The standard is stuck. The enforcement isn’t. OSHA renewed its heat National Emphasis Program for another five years in April, and inspections have jumped from roughly 200 a year to about 2,400, now about 6% of everything the agency does. Contractors heading into summer 2026 face heat scrutiny whether or not a final rule ever lands.
That gap matters because the federal heat standard is still just a proposal with no timeline. Employers who plan around a coming rule are planning around the wrong thing. What’s real is the inspection targeting 55 high-risk industries off 2022–2025 injury data, and construction sits near the top.
The toll behind the rule
The case for it is grim. Between 1992 and 2022, environmental heat killed 986 workers on the job, 334 of them in construction, a sector that’s about 6% of the workforce but roughly a third of heat deaths. Those are the numbers driving the enforcement even as the rulemaking stalls.
What inspectors actually ask for
The checklist is concrete. A written heat illness prevention plan. Acclimatization procedures for new and returning crews. Documented supervisor and worker training. Records of temperature or heat-index monitoring. And evidence that water and rest breaks happen on the jobsite, not just on the poster in the trailer. It pairs with a broader push on jobsite risk we tracked in OSHA’s 2026 agenda. The paperwork is the easy part. Proving the breaks actually happened is where citations get written.
Guidance: OSHA Heat Exposure.