Indoor Heat

By Beeta B. Lashkari and Andrea Chavez

As record-breaking temperatures continue to impact communities and workplaces across the country, heat illness prevention remains a top priority for regulators at both the federal and state levels. Below is an update on recent legislative and regulatory developments aimed at protecting workers from the hazards of extreme heat.

Federal OSHA: Rulemaking Hearing and Legislation

On the Fed/OSHA level, the current debate revolves around, if a final rule is promulgated within the next 3.5 years, whether that standard should be more prescriptive, or more performance-oriented, than the current proposed rule as drafted. The two updates below, regarding the rulemaking hearing, and new legislation that has recently been introduced, reflect this tension.

Rulemaking Hearing: As we just reported, the public rulemaking hearing on Fed/OSHA’s proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings rule recently concluded on July 2, 2025, after commencing on June 16, 2025. Continue reading →

By Eric J. Conn and Beeta B. Lashkari

On July 2, 2024, OSHA revealed an unofficial version of its Notice of Proposed Rulemaking (NPRM) for an Indoor and Outdoor Heat Illness Prevention Rule. For unknown reasons, OSHA has not yet published the official NPRM in the Federal Register, but it is expected any day. Interested stakeholders will have a 120-day period to submit public comments to OSHA after the NPRM is published, which will make comments due likely sometime in December 2024.

CMC’s Employers Heat Illness Prevention Rulemaking Coalition has had a prominent seat at the table from the get-go to advocate for the most reasonable possible standard. Read our article here for more information about our advocacy to OSHA during earlier stages of OSHA’s Heat Illness Rulemaking.

This Alert provides a detailed summary of what is in OSHA’s proposed Indoor and Outdoor Heat Illness Prevention Rule and how to ensure your industry’s interest are represented during the final phase of OSHA’s Heat Illness Rulemaking.