SAFETY UPDATE www.mrca.org — Midwest Roofer 14 I t seems appropriate that I use this article to update our members on heat illness prevention. First, remember that the OSHA Heat Illness Prevention Standard is still pending at OSHA. As I hope you will recall, virtual public hearings were held on this proposed standard in July 2025. As a result of this, the record was opened for anyone to submit written comments until October 30, 2025. OSHA established a National Emphasis Program (NEP) for Heat Illness Prevention, which was set to, and did, expire on April 8, 2026. However, on April 10, 2026, OSHA established a new NEP for five more years. In doing so, OSHA has reminded employers and employees that it takes heat illness, and the injuries it can cause, very seriously. In the new NEP, OSHA has updated target industries using current data from the Bureau of Labor Statistics and OSHA. These industries have been identified as residential building construction; non-residential building construction; foundation, structure and building exterior contractors; building finishing contractors; and other specialty trade contractors as target industries for heat illness prevention enforcement. I believe that this covers just about any employer in any area of construction. OSHA has also provided information on points that an OSHA compliance officer (CSHO) is to consider when evaluating an employer’s Heat Illness Prevention Program. These include: 1. Is there a Heat Illness Prevention Program in place that is effectively communicated to employees? 2. How does the employer monitor the ambient temperature and the levels of work exertion at the worksite? With this, OSHA is emphasizing that By: Gary Auman, MRCA Legal Counsel U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration DIRECTIVE NUMBER: CPL 03-00-024 SUBJECT: National Emphasis Program – Outdoor and Indoor Heat-Related Hazards DIRECTORATE: Directorate of Enforcement Programs SIGNATURE DATE: April 10, 2026 EFFECTIVE DATE: April 10, 2026 ABSTRACT Purpose: This Instruction describes policies and procedures for the continued implementation of a National Emphasis Program (NEP) to protect employees from heat-related hazards and resulting injuries and illnesses in outdoor and indoor workplaces in general industry, construction, maritime, and agriculture. This NEP sets forth a targeted enforcement component and reiterates compliance assistance and outreach efforts. This approach is intended to encourage early interventions by employers to prevent illnesses and deaths among workers during high heat conditions, such as working outdoors in a local area experiencing a heat wave, as announced by the National Weather Service. Scope: This Instruction applies OSHA-wide. References: Section 5(a)(1) of the Occupational Safety and Health Act (OSH Act), 29 U.S.C. § 654. OSHA Instruction, CPL 02-00-164, Field Operations Manual (FOM), April 14, 2020. (See Section III for additional references.) Cancellations: CPL 03-00-024, National Emphasis Program – Outdoor and Indoor Heat- Related Hazards, April 8, 2022. State Impact: Notice of Intent Required, Adoption Encouraged. See Section VI. Action Offices: OSHA Regional and Area Offices, State Plan and OSHA On-Site Consultation programs Originating Office: Directorate of Enforcement Programs, Office of Health Enforcement HOT OFF THE PRESS!! SAFETY UPDATE
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