OSHA Revises Heat Stress NEP with New Enforcement Appendices

OSHA revised and extended its National Emphasis Program on heat stress. The update adds Appendix I, an 11-item checklist for evaluating heat programs, and Appendix J, a citation guide for heat hazards under the General Duty Clause.

Enforcement Shift

According to Safety+Health Magazine, the changes move the program from awareness and data collection toward enforcement. Inspectors now have defined tools to issue citations more quickly during inspections. The NEP directs officers to inquire about heat safety programs in any inspection when the heat index reaches 80°F or higher.

Program Evaluation Criteria

Appendix I outlines specific elements inspectors will review to determine program effectiveness. Appendix J provides guidance on what constitutes a heat hazard and how to build a case. Employers can align their programs with these appendices to prepare for audits.

Required Practices

The NEP specifies heat index monitoring using tools such as the OSHA-NIOSH Heat Safety Tool App. Acclimatization procedures must include gradual workload increases, more frequent breaks, and documented monitoring of new or returning workers, with reference to American Conference of Governmental Industrial Hygienists guidance. Training must cover heat illness signs, symptom reporting, first aid, emergency contacts, and prevention measures. Employers must also designate a heat safety representative to manage the program.

According to Safety+Health Magazine, visible water and shade stations are emphasized because officers may initiate reviews on heat priority days when such measures are absent from view.