Washington, April 28, 2026, 09:05 EDT
OSHA is sticking with its national workplace heat enforcement push, but now meat-processing plants are more firmly in the agency’s crosshairs—even though it dropped its earlier quota for heat-related inspections. The updated National Emphasis Program, steering both inspections and outreach, kicked in on April 10 and could stretch out as long as five years.
Timing is critical here. As the weather heats up, employers across food processing, warehousing, construction, and agriculture are still operating without a finalized federal heat safety rule. With rulemaking still in limbo, OSHA is left leaning on current enforcement guidance and existing regulations.
OSHA’s revised program now targets 55 industries it considers high risk, ditches the previous inspection quotas, and includes revamped instructions for evaluating heat programs and issuing citations. The National Emphasis Program, or NEP, is OSHA’s temporary tool to crack down on hazards or sectors it flags as particularly risky.
OSHA’s appendix now includes animal slaughtering and processing among its newly targeted industries, with hog and pig farming and cheese manufacturing joining the list. Also named: bakeries, tortilla manufacturing, warehousing, storage, couriers, local delivery, and waste collection services.
On Tuesday, FreshFruitPortal said OSHA removed fruit and tree nut farming from its priority-industry list, shifting the focus for a sector often flagged for heat risks. Civil Eats had previously noted this move, adding that greenhouse, nursery, and floriculture operations are now included.
The enforcement threshold is still wide. According to OSHA, when heat hazards show up on heat priority days, compliance officers are set to widen inspections—and when the National Weather Service puts out a heat advisory or warning, random heat inspections will hit high-risk industries.
OSHA’s workload has already shifted under the program. The updated directive puts annual heat-related hazard inspections by federal OSHA at about 2,400 from 2022 through 2025, which includes around 50 fatality cases tied to heat every year. Bureau of Labor Statistics numbers, also cited, show an average of 3,793 heat-related DART cases—those causing days away, restrictions, or transfers—plus 48 deaths each year between 2021 and 2024.
It comes down to the General Duty Clause in the Occupational Safety and Health Act, obligating employers to maintain workplaces free from hazards that could cause death or serious harm. For meat processors and other indoor operations, that’s significant—OSHA’s rules extend to heat dangers both inside and out.
Eric J. Conn, who leads Conn Maciel Carey’s OSHA and workplace safety group, together with Rachel L. Graeber and Beeta B. Lashkari, noted OSHA’s recent move: heat hazards have been elevated to a “core enforcement priority.” According to the trio, this update signals a more robust approach—expect tougher, data-focused enforcement and clearer rules for citing violations. Conn Maciel Carey
The new program, though, trims its focus in a notable way. OSHA chopped 46 industries from its target list, brought 22 in, and kept 33, slicing the total by roughly 30%, according to Beveridge & Diamond attorneys Mark N. Duvall, Heidi P. Knight, Jessalee L. Landfried, Jayni A. Lanham and Ning Hsu. Even so, they cautioned, employers still face the risk of both incident-based and proactive inspections.
Worker advocates aren’t happy about dropping inspection targets. United Farm Workers digital director Jocelyn Sherman called it “terrifyingly unclear” if OSHA will keep up with proactive inspections at hot worksites, according to Civil Eats. OSHA’s response: the updated program is meant to sharpen outreach, boost compliance support and concentrate enforcement where heat risks run highest. Civil Eats
The federal heat standard hasn’t been finalized yet. According to OSHA’s rulemaking page, a public hearing on the Heat Injury and Illness Prevention proposal wrapped up July 2, 2025. The agency then accepted post-hearing comments until Oct. 30. If adopted, the rule would require employers in the scope of the standard to develop plans for identifying and managing heat risks.
Near-term risk isn’t spread evenly among companies. Meat processors and other public employers could see more documentation checks—water access, rest breaks, shade, worker training, acclimatization, heat monitoring. Even firms off the official list aren’t off the hook; a single worker complaint, hospitalization, or fatality can trigger a case. State rules complicate things further. Legal reviews flag California, Oregon, Washington, Colorado, Maryland, Minnesota, and Nevada—all with some form of heat-related regulation or standards.
