Rising Heat Means More Vigilance in Keeping Workers Safe

Extreme heat is on the rise in the United States, challenging the ability of many industries and  employers to keep workers safe, especially in high risk industries with considerable amounts of outdoor work, such as construction.

While we can expect unabated climate change to continue to pose a threat, we do have a playbook to mitigate these risks. Devoting the resources to create a plan, and more importantly, implementing the plan, can quite literally save lives on the jobsite.

The National Oceanic and Atmospheric Association (NOAA) recorded 2025 as the fourth hottest year in the 131-year record for the contiguous United States, with Nevada and Utah eclipsing their previous all-time records. These sustained high temperatures in many states present a multitude of risks, most notably heat exhaustion, or heat stress, and heat stroke, which can be life-threatening.

An increase in heat-related occupational and nonoccupational deaths and injuries is marching along with the rising mercury. According to a study published in JAMA tracking the incidence of heat-related illness from 1999 to 2023, “the number of heat-related deaths increased from 1069 in 1999 to 2325 in 2023, a 117-percent increase in the number of heat-related deaths and a 63-percent increase in the age-adjusted mortality rates.” The lowest number of heat-related deaths in the study period was 311 in 2004, whereas the highest, 2325, was in 2023.

For employers, the OSHA general duty clause, which is the federal standard for protecting employees from heat events, is a baseline requirement – the minimum required by law. Certain states such as California, Nevada, Washington, and Colorado have implemented stricter requirements for heat illness prevention which exceed the federal standards.

Dorothy Doyle
Vice President of Risk Engineering
Liberty Mutual

“The problem is that [OSHA has] been essentially defunded during this administration,” said Michele Hibbert, Senior Vice President of Regulatory Compliance Management at Enlyte.

“A lot of the prevention pieces and the monitoring have been minimized to less onsite review and more documentation review. That’s how they’re being structured to do it. So they lowered their staffing as a result, which means we may miss some violations at the end of the day because of that.”

Despite the hit to administrative staff, the federal government has still been somewhat visible on the issue. In response to the threat and perceived need, the Occupational Safety and Health Administration (OSHA) has extended its National Emphasis Program on Outdoor and Indoor Heat-Related Hazards until April of this year.

These programs usually deliver increases in inspections and attendant citations. According to OSHA, “the program inspects workplaces with the highest exposures to heat-related hazards proactively to prevent workers from suffering injury, illness or death needlessly.”

Since the launch, OSHA has conducted several thousand federal heat-related inspections and issued dozens of citations. This is coupled with a new proposed rule, Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings, for which the public comment period was held last year. The new standard will require employers to specifically control for heat-related risks across industries. However, standards are not a guide for employers beyond the bare minimum.

“An employer in any industry, particularly higher risk industries, needs to start with fully assessing the risk,” said Greg Stefan, SVP of Risk Control for Arch Insurance.

“Do they truly understand the exposures that their employees are facing? Based on that assessment, then determining how is the employer going to implement appropriate controls to manage the risk? The day-to-day efforts must begin with an assessment of their own risks or they often fail. The nuts and bolts of the baseline regulatory requirements are common sense and don’t have to be complicated. The biggest ongoing problem we see is in the execution of their plan and its implementation in the field.”

Next comes training. “Prevention and education is key and so long as you’re incorporating that, I think it decreases your bottom line in general,” said Melissa Martinez, Clinical Operations Manager at Enlyte. Martinez further emphasized the need for the training provided to be reinforced frequently, so that it doesn’t feel like a one-off requirement but rather a culture of safety across the organization.

The highest risk industries, like construction and agriculture, should include the specific measures to address heat stress, which begins with mild symptoms like fatigue, tachycardia, and thirst, and can quickly progress.

“Heat safety is just risk management in real time. If you look at that proposed standard, it’s an 80 and 90-degree heat index threshold. When the index crosses 90 degrees a company’s plan should already be working and in place,” explained Philip Maddox, Technical Director for Workers Compensation at Nationwide.

“For agriculture, at 80 degrees, you should have water stations at least every 300 feet, you’re going to want shade trailers, and to make sure acclimatization is already in place. As you approach 90 degrees, it’s paid breaks, supervisor rounds, EMS directions posted. You could also incorporate tech responses like cooling vests, maybe even wearables for lone workers so you can identify where they are since they won’t be in a group and supervised.”

Maddox explained that it’s similar for another high-risk industry, construction.

Joshua Martinez
Senior Vice President of Construction Safety
Gallagher Bassett Technical Services

“At 80 degrees we want to schedule our activities for the risk, add pop-up canopies, and implement task rotation so the same workers aren’t at risk all the time,” he said. “At 90 degrees, paid breaks and foreman observation, hazard alerts possibly via wearables, PPE and cooling vests.”

These measures are common sense in many cases, but implementation of the plans are the barometers of success to prevent worst case scenarios.

“Proactively and adaptively, the strategies that these companies are taking for this include developing robust heat stress programs aligned with OSHA standards – embedding heat controls in operational procedures is key, and investing in engineering controls,” said Joshua Martinez, Senior Vice President of Construction Safety for Gallagher Bassett Technical Services.

“Those engineering controls include cooling stations, fans, body vests and towels, those help on job sites and promote awareness of heat-related illness symptoms.”

Academic research bears out the necessity for vigilance. According to NSC Injury Facts®, over the past decade, exposure to environmental heat has contributed to an estimated 335 fatalities and more than 20,100 illnesses or injuries resulting in days away from work. A separate study published in BMC Environmental Health found a correlation between heat and all-cause injury, even indoors, past 85 degrees, and “at a heat index of 110°F or higher, the odds [of injury]  increased by 22 percent in states without occupational heat rules.”

Another Workers’ Compensation Research Institute (WCRI) study using claims data and weather data from 2016 to 2021 across 24 states found that the probability of work-related accidents increases by five to six percent when the maximum daily temperature rises above 90°F, relative to a day with temperatures in the 65–70°F range. Even more concerning is correlative findings in the study indicating a stronger effect on traumatic injuries, illustrating the potentially compounding effect of heat stress which leads to a catastrophic fall.

“We have seen examples where heat, combined with pollution (which can be realized as agricultural pollution in areas such as the central valley of California) can lead to claims with HVAC contractors who are working on roofs,” said Matt Zender, Senior Vice President of Workers’ Compensation Product Management at AmTrust Financial, of these cascading effects.

“One opportunity with these types of claims is that education can be extremely productive as the most beneficial approaches follow common sense and are therefore easy to implement.”

For his part, MSIG USA Head of Casualty Jayson Taylor explained that in a tight labor market for these industries, it’s even more important to ensure these risk mitigation techniques are visible and effective.

“People want to go work where they hear good things are going on and they’re treated well,” he said. “And I think that’s part of being treated well  – knowing it’s a good safe environment to work in, and that’s important.”

Standard practices, even advanced PPE and technology, do have some impact on an employer’s bottom line, but as with the establishment of any safety culture, industry should recognize the big picture.

“Efficient operations are safe operations, and efficient operations are a strategic benefit and competitive differentiator, they tend to flow to the bottom line and improve quality of delivery time, employee engagement, profitability, everything,” said Dorothy Doyle, SVP of Risk Engineering at Liberty Mutual.

“Failure to act, failure to keep employees safe can lead to legal liability, yes, but it can also lead to reputational damage, talent retention challenges, so we encourage clients at every junction to view this as a core business priority, not just a checkbox.” &