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What the plan must do
Heat risk on a construction site is produced by the combination of environmental conditions and the work itself. Air temperature alone does not tell you whether a roofing crew, concrete crew or equipment operator can safely continue. Humidity, direct sunlight, radiant heat from roofs and pavement, air movement, workload, clothing and personal protective equipment (PPE), shift timing, exposure duration and acclimatization all change the risk.
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OSHA states that employers should create a written plan to prevent heat-related illness. The plan should be available to supervisors and workers at the site and should describe what actually happens on that project. A model document copied without site details cannot decide who will check conditions, where a worker will cool down, how an ambulance will enter the site or when a task must be changed.
The federal OSHA heat-injury rulemaking page, accessed October 13, 2026, describes the Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings as a proposed rule. The informal public hearing ran from June 16 through July 2, 2025, and the post-hearing comment period ended October 30, 2025. It is not a final federal standard. The General Duty Clause and applicable state-plan or state occupational-heat requirements may still impose duties, and those requirements can differ by location.
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1. Set the scope, ownership and daily authority
Put the project identity and the plan’s authority on the first page. Identify the employer, project address, covered buildings and work areas, expected activities, plan owner and revision date. State that the plan applies to outdoor work and to indoor areas that become hot because of weather, equipment, processes or limited ventilation.
Name the people who make the plan work
- Plan owner: maintains the written procedure and coordinates changes with the employer’s safety system.
- Daily heat-plan lead: a named person for every workday who checks conditions, implements controls and has authority to change work. OSHA says this person should know how to identify and control hazards, recognize symptoms, provide first aid and activate emergency medical services.
- Supervisors and forepersons: conduct the pre-shift briefing, enforce work/rest arrangements, observe workers and report changes to the daily lead.
- Workers: follow controls, use water and recovery periods, work with their assigned buddy and report symptoms or unsafe conditions immediately.
- First-aid responders: list trained responders, their locations and the equipment available to them.
- Emergency contacts: post the site address, access gate, directions for emergency vehicles and the method for calling 911.
The daily lead must be close enough to observe the crew and conditions. Include a rule that any worker may stop work or leave the task to report symptoms without waiting for permission. Define who can order a task paused, moved to a cooler period, rotated or stopped.
2. Assess heat hazards and establish decision triggers
Complete a pre-shift assessment for each major task and repeat it when conditions change. Record the task, location, time, crew size, clothing or PPE, expected duration and available recovery space. Reassess after a weather alert, a sudden increase in temperature or humidity, a change in wind or cloud cover, a move to a roof or enclosed space, a change in PPE, or an increase in production demands.
Factors to record
- Physical workload, including lifting, carrying, climbing, bending and sustained force.
- Air temperature and humidity.
- Direct sun and radiant heat from roofs, pavement, masonry, hot equipment or other surfaces.
- Air movement and ventilation.
- Protective clothing, impermeable garments, helmets, face protection and respirators that may restrict heat loss.
- Length and timing of the exposure, including whether strenuous work is scheduled during the hottest period.
- Distance to water and the recovery area, and whether that area is actually cool enough to support recovery.
- Worker acclimatization, recent absences, new assignments and known susceptibility concerns that require occupational-health advice.
Choose the right heat measurement
OSHA identifies an on-site wet bulb globe temperature (WBGT) meter as the most accurate way to measure the environmental heat impact on body temperature. A WBGT reading incorporates the effects of temperature, humidity, sunlight and air movement. If you use a meter, record its location, the task and the conditions represented by the reading; a measurement in a shaded office does not represent a crew on a roof.
The OSHA/NIOSH Heat Safety Tool can provide heat-index information and workload guidance, but it does not measure WBGT. Treat an app estimate as an aid to a decision, not as a direct substitute for a site measurement. Where no single method fully represents the exposure, use the best available assessment and apply additional controls rather than presenting one universal temperature cutoff as safe for every task or jurisdiction.
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| Assessment option | What it tells you | Limit to state in the plan |
|---|---|---|
| On-site WBGT meter | Most accurate assessment of environmental heat impact when placed to represent the work area. | Readings are location- and time-specific; document where and when they were taken. |
| OSHA/NIOSH Heat Safety Tool | Heat-index information and workload guidance. | It reports heat index, not WBGT, and may not represent radiant heat or air movement at a particular task. |
| Weather information plus site observation | Useful when instruments are unavailable and for anticipating changes. | Do not treat a forecast or one thermometer reading as a complete assessment of workload, PPE and radiant heat. |
Write actionable triggers
Do not write only “monitor the weather.” Specify what happens when risk rises: the daily lead increases the frequency or length of recovery periods, moves work to a cooler time, adds shade or airflow, reduces manual handling, rotates tasks, shortens exposure for unacclimatized workers, or stops the task. Triggers should account for the combined assessment rather than rely on a single number.
3. Apply controls in the order that protects the crew
Use engineering measures first where feasible, then work-practice and scheduling measures. PPE remains necessary for the underlying construction hazard, but it can also increase heat load; assess both hazards together.
Engineering controls
- Use cooled or air-conditioned equipment cabs and break areas where available.
- Increase ventilation or air movement in enclosed or partially enclosed spaces.
- Install reflective barriers or insulation when roofs, pavement, equipment or other sources radiate heat.
- Use fans or misting fans when they are suitable for the environment and do not create electrical, visibility, contamination or slip hazards.
- Use mechanical aids to reduce lifting, carrying and other manual exertion.
Work-practice and scheduling controls
- Start earlier or move strenuous work to cooler hours when the project schedule allows.
- Break a heavy task into shorter work periods and provide recovery in a cool location.
- Rotate workers between tasks only when each worker is trained and the rotation genuinely reduces heat load.
- Reduce unnecessary manual handling and stage materials closer to the point of use.
- Shorten shifts or exposure periods for new, returning or otherwise unacclimatized workers.
- Require recovery breaks when the assessment calls for them; do not make workers choose between a production target and a break.
Check that the controls do not undermine another safety requirement. For example, a fan or misting device must not create a new hazard, and removing protective clothing is not an acceptable heat control if it leaves a worker exposed to the original hazard.
4. Make water, rest and shade usable
Water and recovery arrangements fail when they are technically present but too far away, difficult to reach or unavailable during the busiest part of the shift. Keep cool potable water near active work, in a familiar location, with enough supply for the shift. Remind workers to drink regularly rather than waiting until they are thirsty.
For work lasting two hours or more, OSHA advises access to electrolyte-containing drinks. State in the plan where those drinks are kept and how the supply will be replenished. Do not make a worker walk across an active work zone or climb down from a roof simply to drink.
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Define the recovery location
| Recovery option | When it can work | Checks before the shift |
|---|---|---|
| Shaded area | Useful when the shade remains available and is materially cooler than the work area. | Confirm coverage throughout the shift, seating or space, airflow and a safe route from the task. |
| Air-conditioned vehicle or building | Strong option when workers can reach it promptly and it is not occupied by another operation. | Keep access clear, confirm the unit is operating and set a process so workers are not denied entry. |
| Suitable tent or fan area | Can provide recovery when configured to reduce heat and support airflow. | Inspect stability, ventilation, fan placement, electrical safety and whether the area is cool enough for recovery. |
Break frequency and duration must rise as heat stress rises. Set them using the heat assessment, workload, PPE, individual factors and the quality of the recovery location. Record who announces a break, how workers are relieved from the task and how the lead confirms that breaks are actually taken.
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5. Acclimatize new and returning workers
A worker who performed well in cooler weather may not tolerate a full hot-weather workload after an absence. Pay particular attention to new hires, temporary workers, people returning after a week or more away, the first sustained warm period of spring or early summer, and abrupt increases in heat compared with recent conditions.
Use the 20-percent progression
OSHA and NIOSH recommend limiting a new worker’s heat exposure to 20 percent of the normal exposure duration on day one, then increasing exposure by 20 percent on each additional day. The following example shows the progression as a percentage of the normal exposure duration:
| Day | Maximum portion of normal heat exposure | Plan action |
|---|---|---|
| 1 | 20% | Assign lower exposure, frequent recovery and a trained buddy. |
| 2 | 40% | Reassess tolerance and conditions before increasing exposure. |
| 3 | 60% | Maintain close observation and the planned recovery periods. |
| 4 | 80% | Increase only if the worker is tolerating the assignment and conditions support it. |
| 5 and after | Up to 100% if appropriate | Continue monitoring; some workers may need a slower progression. |
OSHA says acclimatization commonly takes one to two weeks and that some workers may need up to 14 days. Use tasks with intensity similar to the work the person will eventually perform, keep additional breaks in place and extend the progression when symptoms, unusual fatigue or changing conditions warrant it.
Use a buddy system
Pair a new or returning worker with someone who knows the task and the warning signs. The buddy checks in at agreed intervals, confirms water and break access, and reports symptoms immediately. A buddy system supplements—not replaces—supervisor observation and the daily lead’s responsibility.
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6. Train, brief and communicate
Provide training before heat exposure and refresh it when conditions, assignments or controls change. Use languages and communication methods the crew understands, including briefings suited to noisy or remote areas.
- How heat illness develops and why workload, humidity, sun, radiant heat, PPE and acclimatization matter.
- How to use water, electrolyte-containing drinks where applicable, recovery areas and scheduled breaks.
- The acclimatization progression and the buddy assignment.
- Which engineering and work-practice controls apply to each task.
- How to stop work, report symptoms and obtain relief without delay.
- How to recognize the warning signs covered by the site’s first-aid procedure.
- How to cool an affected worker, summon emergency medical services and direct responders to the site.
Train supervisors separately on reading the daily assessment, changing controls, documenting decisions and responding when a worker reports symptoms. The OSHA model plan is a resource; it expressly is not designed to address every worksite scenario, every state or local requirement, or workers with medical or preexisting conditions that increase risk. Do not use that limitation to exclude a worker. Seek appropriate occupational-health and legal advice about individual accommodations and jurisdiction-specific duties.
7. Respond immediately to suspected heat illness
Symptoms are a prompt for action, not an invitation to diagnose the illness at the worksite. The plan should tell every worker exactly what to do.
- Stop the task. Tell the supervisor or daily heat-plan lead and protect the worker from further exposure.
- Move to a cooler area. Use the designated shade, air-conditioned vehicle or building, or suitable fan-supported recovery area.
- Cool immediately. Remove outer layers as appropriate and use the site’s available cooling methods. OSHA describes cold-water immersion or an ice bath as the best method for rapid emergency cooling; cold wet towels, ice applied to key areas and fans are other listed methods when immersion is not available.
- Stay with the worker. Do not leave the person alone while arranging care or transport.
- Call 911 when in doubt. Call immediately for confusion, slurred speech or unconsciousness—signs of heat stroke—while cooling continues.
- Give responders accurate information. Provide the site address, gate, access route, time symptoms began, task, PPE, cooling already attempted and the worker’s current condition.
Post the emergency procedure at the water and recovery areas, in site offices and where supervisors gather. Practice it before hot work begins. Verify that gates, roads, elevators and escorts will not delay emergency access.
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8. Run the plan every workday
Pre-shift checklist
- Daily heat-plan lead named and present or reachable.
- Weather, site measurements and task conditions checked.
- High-heat tasks, PPE, duration and workload identified.
- Water, electrolyte-containing drinks for qualifying work, shade and cooling equipment available and accessible.
- Break schedule and work/rest changes communicated.
- New and returning workers assigned an acclimatization schedule and buddy.
- Emergency address, access route, responder and communication method confirmed.
During-shift checks
- Reassess after weather alerts, task changes, movement to a hotter area or any report of symptoms.
- Observe workers rather than relying only on self-reporting.
- Confirm that breaks are occurring in the designated recovery area.
- Refill water and cooling supplies before they run out.
- Apply the escalation decision: add controls, change the schedule, reduce exposure or stop work.
End-of-shift review
- Record significant readings, changes, symptoms, incidents, near misses and corrective actions.
- Note equipment or recovery-space failures that must be repaired before the next shift.
- Update acclimatization assignments and the next day’s briefing.
9. Document, review and improve the plan
Keep the current plan in the employer’s required format, along with daily assessments and changes, training records, acclimatization assignments, observations, incidents, near misses and corrective actions. Documentation should show what the site actually did, not merely that a template exists.
Review the plan after a heat illness or near miss, a material change in work, PPE or site layout, a failure of water or cooling access, or a change in governing requirements. OSHA inspection guidance indicates that inspectors may review employer plans, acclimatization, work/rest schedules, water and shade access, and training records. A record that matches field practice helps supervisors identify weaknesses before an inspection or emergency does.
10. Verify the rules for the project’s location
Federal OSHA jurisdiction, an OSHA state plan and other state or local requirements may differ in scope, thresholds and required actions. Before describing the plan as compliant, identify the project’s location, the agency with authority and any construction-specific rule, collective agreement or contract requirement that applies. Check the current rule and agency guidance for that jurisdiction; do not treat OSHA’s model plan or a federal proposal as a universal legal template.
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