Heat Illness Prevention in the Workplace
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Nevada Heat Illness Prevention Policies and Employer Obligations
Nevada has recently adopted a formal heat illness prevention regulation to protect workers from heat-related hazards. The regulation was approved in late 2024 and will be enforced beginning April 29, 2025.
Who Must Comply
- Employers with 10 or more employees who have workers performing tasks with potential heat exposure must comply with the heat illness rule.
- Employers of any size with workers exposed to recognized heat hazards under the federal General Duty Clause are still responsible to protect those workers, even if they are not covered by the Nevada-specific rule.
Key Policy Requirements
1. Job Hazard Analysis (JHA)
Nevada employers must perform a one-time written job hazard analysis for any classification where employees are exposed to conditions that could result in heat illness for more than 30 minutes in any 60-minute period, excluding breaks.
This analysis must:
- List job classifications and tasks where heat exposure may occur
- Identify working conditions that may cause heat illness
- Identify measures to mitigate or eliminate identified hazards
JHAs must be reviewed and revised when job duties significantly change or after a heat-related incident.
2. Written Heat Illness Prevention Program
If the job hazard analysis identifies heat risk, employers must include a Heat Illness Prevention Plan within the company’s safety program.
This plan must include:
- Provision of potable drinking water for employees
- Rest breaks when workers show signs or symptoms of heat illness
- Means of cooling (shade, fans, ventilation, air-conditioning where available)
- Monitoring working conditions that could create heat exposure
- Identification and mitigation of heat sources such as radiant, conductive, or environmental heat
- Training employees on hazard recognition and prevention
- Emergency response procedures for heat illness incident
The safety plan must be clearly documented and integrated into the employer’s overall safety practices.
3. Training Requirements
Employers must provide training to employees identified in the job hazard analysis on:
- How to recognize the hazards of heat illness
- Procedures to follow to minimize the risk of heat illness
- How to respond if an employee shows signs or symptoms of heat illness
Training must be provided before work begins in heat-exposed conditions and should be refreshed regularly.
Federal OSHA guidance also underscores that training should cover hazard recognition, first aid, proper rest and hydration practices, and acclimatization processes.
4. Designated Monitoring and Emergency Procedures
Employers must designate an individual responsible for monitoring working conditions and ensuring emergency response procedures are followed when an employee is experiencing heat illness.
That person must:
Monitor workers and environmental conditions
Contact emergency services if necessary
Provide necessary information to responders
Ensure procedures are followed appropriately
This monitoring duty extends to both outdoor and indoor environments when heat exposure is a risk.
5. Exemptions and Special Conditions
Some employers are exempt from portions of the Nevada heat regulation if:
- Work is performed indoors in a climate-controlled environment with effective cooling systems.
However, if climate control fails, employers must take good-faith measures to address heat hazards until the system is restored.
Collective bargaining agreements cannot reduce or waive heat illness prevention requirements — employers must meet or exceed regulatory obligations.
How Nevada Enforces the Policy
Starting April 29, 2025, Nevada OSHA inspectors can review employers’ hazard analyses, written safety plans, training records, and monitoring procedures during:
- General inspections
- Complaint investigations
- “Heat priority” inspections — days when temperatures reach or exceed 90°F
- Follow-ups after incidents or reports of heat illness
Failure to comply can result in citations, fines, and increased liability — particularly if a heat-related illness or fatality occurs on the job.
Best Practice Expectations Beyond the Regulation
In addition to the regulation’s minimum requirements, Nevada OSHA guidance recommends employers adopt:
- Engineering controls such as shade, ventilation, and reflective shields
- Acclimatization schedules for new or returning workers
- Detailed work/rest schedules tailored to environmental conditions
- Proactive monitoring using environmental metrics like WBGT (Wet Bulb Globe Temperature)
Employers are encouraged to involve employees in hazard analysis and review procedures to improve accuracy and efficacy.
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