5 Ways to Reduce Heat Illness Risk Before Summer Peaks  

Recent headlines around the expiration of OSHA’s Heat Illness National Emphasis Program (NEP) have created some confusion. But from a compliance standpoint, very little has actually changed. 

OSHA’s Heat Illness National Emphasis Program officially expired on April 8, 2026. But it’s important to understand what that really means. 

The NEP was never a formal rule or standard. It didn’t create new legal requirements for employers. Instead, it directed OSHA to prioritize inspections in high-risk industries and conditions and provided guidance to compliance officers on what to look for. 

Even without the NEP in place: 

• OSHA can still cite heat hazards under the General Duty Clause  
• Inspections can still occur, especially during high-heat conditions  
• Employer obligations to provide a safe workplace remain unchanged  

In other words, enforcement hasn’t gone away. The same expectations still apply. 

As temperatures rise, employers still face growing pressure to prepare employees and supervisors for heat-related risks. 

Each year, about 28,000 workplace injuries are linked to extreme heat, according to researchers at George Washington University and Harvard. Many of them incidents are preventable with the right awareness and response. 

Heat illness incidents often develop gradually through routine decisions employees and supervisors make under pressure to stay productive, meet deadlines, or push through discomfort. 

5 Steps Employers Should Prioritize Before Summer Heat Peaks 

With summer temperatures approaching, employers should focus on practical steps that reduce heat illness risk before incidents occur. 

1. Identify Where Heat Risk Actually Happens 

Heat risk isn’t limited to outdoor jobs. 

Warehouses, manufacturing floors, kitchens, retail loading zones, hotel laundry operations, and delivery vehicles can all expose employees to dangerous temperatures, especially during peak summer months. 

On manufacturing floors, machinery, PPE, and limited airflow can intensify heat exposure. Delivery drivers move in and out of hot vehicles throughout the day. Retail employees working in garden centers, curbside pickup, or outdoor loading areas may spend hours exposed to extreme heat without realizing how quickly dehydration builds. 

In construction and outdoor industries, the risks can become even more visible. A roofing crew pushes through the last hour of a project during a heat advisory. One worker becomes disoriented but avoids speaking up because the team is already behind schedule. 

These are the moments where heat illness risk often begins. 

2. Train Supervisors to Recognize Early Warning Signs 

Supervisors are often the first line of defense when heat-related symptoms appear. But without training, early warning signs can be missed or mistaken for normal fatigue. 

An employee slows down, becomes dizzy, appears confused, or grows irritable during a shift. A supervisor assumes they simply need a break or more motivation to finish the job. 

By the time symptoms become obvious, the situation may already be serious. 

Training supervisors to recognize symptoms early and respond quickly can help prevent situations from escalating into medical emergencies. 

3. Pay Close Attention to New and Returning Workers 

OSHA has consistently emphasized that new and returning workers are often at greater risk as their bodies adjust to working in higher temperatures. 

That’s especially important for organizations managing seasonal hiring, temporary workers, or employees returning after time away from physically demanding work. 

Heat safety training should help employees understand: 

• How heat illness develops,  
• When to report symptoms,  
• And when it’s appropriate to stop work and seek help.  

Organizations should also review whether acclimatization procedures are clearly communicated and consistently followed during high-heat periods. 

4. Reinforce Heat Safety Throughout the Summer 

Heat safety can’t be treated as a one-time conversation at the start of the season. 

As temperatures rise, employees and supervisors need ongoing reminders that reinforce safe decisions in real-world situations. 

This is where short reinforcement tools can play an important role. Brief, scenario-based reminders help employees recognize symptoms faster, respond appropriately under pressure, and keep key safety behaviors top of mind throughout the summer. 

Consistent reinforcement is especially valuable in fast-moving work environments where employees are balancing productivity, staffing pressures, and physically demanding work. 

5. Align Policies, Training, and Response Procedures 

While there’s still no finalized federal heat illness prevention standard, OSHA has made its direction clear. Employers should anticipate continued focus on: 

• Access to water, rest, and shade,  
• Acclimatization for new or returning workers,  
• Supervisor readiness,  
• Clear response procedures for heat illness incidents.  

Seven states, including CA, CO, MD, MN, NV OR, and WA, currently have workplace heat illness prevention standards, and at least six additional states are moving legislation forward. 

At the same time, penalties remain significant: 

• Up to $16,550 per violation for serious hazards  
• Up to $165,514 per violation for willful or repeat violations  

Because citations are issued per violation, a single incident can quickly escalate into substantial exposure. 

About the Author 

Bailey Whitsitt serves as Compliance Counsel at Traliant, where she oversees regulations, solutions and topics related to workplace violence, bystander intervention, labor and employment law governance. She is a graduate from Iowa State University and Loyola University Chicago School of Law and has practiced at various firms, including Taft Stettinius & Hollister and Clark Hill Law.