Arizona’s Heat Challenge: Protecting Workers in a Warming State

Arizona's extreme summer temperatures are more than an inconvenience - they are a serious occupational hazard. With annual average highs in Phoenix often exceeding 100°F and record-breaking heat waves becoming the norm, workers across industries face real and life-threatening risks. From construction crews under the desert sun to warehouse staff in hot indoor environments, heat exposure threatens the health, safety, and livelihood of millions.

Across the state, policymakers, advocates, and employers are responding with a suite of heat safety initiatives, regulatory updates, and emerging guidelines aimed at preventing heat-related illnesses and deaths in the workplace.

Why Heat Safety Matters in Arizona

Heat-related illnesses range from cramps and exhaustion to heat stroke - a medical emergency that can cause organ damage or death. Workers in outdoor and indoor heat environments - including construction, landscaping, delivery, agriculture, manufacturing, and warehousing - are especially vulnerable. The effects of high heat aren't limited to outdoor jobs; intense heat can accumulate indoors near machinery or in areas with limited ventilation.

Historically, workplace heat protections across the U.S. have relied on broad obligations like the Occupational Safety and Health Act's General Duty Clause, which requires employers to provide workplaces “free from recognized hazards.” But that clause alone offers limited clarity or enforcement mechanisms specific to heat risk. Arizona, like many states, is now moving toward more targeted solutions.

In the absence of a federal heat-specific standard, OSHA launched a National Emphasis Program (NEP) on Heat in 2022-an enforcement initiative that prioritizes inspections in high-risk industries such as construction, agriculture, warehousing, and manufacturing during hot weather months. The NEP increases proactive inspections, directs compliance officers to review heat illness prevention programs, and raises awareness that heat is a recognized occupational hazard. However, even under the NEP, most citations are still issued using the General Duty Clause. Because that clause requires OSHA to prove that heat is a recognized hazard, that the employer failed to implement feasible controls, and that those controls would materially reduce risk, enforcement can be complex and resource-intensive. As a result, while the NEP signals stronger federal attention on heat safety, it does not necessarily provide the clarity or straightforward compliance pathway that a dedicated heat standard would offer.

Arizona's Heat State Emphasis Program: A Foundation for Change

In July 2023, the Arizona Division of Occupational Safety and Health (ADOSH), part of the Industrial Commission of Arizona (ICA), launched a State Emphasis Program (SEP) focused on “Outdoor and Indoor Heat-Related Hazards.”

This SEP represents a pivotal shift: it institutionalizes heat risk as a priority for workplace safety inspections and outreach. Under the program, ADOSH inspectors integrate heat risk into all aspects of workplace evaluations, with a focus on early intervention and preventative measures. The SEP emphasizes core strategies such as:

• Access to cool potable water
• Adequate rest breaks and shaded areas
• Worker training on heat illness signs and prevention
• Acclimatization for new and returning workers

ADOSH procedural guidance explicitly calls for inspections not just in outdoor construction but also in indoor environments prone to radiant heat hazards, such as manufacturing facilities.

In addition to compliance efforts, ADOSH's SEP includes outreach and assistance offering free evaluations and training to help employers build effective heat safety plans.

Phoenix's Worker Safety Ordinance: A Local Model

At the local level, Arizona's largest city - City of Phoenix Worker Safety Ordinance - has taken a proactive stance. In March 2024, Phoenix passed a heat safety ordinance requiring that all city contractors and subcontractors maintain written heat safety plans as part of their contracts.

This ordinance aims to ensure:

• Written heat hazard mitigation plans are in place for outdoor workers
• Hydration, shade breaks, and rest periods are systematically incorporated
• Employers document procedures for preventing heat-related illnesses
• Workers in covered contracts receive clear protections against extreme heat

By tying heat safety plans to city contracts, Phoenix is pushing employers to adopt structured practices rather than ad-hoc responses. Experts note that such ordinances are essential first steps toward widespread adoption of real, enforceable standards.

State-Level Momentum: Task Forces and Guidelines

Beyond local ordinances and the SEP, Arizona's state leadership has catalyzed broader policy progress. In May 2025, Governor Katie Hobbs signed an executive order directing ADOSH to form a Workplace Heat Safety Task Force charged with developing recommended heat guidelines for employers.

This Task Force - composed of labor representatives, safety experts, business leaders, and policy advocates - spent months gathering evidence and consensus on practical heat risk mitigation strategies. Its final recommendations, delivered at the end of last year, outline a clear set of employer best practices that emphasize:

• Access to water, shade, and rest
• Worker acclimatization programs
• Heat safety training for all employees
• Clarified definitions and employer responsibilities

These guidelines target common risk factors and are designed to be actionable across industries. While not yet codified into regulation, they represent a major step toward statewide heat safety expectations.

Following submission, recommendations were reviewed by the ADOSH Advisory Committee in early 2026 and are expected to inform future regulatory updates.

Advocacy and Calls for Enforceable Standards

Despite momentum, worker advocates argue Arizona needs even stronger, enforceable statewide standards. In December 2025, groups including the Arizona Heat Standards Coalition delivered a petition with over 1,500 signatures urging state government to adopt baseline protections such as guaranteed access to water, shade, rest, and training for all workers.

Advocates point to preventable worker deaths and illnesses during record heat years as evidence that voluntary or advisory guidelines alone are insufficient. Their push underscores the urgency of formalizing heat safety requirements that apply across industries and job sites.

Best Practices for Employers - What You Can Do Now

Even as policy evolves, employers can take immediate steps to protect workers and reduce heat-related incidents:

1. Develop a Heat Safety Plan

A formal plan should include hazard assessment, hydration protocols, rest schedules, acclimatization procedures, and emergency response steps.

2. Ensure Access to Water and Shade

Provide plentiful cool water and shaded or air-conditioned rest areas, especially during peak heat conditions.

3. Train Employees and Supervisors

Educate workers on recognizing signs of heat stress - such as dizziness, cramps, and nausea - and communicate reporting procedures.

4. Implement Acclimatization Protocols

Gradually increase work times in high heat for new or returning workers to build tolerance and reduce shock.

5. Track Conditions and Adjust Schedules

Monitor local heat advisories and adjust work schedules or rotations accordingly. Use tools like the Wet-Bulb Globe Temperature (WBGT) as a measure of environmental risk where feasible.

Looking Ahead: A Cooler, Safer Arizona

Arizona's legislative and regulatory landscape around worker heat safety is evolving rapidly - from SEP enforcement efforts and local heat ordinances to statewide task force recommendations and advocacy campaigns. While gaps remain, this mixture of policy, best practice guidance, and community action reflects a growing commitment to making heat safety a central part of occupational health in a warming world.

For employers, now is the time to align operations with emerging standards - building heat safety into workplace culture not only protects workers but enhances productivity, morale, and community trust.