Keeping workers safe this summer
Portions of this content appeared in the Summer 2025 print edition of NAPA Quarterly. Subscribe here.
NAPA Vice President for Environment, Health & Safety Howard Marks has led multiple sessions centered on NAPA resources for companies to develop their own heat illness prevention plans.
While OSHA proposed rulemaking aimed at developing a federal heat standard in 2024, Marks said the future of OSHA’s heat illness prevention policies is less than certain, although there is a virtual public hearing on the proposed rule scheduled for June 16. (Editor’s Note: The informal public hearing on OSHA’s Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings proposed rule concluded on July 2.)
In the interim and likely until federal OSHA issues any further rulemaking, six states have already established their own heat standards: California, Maryland, Minnesota, Nevada, Oregon, and Washington. According to the Coalition for Workplace Safety, if OSHA were to move forward with its heat standard, policies in those half-dozen states would stay in place so long as they are found to offer at least equal protection.
Colorado, New Jersey, New York, Rhode Island, and Texas, however, fall under the federal OSHA jurisdiction, meaning if their proposed standards were enacted, an implemented OSHA standard would void them. Utah had a proposed state heat standard that ultimately did not become law, while there is a bill introduced in the Arizona legislature in February that seeks to establish standards in the Grand Canyon State. And Maryland introduced and finalized its own standard that appears problematic to implement.
Regardless, and given state and federal interest to minimize heat illness across outdoor workers, companies should review NAPA’s resources and compare to any currently issued state standard. For those states that do not yet have their own standard, NAPA’s resource guide should meet OSHA’s still current National Emphasis Program.
