OSHA Updates Workplace Heat Directive

OSHA’s revised heat hazards directive identifies 55 high-risk industries and now includes plastic product manufacturing (NAICS Code – 3261), and prioritizes inspections during complaints, heat index days above 80°F, or heat-related weather alerts. Inspectors will review heat illness records, interview workers, and assess exposure risks, water, rest, shade, PPE, and controls. There are heat safety guidance and tools made available by OSHA and NIOSH. Employers should maintain a clear heat program covering monitoring, hydration, breaks, acclimatization, training, and emergency response.

In an April 10^th 2026 revised National Emphasis Program – Outdoor and Indoor Heat-Related Hazards directive, Occupational Safety and Health Administration (OSHA) identified 55 “high hazard” industries for heat related injuries, including NAICS code 3261 – Plastic Product Manufacturing. The directive emphasizes workplace inspections and prioritizes inspections to occur under the following circumstances: 

• When OSHA has received information about heat-related hazards at an employer. 

• When the heat index is 80 degrees or above – “heat priority days” 

• When the National Weather Service announces heat warning or advisory in an area. 

OSHA inspections will be checking that: 

•  employers have afforded employees’ adequate water, shade, and rest opportunities 

• that employers have also taken steps to reduce heat exposure 

• Provided adequate PPE for heat 

OSHA uses the National Weather Service’s Heat Index, sometimes referred to as the apparent temperature, for their guidance. The Heat Index, measured in degrees Fahrenheit, is a measure of how hot it really feels when relative humidity is factored in with actual temperature. OSHA, Dept. Of Labor (DOL), Centers for Disease Control (CDC), and National Institute for Occupational Safety and Health (NIOSH) have a free Heat Safety Tool app available for both iPhones and Android devices that assists in measurement of Heat Index as well as providing risk level indicators and reminders for protective measures. 

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 (2016), 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). 

If your plant is visited by a Certified Safety and Health Official (CSHO) during a heat-related inspection, you should be advised that they shall: 

• Review OSHA 300 Logs and 301 Incident Reports for any entries indicating heat-related illness(es) 

• Review any records of heat-related emergency room visits and/or ambulance transport, even if hospitalization did not occur, [this may require the use of Medical Access Order], 

• Interview workers for symptoms of headache, dizziness, fainting, dehydration, or other conditions that may indicate heat related illness, including both new employees and any employees who have recently returned to work. 

• 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;  

• Workload exertions, which can be estimated 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; and  

• Duration of exposure during which a worker is continuously or repeatedly performing moderate to strenuous activities. 

• CSHOs can and will conduct NEP inspections if your plant is already on the list for a scheduled NEP program inspection. 

If you have not already, any plant with NAICS code 3261 – Plastic Product Manufacturing can expect their OSHA Regional Office or Area Office to conduct outreach programs concerning heat illness. It is recommended that you develop or review a Heat Program. An example of what OSHA will look for is a program that addresses the below concerns: 

1. Is there a heat program (written or verbal) that is effectively communicated to employees?  

2. How did the employer monitor ambient temperature(s) and levels of work exertion at the worksite?  

3. Were there sufficient amounts of cool water easily accessible to the employees?  

4. Did the employer allow additional breaks for hydration?  

5. Were there scheduled rest breaks?  

6. Was there access to a shaded area? 

7.  Did the employer provide time for acclimatization of new and returning workers?  

8. Were administrative controls used (earlier start times, workload adjustments, and employee/job rotation) to limit heat exposures?  

9. 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? 

10.  Do employees and supervisors understand the heat program?  

11. Is the heat program properly implemented and managed by a designated heat safety representative? 

If your plant is in operation in California, please be advised that the state of California’s Department of Industrial Relations has its own set of rules governing Heat Illness prevention. Please refer to the Cal/Osha Heat Illness Prevention Guidance and Resources webpage for additional information. 

For any additional questions, please contact Brad Lavelle.