Good morning. If you’re running crews on roofs, in attics, in unconditioned mechanical rooms, or in a truck through the peak of summer, here’s a wrinkle worth knowing: the federal enforcement program that hovered over you for four years lapsed back in April — right as heat season was ramping up. That’s not the win it sounds like. Here’s what actually changed — and what still bites.
Top story — The heat enforcement program expired, but the risk didn’t
OSHA’s Heat National Emphasis Program — the directive that let inspectors show up unannounced whenever the heat index hit 80°F — expired on April 8, 2026, with no public sign the agency plans to extend or replace it. Launched in April 2022, that program drove roughly 7,000 heat inspections between April 2022 and December 2024 — up from about 200 a year before it — and produced 60 citations, 1,392 hazard-alert letters, and nearly 1,400 workers pulled off hazardous jobsites (Ogletree Deakins). Here’s the catch: the program lapsing doesn’t make heat legal to ignore. OSHA can still cite you under the General Duty Clause — Section 5(a)(1) of the OSH Act — for a recognized hazard like heat, and it used exactly that authority all through the program. Fewer surprise visits, same legal exposure if a tech goes down.
Quick hits
The proposed federal rule is stalled, not dead. OSHA’s permanent heat standard — published as a proposed rule on August 30, 2024, covering construction, general industry, maritime, and agriculture — finished its public hearing on July 2, 2025 and its post-hearing comment period on October 30, 2025, but hasn’t been finalized. Per the DOL’s 2026 regulatory plan, OSHA now says it will issue a supplemental proposed rule in December.
Know the two numbers in that rule. The proposal sets an initial heat trigger at a heat index of 80°F (water, shade, rest breaks, acclimatization) and a high-heat trigger at 90°F (extra breaks, monitoring). Whatever the final version says, those thresholds are where the debate sits.
Seven states already bind you regardless of Washington. If you work in California, Colorado, Maryland, Minnesota, Nevada, Oregon, or Washington, those states run their own heat-illness standards under OSHA-approved State Plans — enforceable no matter what the federal rule does.
The Tip — Write a one-page heat plan before the next hot week
The cheapest insurance against a General Duty Clause citation — and against a heat-stroke lawsuit — is a written plan you can hand an inspector. Keep it to a page: cool water within reach, a shaded or cooled rest spot, paid rest breaks that scale up as the heat index climbs past 80°F, and an acclimatization schedule that eases new hires and anyone back from a week off into full exposure over their first several days (most heat deaths hit workers in their first days on the job). Add a line naming who watches the forecast and calls the breaks. Train the crew on the symptoms once, log that you did it, and you’ve covered the basics that every version of this rule — state or federal — asks for.
Tool watch — [Not sponsored]
The free OSHA-NIOSH Heat Safety Tool app puts the current heat index and risk level on your foreman’s phone and spells out the precautions at each level — a simple way to make the 80°F trigger a real decision on-site instead of a guess. It’s a government app; no one paid for this mention.
That’s the callout. See you next time.
The Callout — the business brief for the trades.
We label every commercial placement: [Sponsor], [Affiliate], or [Not sponsored]. Today’s Tool watch is our own honest read — no one paid for it.
Sources: OSHA — Heat Injury and Illness Prevention Rulemaking · Ogletree Deakins — OSHA’s Heat Program to Expire While Heat Standard Stalls · EHSLeaders — OSHA Reveals Plans for Final Heat Illness Rules · OSHA — Heat Illness Prevention Campaign and Heat Safety Tool app