finalized, employers would be required to comply with its requirements within 150 days of publication. Therefore, even if the rule is finalized, employers would not be subject to its requirements until 2025.

Employers may take steps now to prepare to comply with the standard (such as identifying and addressing heat hazards, preparing and updating policies, and preparing training protocols for employees and supervisors). However, the proposed standard is likely to face pushback, so employers should monitor for updates and potential legal challenges.


Additional Resources

Employers may also refer to the following resources for additional information and to learn how to provide comments:

If you have any questions on the standard, please reach out to me or Ken Alderden on the Health and Safety team at Hausmann Group. 


Rick Barton, CSP, ARM

Rick has over 20 years of experience in safety and risk control, working with clients in many industries including Construction, Mining, Trucking, Manufacturing, and Hospitality. He specializes in assessing risk for the clients of Hausmann Group to reduce loss potential. Through safety assessments and loss analysis, Rick develops solutions which include safety management techniques, training, and engineering. Additionally, he has been asked to speak at local and national safety conferences on topics such as "How to Manage Safety on a Jobsite", and "What it takes to be a Safety Leader”. Rick is an Authorized Instructor of OSHA Regulations Construction and General Industry Regulations. He is an active member of the Wisconsin Transportation Builders Association (WTBA), Associated Builders & Contractors (ABC), the Wisconsin chapter of The American Society of Safety Engineers (ASSE), and the Association of General Contractors (AGC). He is also on the Advisory Board of the Safety Studies Department at the University of Wisconsin Whitewater. Rick is an avid boater and enjoys sharing time on the water with family and friends. His children are spread across 4 U.S. states and Japan, so he and his wife are often traveling to visit them. He also has attended more than 150 games in the last 15 years to see his beloved Green Bay Packers play.