OSHA issued an updated National Emphasis Program for outdoor and indoor heat-related hazards on April 10, 2026, two days after the previous version expired. The revised NEP is effective immediately and will remain in place for five years, through April 10, 2031.
Why the Timing Matters
OSHA first launched the Heat NEP in April 2022 for a three-year term. It was extended by one year in January 2025, pushing the expiration to April 8, 2026. This latest update replaces that program entirely rather than extending it again, and it extends the emphasis period from three years to five.
What Changed in the 2026 Version
The updated NEP uses OSHA and Bureau of Labor Statistics data from 2022 through 2025to set a target list of 55 high-risk industries for inspection priority.
The list is smaller than the one it replaces. OSHA retained 33 industries from the 2022 program, added 22, and removed 46, cutting the target list from roughly 79 industries to 55. The additions include plastic product manufacturing, metalworking machinery manufacturing, general freight trucking, animal slaughtering and processing, and electric power generation, transmission, and distribution.
Construction and agriculture were covered under the original 2022 program and remain on the list.
The revised program also drops the numerical inspection goal that shaped the original NEP, which is a directive for each regional office to increase on-site heat inspections 100 percent over the 2017–2022 baseline, and adds two appendices: Appendix I, on evaluating an employer's heat program, and Appendix J, on citation guidance.
The Scale of the Enforcement Shift
Heat-related inspections made up about 0.5 percent of all federal OSHA inspections in the five years before the original 2022 NEP. That figure rose to roughly 6 percent over the program's first run, and annual heat inspections grew from around 200 a year to about 2,400.
Between April 2022 and December 2024, OSHA conducted close to 7,000 heat-related inspections, issued 1,392 hazard alert letters, and issued 60 citations tied to heat hazards under the OSH Act.
Why This Runs Ahead of a Final Rule
OSHA proposed a national heat injury and illness prevention rule in August 2024. That rulemaking remains unfinalized, but it is moving: under the Department of Labor's regulatory plan, OSHA intends to issue a supplemental notice of proposed rulemaking in December 2026.
In the meantime, OSHA has relied primarily on the General Duty Clause to cite employers for heat-related hazards, since no dedicated federal heat standard currently exists.
OSHA's own directive puts the toll at an average of 3,793 days away, restricted, or transferred (DART) cases and 48 fatalities per year from environmental heat exposure between 2021 and 2024, which is why the agency chose to keep an enforcement program in place rather than wait for the rule to clear review.
Employers in any of the 55 targeted industries can use this window to get ahead of an inspection by documenting their heat program now, since a documented risk register and audit trail gives an inspector exactly what OSHA's new citation guidance says it will be looking for.
References: U.S. Department of Labor, news release | Littler, "OSHA Updates and Extends its Heat Program for Five More Years" | Ogletree, "OSHA Revives National Emphasis Program for Heat-Related Illness"
Mehreen Iqbal
Started with a Bachelors in Microbiology, then a Masters in Public Health; Currently a Workplace Safety Expert.