OSHA’s Heat Standard Likely to Affect Indoor Manufacturing Facilities | FIRST, VERIFY

July 16, 2021

This past spring, the Occupational Safety and Health Administration (OSHA) announced its intention to implement a new heat illness standard that will apply to indoor environments. The agency said it has manufacturing facilities in mind, as the rule targets “indoor workers without climate-controlled environments.”


A new heat illness standard is a top priority for OSHA under President Joe Biden, who is seeking to make good on his pledge to be “the most pro-union president you have ever seen.” Public Citizen and Senate Democrats petitioned Biden to encourage the new standard. House Democrats introduced legislation giving the agency two years to promulgate a heat standard. That proposal failed.


Noting that 18 of the last 19 years were the hottest on record and the intensity of recent heat waves have put many employees at an increased risk of heat illness or injury, Acting Assistant Secretary of Labor for Occupational Safety and Health Jim Frederick announced in June that he intends to launch the rulemaking process by publishing a request for information. Frederick remarked that he hopes the agency will have “some very, very good, very thorough stakeholder engagement and involvement” while it develops the rule. “We hope that our request for information is very thoroughly responded to by as many stakeholders as possible.”


The proposed standard is in its preliminary stages and its contents are not yet clear. Requirements in several state standards offer clues. The OSHA standard may mandate break times and require employers to monitor employee acclimatization, as well as temperatures and humidity levels. Such provisions could effectively require costly changes in manufacturing worksites that do not have air conditioning and have a local source of heat, such as a furnace or an oven. Heat levels also can be affected by the presence of many workers at a site, especially if they are engaged in physically exerting tasks.


For example, a factory with employees melting substances like metal or glass would use machinery that can become extremely hot and affect the surrounding environment, regardless of outdoor temperatures. A factory with a furnace operating over 500 degrees causing nearby employees, who may be in heavy personal protective equipment, to perspire heavily, the standard may require cooler temperatures. Minnesota’s indoor heat standard requires employers to measure heat using “wet-bulb globe temperature” (WGBT) index, which is calculated by air temperature, air speed, humidity, and radiation. Permissible heat levels vary by levels of exertion as follows:


“Heavy work” is defined as exerting 350 or more kcal/hr. (kilocalories per hour), which can include heavy lifting and pushing, shovel work. The permissible heat level cannot exceed 77 degrees Fahrenheit.


“Moderate work” is defined as exerting 200 to 350 kcal/hr., which can include moderate lifting and pushing. Its permissible heat level is 80 degrees Fahrenheit.


“Light work” is defined as exerting 200 kcal/hr., which can include sitting or standing performing light hand or arm work. The permissible heat level is 86 degrees Fahrenheit.


In this example, a facility must calculate WGBT and constantly monitor and adjust conditions according to the highest level of exertion by any workers in the working environment. Some manufacturers might find this level of calculation unworkable because of varying or changing production schedules and varying outdoor heat conditions, particularly during heat waves.


There are a few things manufacturing employers can do to help prevent heat-related issues from creeping up, including making sure that employees have:


  • Access to water and stay hydrated;
  • Adequate rest time and take regular breaks; and
  • Access to the shade whenever possible.
  • Employers also can make sure that employees are properly acclimatized before engaging in strenuous activities.


States Considering Standards


On July 8, Oregon adopted a 180-day emergency rule protecting workers from indoor and outdoor heat. The requirements expand access to shade and cool water and include regular cool-down breaks, training, communication, emergency planning, and other measures. It also uses a tiered system with requirements starting up once the heat index is at 80 degrees and increasing when the heat index reaches 90. This temporary standard likely will be the basis of a permanent one to be adopted in the fall.


Virginia is drafting a standard with an intent to “reduce/eliminate employee injuries, illnesses, and fatalities due to exposure to excessive heat at indoor and outdoor places of work.”


General Duty Clause


Historically, OSHA has protected workers against extreme heat by using the General Duty Clause, a “catch-all” provision in the Occupational Safety and Health Act that requires employers to provide employment and places of employment that are free of recognized hazards, which, in the past, has included heat exposure. OSHA noted that in a 2019 case, A.H. Sturgill Roofing Co. v. Secretary of Labor, the Occupational Safety and Health Review Commission (OSHRC) set a high bar for use of the General Duty Clause in cases involving heat exposure and other potentially dangerous environmental conditions. In 2020, an OSHRC judge followed Sturgill and overturned five heat hazard citations against the U.S. Postal Service, holding that OSHA could not rely on a National Weather Service guide to determine heat severity.


OSHA Recommendations


Currently, OSHA recommends that employers set thermostats between 68 degrees and 78 degrees Fahrenheit. OSHA also provides guidance on “Working In Outdoor and Indoor Heat Environments,” and it suggests that employers:


  • Provide workers with water and rest.
  • Allow new or returning workers to gradually increase workloads and take more frequent breaks as they acclimatize or build a tolerance for working in the heat.
  • Plan for emergencies and train workers on prevention.
  • Monitor workers for signs of illness.


Author: By Courtney M. Malveaux


Source: https://www.jacksonlewis.com/publication/osha-s-heat-standard-likely-affect-indoor-manufacturing-facilities



You might also like

By Erica Montefusco March 18, 2026
Erica Montefusco , Senior VP, Risk & Compliance at PROtect tells us why risk management is ultimately an ethical responsibility
Human Risk Perception and Workplace Safety Biases
March 17, 2026
Learn how cognitive biases like optimism bias and normalization of deviance affect workplace safety and increase contractor risk exposure.
By Erica Montefusco March 13, 2026
Erica Montefusco , Senior VP, Risk & Compliance at PROtect tells us why composure is one of the most underestimated risk controls There is a version of leadership that looks strong: Decisive. Authoritative. Confident. Unshaken. And then there is the version of leadership that is actually strong: Calm. Measured. Intentional. Grounded under pressure. The difference only reveals itself in difficult moments. Curiosity enables leaders to identify emerging risks. Resilience determines how they respond when those risks materialize. Pressure Is the Real Leadership Test Industrial and operational environments are inherently dynamic. In industrial environments, pressure is inevitable. Production deadlines tighten. Weather shifts unexpectedly. Incidents occur. Regulators call. Clients demand answers. In those moments, policies matter. Procedures matter. Training matters. Leadership behavior becomes as consequential as policy design. But something else matters just as much: Tone. When pressure rises, people do not default to the manual. They calibrate to leadership. If the leader escalates, the room escalates. If the leader steadies, the room steadies. The tone established by senior leaders influences how information is shared, how accountability is approached, and how effectively teams navigate uncertainty. Escalation can either compound disruption or contain it. Composure is not personality. It is a decision. And it is one of the most powerful risk controls we have. Sustained resilience preserves the conditions necessary for effective risk management. It protects decision quality, maintains organizational trust, and ensures that even under scrutiny, the organization responds with stability rather than volatility. In high-consequence industries, that stability is not simply a leadership trait — it is a strategic asset. Curiosity helps us identify risk. Resilience shapes how we respond when that risk becomes real. Anyone who has worked in industrial or operational environments knows that pressure is not hypothetical. Deadlines compress. Expectations escalate. Incidents require immediate clarity. External scrutiny can intensify without warning. In those moments, policies and procedures matter — but so does something less tangible. Leadership tone matters. Over time, I have come to understand resilience not as toughness, but as intentional calm. It is the ability to pause when acceleration feels easier. It is choosing clarity over reaction. It is protecting the quality of a decision, even when timelines feel compressed. Resilience Is Not Loud Resilience is often misunderstood as toughness. In my experience, resilience is quieter than that. It is the ability to absorb impact without amplifying it. To process urgency without transmitting panic. To hold responsibility without deflecting it. Resilience does not mean indifference. In fact, it often requires absorbing more than you show. It means holding responsibility without transmitting panic. It means reinforcing accountability without creating fear. There have been moments in my career when decisions had weight. When incidents required difficult conversations. When leadership alignment was not immediate. When the right path was clear but not easy. Resilience is not the absence of doubt. It is the ability to move forward thoughtfully despite it. Resilience in risk leadership is therefore not emotional detachment, nor is it rigid confidence. It is disciplined composure. It allows leaders to slow decision-making when urgency threatens clarity, to distinguish between material risk and momentary noise, and to reinforce accountability without creating defensiveness or fear. The Invisible Weight of Responsibility Risk leadership carries a particular kind of weight. When you approve a program, sign off on a system, or certify readiness — you are implicitly saying: “I believe this protects our people.” That should never feel casual. Under pressure, the temptation is to accelerate. To compress review cycles. To assume stability. But experience teaches something different; the cost of rushing risk decisions compounds quietly. Strong leadership sometimes means slowing down when everyone else wants to speed up. That is not obstruction. That is stewardship. Crisis Reveals Culture Difficult moments reveal culture more clearly than routine ones. When pressure rises, do people continue to speak openly? Do teams stay focused on understanding what happened, or do they shift toward protecting perception? The answers to those questions tell you whether resilience is embedded in the organization — or merely assumed. You can learn more about an organization in a single difficult week than in a year of routine operations. When something goes wrong, watch: Do people look for blame? Or do they look for understanding? Do leaders protect reputation first? Or protect people first? Do teams communicate openly? Or retreat into defensiveness? Resilience is not built during crisis. It is revealed. The culture you shape on ordinary days determines how your organization behaves under extraordinary ones. Organizations reveal their cultural maturity during periods of stress. In resilient environments, reporting remains transparent, analysis remains objective, and improvement efforts focus on systems rather than blame. In fragile environments, pressure suppresses reporting and shifts attention toward reputational protection rather than operational correction. In my experience, resilience is built long before crisis arrives. It develops through experience, through reflection, and through learning when to slow down rather than speed up. It is strengthened every time a leader chooses steadiness over escalation. In high-risk environments, that steadiness is not just a leadership trait. It is a protective force. It safeguards decision quality, preserves trust, and creates the conditions where honest conversations can continue — even under pressure. And often, that makes all the difference. Personal Evolution Under Pressure Early in my career, I believed strength meant always having the answer. Now I understand that strength often means holding space long enough to ask better questions. “What are we missing?” “What assumptions are we making?” “What would this look like if it went wrong?” Pressure can narrow perspective. Resilient leadership expands it. Over time, I have learned that steadiness is not automatic. It is built through experience. Through adversity. Through moments that test your confidence. Resilience is not inherited. It is earned. The Discipline of Staying Calm Remaining calm under pressure does not mean you are unaffected. It means you are intentional. Intentional about your words. Intentional about your pace. Intentional about your influence. In high-risk environments, emotional regulation is not a soft skill. It is operational infrastructure. It protects decision quality. It protects team cohesion. It protects escalation pathways. Calm leadership does not remove risk. It reduces secondary damage. Why This Matters More Now We are operating in an era of accelerated visibility. Data moves faster. Public scrutiny is sharper. Regulatory expectations evolve quickly. Pressure will not decrease. The leaders who endure will not be the loudest. They will be the most grounded. Resilience in leadership is not about dominance. It is about stability. And stability, in high-risk environments, is strength. Closing Reflection There is a difference between reacting and responding. Reaction is emotional. Response is intentional. Under pressure, that distinction determines outcome. Resilience is not something we list on a résumé. It is something people feel when they stand in a room with you during a difficult moment. And in risk leadership, that feeling can make all the difference.

Book a Service Today