Change to Inspection Guidance for Heat Hazards

What happened: OSHA April 10 updated its National Emphasis Program (NEP) on outdoor and indoor heat-related hazards, which targets enforcement for high-risk industries, including transportation construction.

To be clear, the NEP is not a regulation and does not create new requirements. It is an existing enforcement directive that guides inspection priorities, allowing OSHA to inspect without a complaint.

Originally issued in 2022, this revised program uses recent data to focus inspections and includes updated guidance on how the agency evaluates and cites heat hazards.

What this means: For contractors, this means heat exposure may be reviewed as a standalone hazard, not just during complaint-based or general inspections.

OSHA can conduct targeted inspections specifically for heat hazards, particularly on days with heat advisories or warnings. Inspectors may also expand the scope of any on-site inspection if heat risks are observed.

What’s next: The updates are effective immediately and will remain in place for five years. ARTBA will monitor how OSHA implements the program.

No updates have been provided on the separate heat standard rule proposed by OSHA in 2024.

Contact Brad Sant or Prianka Sharma for more information.