On April 10, 2026, the Occupational Safety and Health Administration (OSHA) announced an updated Heat National Emphasis Program (NEP) to protect workers from outdoor and indoor heat-related illnesses and injuries. Effective for five years from the date of publication, the revised NEP includes several notable changes from the original 2022 version: an updated list of targeted industries, revised inspection and citation procedures and the elimination of numerical inspection quotas.

Background

In 2022, OSHA launched the original heat NEP, establishing a formal, targeted enforcement initiative to protect workers from heat-related hazards in both outdoor and indoor workplaces. The program directed OSHA inspectors to conduct programmed inspections on any day the National Weather Service issued a heat warning or advisory, focusing on high-hazard industries, including tree care and landscaping services (NAICS 5617). It also required each OSHA region to double its heat-related inspection activity measured against a five-year baseline average.

Since the NEP’s launch, no federal heat injury and illness standard has taken effect. In its absence, the NEP has relied primarily on the General Duty Clause to cite employers for heat-related violations.

Key changes in the 2026 NEP

The updated NEP includes several noteworthy changes:

• Updated Target Industry List: The 2026 NEP updates the high-hazard industry list using OSHA and Bureau of Labor Statistics data from 2022–2025. NAICS 5617 remains designated as a high-hazard industry. Notably, the NEP does not limit heat-related inspections to listed industries, and inspectors may conduct inspections in any sector where heat hazards are present.
• Formalized Inspection and Citation Guidance: The revised NEP includes reorganized appendices that provide updated and formalized guidance that OSHA believes will improve tracking, outreach and enforcement efforts. Notably, it elevated existing inspection and citation guidance into two dedicated appendices.
• Elimination of Numerical Inspection Goal: The 2026 NEP removes the numerical inspection quotas previously imposed on regional offices. In their place, the updated program adopts a condition-based approach: inspections occur when specific heat conditions are met in relevant industries, rather than to satisfy a predetermined count.

Unchanged items in the Heat NEP

The updated NEP retains core elements from the original program. OSHA compliance officers will continue to conduct outreach and expand the scope of any inspection where heat-related hazards are identified on heat priority days. Inspectors will also continue to conduct inspections targeting heat hazards in high-risk industries on days when the National Weather Service issues a heat advisory or warning.

The core elements of an effective heat illness prevention program also remain unchanged: access to cool water and shaded rest areas, scheduled rest breaks, structured acclimatization plans for new or returning employees, training on heat illness symptoms and emergency response and established monitoring and emergency procedures.

OSHA heat rulemaking

OSHA is still in the rulemaking process for a nationwide workplace heat safety standard that would set specific triggers for employers to protect outdoor and certain indoor workers from extreme temperatures and require employers to implement certain measures to protect workers.

Uncertainty remains, however, regarding the Trump administration’s approach to the Biden-era proposal, including potential modifications, the rulemaking timeline, and how compliance requirements may ultimately be structured

Conclusion

Employers should review the updated NEP and assess their work sites against OSHA’s heat illness prevention recommendations. Despite the absence of a federal heat standard, employers remain subject to inspection and citation under the NEP and should anticipate increased OSHA activity as summer approaches. Additionally, several states have implemented their own heat safety requirements that employers may need to follow.

TCIA will continue to monitor OSHA’s actions on heat-related illness and injury prevention and keep members informed of developments.

Bailey Graves is a senior associate at Ulman Public Policy, TCIA’s Washington, D.C.-based advocacy and lobbying partner.