In April 2026, OSHA reissued its Heat National Emphasis Program (NEP), strengthening enforcement of heat-related workplace hazards. The program now places greater focus on both indoor and outdoor exposures and applies to public sector employers through New York’s Public Employee Safety & Health (PESH) Bureau.
How Does OSHA’s Heat NEP Apply to Public Entities?
In New York, OSHA standards are enforced for public employers through PESH, which has adopted the Heat NEP. This means state and local agencies are subject to heat-related inspections and enforcement, even though OSHA does not directly regulate public sector workers.
Key Changes in the 2026 Heat NEP
- Expanded coverage of indoor heat hazards
Includes environments like kitchens, laundries, boiler rooms, and unconditioned facilities - Standardized inspection criteria
Inspectors now follow consistent guidance when evaluating prevention programs and issuing citations - Heat priority day inspections
Increased enforcement during days with a heat index of 80°F or higher or during heat advisories - Inspections regardless of daily temperature
PESH may evaluate heat programs even if temperatures are not elevated on the day of inspection
What PESH Expects from Public Employers
Public entities must demonstrate that heat illness prevention is actively managed—not just documented.
Key expectations include:
- Up-to-date, implemented heat illness prevention programs
- Supervisor oversight and accountability
- Monitoring of both indoor and outdoor heat risks
- Documentation of controls, including work adjustments, hydration breaks, and incident response actions
Quick Answer: Do public employers need a heat illness policy?
Yes. Under PESH enforcement of OSHA’s Heat NEP, public employers must maintain and actively implement a heat illness prevention plan, including training, monitoring, and documented response procedures.
Be Ready
The 2026 OSHA Heat NEP increases expectations for public employers. Agencies that align policies with PESH enforcement, clarify supervisory responsibilities, and document actions will be better positioned to reduce inspection risk and protect employees.
Take the Next Step: Align with PESH Expectations
With PESH adopting OSHA’s Heat NEP, public employers need to ensure their heat illness prevention efforts are clearly defined, actively implemented, and well documented.
Download our Heat Illness Prevention Responsibilities Guide for Public Entities to help your team:
- Understand supervisory responsibilities under PESH
- Establish consistent monitoring and response practices
- Strengthen documentation for inspection readiness
Looking for more information on OSHA Heat Illness NEP? Check out OSHA Heat NEP 2026: What Employers Need to Know
Need Help Navigating OSHA’s Heat NEP?
Whether you’re updating policies, training supervisors, or preparing for potential inspections, OneGroup can help you take a proactive, practical approach to compliance. Contact OneGroup to speak with a risk management specialist.