Employers in the United States should prepare for another hotter-than-average summer in 2026.[PM1]
AccuWeather forecasts (opens a new window) that nearly the entire contiguous United States will sweat out average temperatures this year that exceed historical averages from June through [AP2] August. The Pacific Northwest is expected to bear the brunt of the summer, with wide swaths of Washington, Oregon, and Idaho forecast to have average temperatures 4 [AP3] degrees or more above historical norms, according to AccuWeather.
This forecast should grab the attention of all employers, but particularly those in industries where employees work primarily outside, like construction. The summer months, particularly in recent years, have brought heat waves that can endanger workers if employers neglect precautions.
Heat-related deaths have increased by more than 50% since 2000, according to the Yale School of Public Health (opens a new window). Deaths create obvious liability for workplaces where fatal and preventable heat stroke occurs, but heat-related injuries can also lead to expensive workers’ compensation claims.
Moreover, the Occupational Safety and Health Administration (OSHA) updated its National Emphasis Program (NEP) (opens a new window) on outdoor and indoor heat-related hazards this year. OSHA’s revisions signal renewed focus on inspections and enforcement on job sites with high heat-stress risks.
In addition to construction, OSHA has identified other industries with heightened heat risks. Those include livestock farming and processing, foundries, transportation, and manufacturing.
Worksites should have heat illness prevention plans to show inspectors. Heat programs, in general, should:
Specify who is responsible for observing heat safety guidelines.
List measures to help new and temporary workers acclimate to the heat.
Instruct managers and workers on how to recognize signs of heat stress and measures they can take to help someone who is afflicted.
Include policies for altering work schedules and processes during heat advisories.
It’s also helpful for organizations to understand what OSHA inspectors will be looking for, according to the updated NEP, when they show up and review heat illness plans.
Is the heat program effectively communicated to employees, and is it understood?
Do managers monitor temperatures and exertions?
Is enough clean, cool water easily available on site?
Are there scheduled rest breaks, along with additional breaks for hydration?
Do workers have access to shaded areas?
Do managers limit heat exposure by changing work times, adjusting workloads, and rotating employees and tasks?
Are workers trained to recognize the symptoms of heat stroke, how to administer first aid, and how to contact emergency personnel?
Do designated safety representatives at the work site properly manage the heat program?
OSHA’s updated NEP does not establish a federal heat standard. However, employers in states without a specific heat law are still exposed under OSHA's General Duty Clause, which requires employers to protect workers from recognized hazards, including heat, even absent from a specific standard.
California, Oregon, Washington, Maryland, Nevada, Minnesota, and Colorado have already implemented state-specific enforceable heat illness standards. In April, Virginia’s governor signed legislation that will require employers to develop heat illness prevention plans for indoor and outdoor workers starting in 2028.
The California 2024 enacted new workplace heat illness prevention regulations require, among other things, additional breaks, access to shade, and fresh drinking water to outdoor workers when temperatures exceed 80 degrees (82 degrees for indoor workers), with additional protections required at higher temperatures.
Check with a member of your Lockton Risk Control services team for guidance on understanding local regulations and developing a heat illness prevention plan.