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A Proactive Response to OSHA's Proposed Heat Rule
September 9, 2024
Jill Hyman Kaplan, Esq. and Brandon P. Matsnev, Esq.
The Legal Intelligencer
On Aug. 30, 2024, OSHA issued a notice or proposed rulemaking (NPRM or proposed rule) covering hazardous heat in the indoor and outdoor work environments. Several steps remain in the regulatory process until a final, enforceable rule, but employers should be proactive in reviewing it, understanding its requirements, and preparing (or shoring up) a workplace heat safety program. A proactive approach on heat should also have near-term benefits with respect to OSHA enforcement. Over the last several years, OSHA has been actively citing employers for heat-related issues— even without a specific regulation on hazardous heat—and those citations have relied upon key concepts from the proposed rule.
