By Dr. Srivathsan V. Raghavan, DrPH

Heat waves, also known as extreme heat events (EHEs), are defined as exceedingly high temperatures that cause significant concern at the worker and population levels, provided an individual is not exposed for more than one day (Hess et al., 2023). Over the years, due to the shifting patterns of temperatures across the globe, focusing more on the United States, EHEs are more prominent and increased in severity, causing a significant degree of morbidity and mortality, including, but not limited to, heat rash, heat cramps, heat syncope, heat exhaustion, and heat stroke (Gibb et al., 2024). Workers who spend more time in the sun during such EHEs are at higher risk of occupational injuries and related illnesses, a risk exacerbated by workers’ socioeconomic status (Kiefer et al., 2016). In addition to all these direct harmful effects on workers’ health, a handful of indirect impacts at the mental and physical levels, such as increased propensity to get injured at work during their regular shift, lack of focus or the inability to concentrate on their daily tasks at work, and a diminished productivity straining both the worker as well as the employer (Cianconi et al., 2020; Ioannou et al., 2022; Spector et al., 2016).

The planet is breaking temperature records at an alarming rate, transforming extreme heat from a seasonal public health concern into an ongoing crisis. High temperatures are no longer merely uncomfortable; they are a critical risk factor driving a surge in emergency department admissions and workplace incidents. To safeguard our communities, public health frameworks must rapidly evolve from reactive emergency response systems to initiative-taking, comprehensive preventative planning (Hess et al., 2023).

The Hidden Danger on the Job: Occupational Heat Stress

The impact of climate change on workforce safety is profound, particularly for individuals in labor-intensive industries like construction, agriculture, and manufacturing.

1. Elevated Baseline Risks: Workers experience a dangerous combination of ambient heat, intense physical exertion, and restrictive personal protective equipment (Gibb et al., 2024).
2. Acute vs. Chronic Harm: Beyond immediate risks like heat exhaustion or fatal heatstroke, prolonged exposure can trigger acute kidney injuries and significantly increase the risk of chronic kidney disease (Gibb et al., 2024).
3. The Acclimatization Gap: New or returning employees face a disproportionately high risk of heat-related illness if they are rushed into full-shift workloads without a gradual increase in exposure (Gibb et al., 2024).

Subtle Systemic Hazards: Moderate heat exposure can impair cognitive function, thereby subtly increasing the rate of standard workplace injuries, such as falls or equipment accidents, across nearly all industries (Gibb et al., 2024).

Gubernot et al. (2014) state that workers in the United States must be afforded a safe workplace that does not jeopardize their health. On average, 33 to 40 U.S. workers die from EHEs annually, and between 2700 and 3389 U.S. workers experience EHE-related injuries that lead to health complications (Bureau of Labor Statistics [BLS], 2023; Occupational Safety and Health Administration [OSHA], n.d.). According to the National Institute for Occupational Safety and Health (NIOSH) (2026), many Doctors of Public Health (DrPHs) believe these estimates are less accurate, as more than 28,000 U.S. workers are injured by EHEs and heat stress (Park et al., 2025). The official decadal averages, as explained by the BLS in the Census of Fatal Occupational Injuries, are 33 U.S. worker fatalities per decade, which falls within the previously mentioned range of 33 to 40 (National Safety Council [NSC], 2025; BLS, 2023). According to OSHA, a 2020 estimate of U.S. worker deaths exceeds by almost 16 (40+16=56) due to heat stress and EHEs (OSHA, n.d.).

OSHA and CDC consider the reason for the underestimation of various U.S. worker fatalities, such as heart attacks, stroke, kidney failure, and other types of morbidities that lead to mortality on the “cause of death” documentation done at the medical level; i.e., when a U.S. worker is brought to a hospital emergency room, for instance, complaining of symptoms associated with a heart attack, the personnel who care for such U.S. workers document the cause of death as “heart attack” rather than looking at the cause of heart attack – exposure to extreme heat events (EHEs) or heat stress, prolonged exposure to high heat during their work shift (NIOSH, 2026; Park et al., 2025). The Occupational Safety and Health Administration (OSHA) is developing a regulation titled Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. In August 2023, the agency formed a Small Business Advocacy Review (SBAR) Panel to gather perspectives from nonprofit groups, small municipal governments, and small businesses serving as small-entity representatives (SERs). Because the proposed safety regulations will dictate hazardous heat protocols across all interior and exterior operations within OSHA’s legal jurisdiction—encompassing general industry, construction, maritime, and agricultural fields—the agency sought feedback from a diverse assortment of commercial fields. The feedback gathered by OSHA involved SERs spanning several different economic sectors, which included:

1. Agriculture and forestry
2. Building material suppliers
3. Commercial kitchens
4. Construction and utilities
5. Fire protection
6. Landscaping, facilities support, maintenance, and repair
7. Manufacturing
8. Material handling, transportation, and warehousing
9. Oil and gas
10. Recreation and amusement
11. Wholesale and retail trade

OSHA established a Small Business Advocacy Review (SBAR) Panel on 08/25/2023 to make sure of the mandates of the Small Business Regulatory Enforcement Fairness Act (SBREFA). OSHA worked in tandem with the Small Business Administration’s (SBA) Office of Advocacy, the Office of Information and Regulatory Affairs (OIRA), and the Office of Management and Budget. The main purpose of this meeting was to get the insights from small entity representatives as to what the current concerns and pitfalls are for U.S. workers with regards to the understanding and enforcement of heat safety regulations and also what recommendations need to be made or modified to enhance more protections from EHEs, heat stress, heat strokes, and other morbidities such as heart attacks, strokes, asthma, acute kidney diseases, to name a few, that are exacerbated in these conditions (OSHA, 2023). Even though small businesses were considered in this meeting, the recommendations to prevent EHE, heat stress, and other heat-related ailments apply to companies of any size and across industries (OSHA, 2023).

Operationalizing Heat Safety: Balancing Regulatory Compliance and Small Entity Flexibility

The regulatory landscape for occupational heat management is undergoing a significant shift. For C-suite executives, public health leaders, and policymakers, understanding these changes is vital for ensuring both worker safety and organizational compliance.

SBAR Panel Recommendations and Administrative Adjustments

To refine its approach, the Occupational Safety and Health Administration integrated feedback from Small Entity Representatives (SERs) during a Small Business Advocacy Review (SBAR) Panel. This consultation led to several key adjustments in administrative guidance (Occupational Safety and Health Administration [OSHA], 2023):

• Performance-Oriented Flexibility: Small entity representatives argued that uniform, national requirements fail to account for regional microclimates. In response, the SBAR panel recommended that OSHA adopt a flexible, performance-oriented framework (OSHA, 2023). This allows organizations to scale and customize compliance protocols based on geographic and climate realities.
• Simplification of Temperature Triggers: Representatives criticized early temperature benchmarks as overly complex and scientifically unsupported. The panel subsequently urged OSHA to clarify these metrics and present more robust supporting data (OSHA, 2023).
• Reduction of Administrative Burden: Stakeholders strongly opposed exhaustive data collection mandates. Consequently, the panel advised OSHA to scale back recordkeeping obligations, omitting the need to track individual rest durations or minor, first-aid-only heat incidents (OSHA, 2023).

The Notice of Proposed Rulemaking (NPRM)

Following the final SBAR report, OSHA advanced its rulemaking process into the Federal Register. On August 30, 2024, the agency issued its formal Notice of Proposed Rulemaking (NPRM) for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings (Heat Injury & Illness Prevention, 2024).

Incorporating previous stakeholder feedback, the proposed framework introduces a dual-indexed tier system designed to trigger escalating hazard interventions (Heat Injury and Illness Prevention, 2024):

1. Initial Heat Trigger (80°F Heat Index)

At a heat index threshold of 80°F, employers must implement foundational preventive measures. These include:

• Providing accessible, cool drinking water.
• Establishing shaded or air-conditioned break zones.
• Enacting structured acclimatization programs for unacclimated workers.
• Offering paid rest breaks as necessary to prevent heat stress.

2. High Heat Trigger (90°F Heat Index)

At a heat index threshold of 90°F, risk-mitigation protocols are significantly escalating. Mandatory requirements include:

• Providing structured, mandatory paid cooling breaks.
• Implementing health monitoring protocols to detect early signs of heat-related illness.
• Distributing widespread hazard alerts to all exposed personnel.

Institutional Frameworks for Systemic Extreme Heat Mitigation

Mitigating the broad public health risks and infrastructural strains caused by severe thermal events requires a coordinated, multi-tiered systemic strategy (Hess et al., 2023). Public health authorities, clinical leaders, and municipal executives must move beyond reactive measures to establish resilient, initiative-taking community frameworks (Hess et al., 2023).

1. Macro-Level Primary Prevention: Long-term risk reduction depends heavily on strategic urban infrastructure capitalization. Municipalities must prioritize large-scale investments that alter the built environment, such as expanding urban forestry to reduce heat islands, deploying high-albedo cool roofing materials, and engineering automated, real-time meteorological warning systems (Hess et al., 2023).
2. Acute Secondary Prevention: Immediate clinical and logistical interventions must activate automatically during peak emergency windows. This operational phase involves establishing geographically accessible climate-controlled shelters, deploying emergency hydration centers in dense urban cores, and instituting legal prohibitions on utility disconnections to ensure uninterrupted home air conditioning for low-income households (Hess et al., 2023).
3. Stratification of High-Risk Demographics: Clinical and social outreach protocols must be explicitly engineered to account for varying baselines of physiological and socioeconomic vulnerability. Interventions must target individuals with chronic cardiorespiratory pathologies, unhoused populations, and historically marginalized groups whose risk is compounded by language or communication barriers (Hess et al., 2023).
4. Adaptive Governance and Policy Iteration: To ensure continuous quality improvement, governing bodies must mandate formal, data-driven debriefs immediately following significant heat crises. These formal audits isolate systemic failures in supply chains or resource allocation, allowing policymakers to iteratively update municipal Heat Action Plans (HAPs) for future events (Hess et al., 2023).

Summary

The accelerating frequency and intensity of extreme heat events (EHEs) across the United States present an urgent crisis for public health and economic stability. Vulnerable labor populations—particularly outdoor laborers and socioeconomically disadvantaged workers—face heightened exposure to severe health hazards, spanning from heat cramps to fatal heat stroke. Beyond these primary medical emergencies, elevated temperatures cause secondary cognitive and physical deficits. These include impaired worker concentration and a spike in workplace accidents, which ultimately degrade operational productivity and place a heavy burden on both personnel and management.

In response to this mounting systemic hazard, the Occupational Safety and Health Administration (OSHA) is spearheading a decisive federal intervention. The agency is actively drafting a comprehensive mandate titled Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. By integrating critical insights from its Small Business Advocacy Review (SBAR) Panel and advancing through the Notice of Proposed Rulemaking (NPRM) phase, OSHA is building the vital institutional infrastructure needed to mitigate extreme heat hazards across the national workforce.

Call-to-Action

The escalating dangers of climate-driven heat stress demand immediate, unified action from every sector of society. OSHA’s impending regulatory framework will fundamentally rewrite the rules of occupational safety, and your leadership is vital to successfully implementing these lifesaving benchmarks.

Here is how you must act today:

1. For Policymakers & Advocates: Closely monitor the OSHA NPRM pipeline and submit rigorous, evidence-based public testimonies to reinforce federal oversight.
2. For Employers & Industry Leaders: Modernize your corporate safety plans immediately by adopting the OSHA SBAR Panel recommendations, prioritizing mandated hydration, cooling areas, and mandatory rest intervals.
3. For Public Health Leaders: Champion OSHA’s mitigation frameworks within municipal networks to bridge the gap between regulatory policy and community health defense.

Dr. Srivathsan Raghavan is a researcher and practitioner dedicated to solving systemic vulnerabilities within industrial infrastructure. As a Doctor of Public Health, he emphasizes Occupational Health and Safety. He bridges translational science and large-scale corporate execution. Dr. Raghavan integrates rigorous academic theory with real-world operations management to analyze and mitigate environmental health threats. His writing provides evidence-based insights into HAZMAT RMP (Hazardous Materials Responsible Management Person) compliance, offering clinical, scientific, and administrative peers a clear view of how operational design directly affects workforce longevity, population health outcomes, and institutional risk.

References:

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Cianconi, P., Betrò, S., & Janiri, L. (2020). The impact of climate change on mental health: A systematic descriptive review. Frontiers in Psychiatry, 11, Article 74. https://doi.org/10.3389/fpsyt.2020.00074

Gibb, K., Beckman, S., Vergara, X. P., Heinzerling, A., & Harrison, R. (2024). Extreme heat and occupational health risks. Annual Review of Public Health, 45(1), 165–183. doi.org.

Gubernot, D. M., Anderson, G. B., & Hunting, K. L. (2014). The epidemiology of occupational heat exposure in the United States: a review of the literature and assessment of research needs in a changing climate. International journal of biometeorology, 58(8), 1779-1788.

Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings, 89 Fed. Reg. 70698 (proposed August 30, 2024) (to be codified at 29 C.F.R. pts. 1910, 1915, 1917, 1918, and 1926). federalregister.gov.

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National Institute for Occupational Safety and Health. (2026). Heat stress and workers. Centers for Disease Control and Prevention. https://www.cdc.gov/niosh/heat-stress/about/index.html

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Occupational Safety and Health Administration. (2023). Heat injury and illness SBREFA. U.S. Department of Labor. https://www.osha.gov/heat/sbrefa

Occupational Safety and Health Administration. (2023). Report of the Small Business Advocacy Review Panel on OSHA’s potential standard for heat injury and illness prevention in outdoor and indoor work settings. U.S. Department of Labor. osha.gov.

Park, R. J., Pankratz, N., & Behrer, A. P. (2025). A nationwide analysis of heat and workplace injuries in the United States. Environmental Health, 24(1), 112–125. https://pmc.ncbi.nlm.nih.gov/articles/PMC12498468/.

Spector, J. T., Krenz, J., Blank, K. N., & Flunker, M. (2016). A case-crossover study of heat exposure and injury risk in agricultural workers. PLOS ONE, 11(10), Article e0164498. doi.org.