Arizona Heat Safety Guidelines Lack Enforceable Standards Despite Task Force Recommendations

PHOENIX — As summer approaches, Arizona has rolled out new workplace heat safety guidelines that provide detailed recommendations for employers but lack enforceable standards, according to advocacy groups and union leaders.

The state adopted the guidelines on April 9 after the Industrial Commission of Arizona approved recommendations submitted by a Workplace Heat Safety Task Force on Dec. 31, 2025. The task force, created by Gov. Katie Hobbs in May 2025 through Executive Order 2025-09, included 24 members representing construction, agriculture, first responders, hospitality, labor unions, and business groups.

The new recommendations require employers to establish heat illness prevention plans that include access to cool water and shade, training, and gradual acclimatization to intense heat. However, fifteen of the 24 task force members originally called for binding and enforceable heat safety rules, including definitions of hazardous temperatures and minimum rest periods. The final recommendation did not include enforcement provisions.

These are lifelong illnesses for us, said Trina David, a crew chief for an airline at Phoenix Sky Harbor International Airport. She has worked at the airport for 18 years and has seen workers collapse from heat-related illness.

Banner Health reported that pavement temperatures can be 40 to 60 degrees hotter than the air temperature, particularly on airport tarmacs where workers carry heavy luggage. David noted that when breaks are not required, many workers feel unable to take them because they fear retaliation.

Amber Pappas, an occupational safety and health consultant and task force member, explained that ADOSH operates under a state plan approved by the federal Occupational Safety and Health Administration. She described the state emphasis program as relying on what she called the general duty clause, which requires employers to provide a workplace free from recognized hazards that could cause serious injury or illness.

All employers are legally required to provide a place of employment free from potential or recognized hazards that could cause serious injury, illness or fatality, Pappas said. Currently under state emphasis, all we have is that general duty clause.

The task force recommendations will be added to the 2023 emphasis program, providing detailed guidance for employers. The Industrial Commission ordered a report on the effectiveness of the new guidelines by the end of the year.

Jazmin Moreno-Dominguez, an organizer and co-founder of Agave Community Threads who surveyed agricultural workers in southern Arizona, said the guidelines represent a delay rather than actual policy implementation. She is part of the Arizona Heat Standards Coalition, which has called for enforceable heat safety rules.

The task force, while it is a great start, in our opinion, is just continuing to delay actual policy on paper and put protections on the ground, Moreno-Dominguez said.

The Environmental Defense Fund reported that heat-related mortality rates for U.S. crop workers are 20 times higher than other industries. Currently, five states have varying forms of heat standards. Colorado's standard applies only to agricultural workers, while Minnesota's only covers indoor places of employment. California has a Heat Illness Prevention Standard that applies across industries and triggers when temperatures reach 80 degrees.

A Health Affairs study found that California saw an estimated 33 percent decrease in heat-related deaths among outdoor workers after it intensified enforcement of its heat standard in 2010, and a 51 percent reduction after revisions were made to the standard in 2015.

Industrial Commission Chair Dennis Kavanaugh stated that Arizona should study how heat standards worked elsewhere, considering more evidence and budget impacts before initiating rulemaking.

Today is not a once and done. This is the beginning of our process as commissioners to deal with this issue, Kavanaugh said during an industrial commission meeting.

Maxwell Ulin, a staff attorney for UNITE HERE Local 11, noted that the guidelines give employers best practices for heat safety and aid state enforcement to a limited degree by helping investigators assess whether a business is doing enough to keep workers safe.

We will continue to be struggling to enforce what is an otherwise very broad, nonspecific standard for safety and health until workers get hurt or until there is substantial risk of injury to workers, Ulin said.

The Industrial Commission of Arizona will publish annual data on heat-related claims, complaints, and citations to evaluate the effectiveness of the recommendations. ADOSH will also provide downloadable template heat plans to help employers, especially small businesses, implement safety measures and launch a recognition program to highlight model employers who exceed basic safety requirements.