What’s Concerning about OSHA’s New Heat Emphasis Program

Is OSHA Going to Show Up Unannounced?

With summer in full effect, OSHA is ramping up investigations into heat-related illnesses in the workplace. This effort is in line with the new National Emphasis Program (NEP) on Outdoor and Indoor Heat-Related Hazards that took effect on April 8th. The program is designed to keep employees safe from heat-related illnesses and injuries and failure to comply could cost your business tens of thousands of dollars in unexpected fines.

New National Emphasis Program

Under the NEP, OSHA will increase compliance outreach efforts on “heat priority days,” -- days when the heat index is 80 degrees Fahrenheit or higher. Basically, any day in the summer. On such days, OSHA has the authority to conduct unannounced, on-site inspections of your business’s Heat Illness Prevention program. This investigation could include questions around training, a written Heat Illness Prevention Plan (HIPP) policy, heat illness prevention safety measures in place, worker acclimatization, and more.


Your Entire Safety Program Could Be Under Scrutiny

However, the concern to the business owner does not stop with a Heat Illness Prevention Program. While OSHA has this open invitation to walk on to your site to investigate heat-related safety efforts, they can also investigate anything in plain sight. That means if they identify a hazard with a scaffold, equipment usage, or Personal Protective Equipment (PPE), they could issue a citation. If OSHA recognizes an unsafe practice, they can request to see training plans and documentation, specific policies, and JSAs.

So, for the next several months, businesses all around the US should expect increased scrutiny over all aspects of their safety programs and failing to have a plan in place could prove costly.

The Cost of Not Complying

Since this new effort is not yet a Federal Standard, any citations of this NEP will be issued under The OSHA General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act which requires employers to provide employees a workplace that is free from recognized hazards that are causing or likely to cause death or serious physical harm. OSHA citations under this clause can carry fines up to $14,502 per violation of Section 5(a)(1).

Beat the Heat & Citations – Have a Plan

When it comes to safety, knowing “what you need” can be a challenge. Every company’s hazards and risk profile is unique to the work they do and where they do it. When it comes to heat, we recommend having a specific Heat Illness Prevention Program in place. For advice on how to put together this program, you can download our guide here. If you have greater concerns about your overarching safety program and what else OSHA may investigate upon visiting your jobsite, consider a free Hazard Analysis with a Safety Plus safety expert.



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