What are the new OSHA heat requirements?

I. The Problem We Pretended Was Weather

For years, heat sat in an odd category: dangerous, but never dangerous enough to regulate with specificity. Employers checked boxes—water, rest, shade—while the rest was left to culture and hope.

But the climate shifted faster than the policies that governed it. On a single summer afternoon in Houston last year, the heat index hit 108°F outside. Inside a nearby warehouse, an EHS leader named Belinda watched the temperature climb above 95°F before noon. Humidity pooled in the low bays. Airflow lagged. Fans barely mattered. Workers moved slower, not because they wanted to, but because their bodies were negotiating with physics.

None of this qualifies as unusual anymore. That’s the point. And that’s why OSHA is acting.

II. The Data That Forced OSHA’s Hand

The numbers that underlie this rule are not abstract.

• $100B+: estimated annual productivity losses in the U.S. due to heat.

• 65+ days: number of triple-digit heat-index days in Houston last summer.

• 30–50%: productivity reduction reported by EHS leaders on high-heat days.

• 70%: share of heat fatalities occurring in a worker’s first week.

• 0 minutes: cooling effect provided by fans once ambient temperatures exceed roughly 95°F with high humidity.

OSHA’s own fatality investigations show a pattern: workers rarely collapse at 110°F. Most severe incidents happen when heat index sits between 80 and 95°F, especially when humidity climbs or when a worker is early in their acclimatization period.

Indoor environments amplify this. Warehouses hold heat like a slow exhale; manufacturing pits act as heat sinks; HVAC systems rarely reach the corners where people actually work. Heat, in other words, is not an inconvenience. It is a system. It follows rules. And those rules are indifferent to tradition.

III. What OSHA Is Actually Proposing

At the core of the proposed standard are two thresholds:

• 80°F heat index: employers must begin baseline heat protections

• 90°F heat index: employers must escalate protections

Everything else flows from these thresholds. When the heat enters those ranges, employers must have already:

• mapped where heat accumulates

• trained supervisors

• provided accessible water

• identified cooldown locations

• implemented a structured acclimatization process

• established an ongoing monitoring system

And this applies indoors. A stamping plant, warehouse, refinery, packaging center, or distribution hub must comply just as a roofing crew would.

This is not OSHA becoming overzealous. It’s OSHA catching up to the physiology of work.

IV. How the Rule Intersects With Reality

Belinda’s operation in Houston provides a clear lens into how the rule plays out on the ground.

By early afternoon, her crews are following rest–work cycles that mirror OSHA’s proposed model almost exactly. When heat index climbs above 95°F indoors, productivity doesn’t just slide; it falls off a cliff. Her team manages it by pacing work, rotating tasks, and using a single cooled recovery room—a room that becomes progressively less effective as the day wears on, simply because it's too far away.

She described something OSHA’s documents only hint at: heat is spatial, not general. Two workers standing fifty feet apart can be in radically different risk zones. Regulations that treat a warehouse as one uniform environment miss the nuance; this one doesn’t. The new standard expects employers to understand their space with that level of granularity.

She also described the friction created by PPE, especially FR gear. It traps heat. Workers feel pressure to choose between protection and comfort. And cooling vests on the market have so far failed them—too heavy, too hot, too short-lived. OSHA cannot fix those equipment gaps, but the rule will make them impossible to ignore.

V. The Tactical Heart of Compliance

A standard is only useful if it translates into daily decisions. This one does.

1. Map the heat

Every facility has hotspots. OSHA expects employers to identify them, not guess.

2. Monitor continuously

It isn’t enough to take a 9 a.m. reading. Heat risk trails humidity and time. Monitoring must follow the shift.

3. Build cooldowns that work

A distant breakroom is a productivity trap. Cooldown zones must be close enough to reduce downtime.

4. Train supervisors for subtle signs

Heat illness doesn’t begin with collapse. It begins with slowed decision-making, irritability, clumsiness—signs most supervisors were never trained to catch.

5. Treat acclimatization as a program

No new worker should be thrown into a 95°F zone on day one. It’s unsafe and, under the new rule, noncompliant.

6. Document and follow through

OSHA will not care what is written if it does not shape the day. Enforcement will focus on practice.

VI. The Strategic Moment This Creates

Heat has already become one of the most expensive, under-discussed operational forces in the American economy. This rule doesn’t invent that reality; it acknowledges it.

For companies ready to adapt, this is an opportunity rather than a constraint. The organizations I’ve seen succeed in heat-heavy environments share three traits:

1. They design around physiology, not tradition.

2. They invest in tools—cooling, monitoring, workflow—that stabilize output under heat stress.

3. They treat heat planning as part of operations, not compliance.

Those companies lose fewer hours, make fewer emergency calls, and retain more workers over the summer months. Safety becomes a competitive advantage because stability is a competitive advantage.

VII. Why This Will Matter Long Before It Becomes Law

Most OSHA standards take months or years to finalize. But heat doesn’t wait for rulemaking. By June, the conditions that prompted the rule will already be here.

Companies that begin preparing now—mapping heat zones, structuring cooldowns, trialing new cooling technologies, piloting improved PPE—will absorb far fewer losses when temperatures climb. They will also find themselves ahead of a regulatory curve that is not merely likely, but inevitable.

The proposed heat standard is a sober recognition of something the workforce has known for years: heat shapes the way America works. The question is not whether we respond, but how quickly.

Read here if you're interesting in learning about breakthroughs in cooling technology