Arizona Workers Get Heat Safety Guidelines But No Enforceable Standards

New Heat Guidelines Approved, But Advocates Push for Binding Rules

PHOENIX – Arizona has adopted new workplace heat safety guidelines as summer approaches, but advocates say the recommendations lack enforceable standards that could actually protect workers from heat-related illness and death.

The Industrial Commission of Arizona voted on April 9 to approve guidelines developed by Gov. Katie Hobbs Workplace Heat Safety Task Force. The recommendations call on employers to establish heat illness prevention plans that include access to cool water and shade, rest periods, training and gradual exposure to intense heat.

These are lifelong illnesses for us, said Trina David, a crew chief for an airline at Phoenix Sky Harbor International Airport who has worked for 18 years at the airport.

According to Banner Health, pavement temperatures can be 40 to 60 degrees hotter than the air temperature, and the tarmac is no exception. The physical demands compound the risk, David said.

You are talking about exertion levels because each back is 50 pounds or more, David said.

If breaks are not required, she said, many workers feel they cannot take them.

If you leave it as needed people wont take the breaks because they feel retaliation is real, David said.

The new guidelines build on existing workplace safety measures; they do not create protections from scratch. ADOSH operates its own workplace safety program under a state plan approved by the federal agency OSHA, which sets baseline standards for workers protections, said Amber Pappas, an occupational safety and health consultant and facilitator on the task force.

OSHA launched a National Emphasis Program specific to heat hazards in 2022, directing enforcement agencies to focus inspections on heat-related risks. Arizona followed in 2023 by adopting a State Emphasis Program through ADOSH. However, that program includes general guidance, rather than enforceable, heat-focused rules.

Pappas described the requirements as catch all standards, adding that the state relies on an overarching standard, often referred to as the general duty clause, for enforcement.

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, she said. Currently under state emphasis, all we have is that general duty clause.

The task force submitted final recommendations on Dec. 31, 2025, and the Industrial Commission of Arizona, the state agency that oversees ADOSH, voted to approve and roll out those guidelines on April 9. The task force received direction from Gov. Hobbs last May to establish a Workplace Heat Safety Task Force made up of medical experts and workers rights advocates and representatives across Arizona.

The guidelines have a broad reach for industries across the state, including agriculture. Heat-related mortality rates for U.S. crop workers are 20 times higher than other industries, according to the Environmental Defense Fund.

Jazmin Moreno-Dominguez, an organizer and co-founder of Agave Community Threads, surveyed agricultural workers in southern Arizona. She said she has heard stories of workers who have to walk long distances to get to water stations and seek shade in hazardous places like behind tractor tires.

Moreno-Dominguez is part of the Arizona Heat Standards Coalition, a group of community members who called on the state to implement enforceable heat safety rules as quickly as possible.

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.

Fifteen of the 24 task force members called on ADOSH to support binding and enforceable heat safety rules including defining hazardous temperatures and minimum rest periods. Ultimately, the final recommendation approved by the entire task force did not include enforcement provisions and the commission moved forward with the guidelines without launching a rulemaking process.

According to Maxwell Ulin, staff attorney for the UNITE HERE Local 11 union, the Arizona guidelines give employers best practices for heat safety. This also aids state enforcement to a limited degree by helping investigators assess whether a business is doing enough to keep workers safe.

Still, Ulin believes this is not enough protection.

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.

Five states currently have varying forms of heat standards, according to OSHA. Colorado heat standard only applies to agricultural workers, while Minnesota heat standard only applies to indoor places of employment. California has a Heat Illness Prevention Standard that applies across industries and is triggered 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 said 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.

The commission ordered a report on the effectiveness of the new guidelines by the end of the year.

Business Community Welcomes Guidelines as Practical Solution

Grace Appelbe, representing the Arizona Chamber of Commerce and Industry and the Arizona Manufacturers Council, told the commission that the task force recommendations reflect a thoughtful, Arizona-specific approach grounded in real-world experience.

The recommendations before you reflect a thoughtful, Arizona-specific approach grounded in real-world experience. They focus on practical measures water, shade, rest, acclimatization, and training while preserving the flexibility needed across different industries and job sites, Appelbe told the commission.

Appelbe said the Arizona Chamber and Manufacturers Council have been engaged in the heat safety conversation since the task force was convened by executive order in 2025.

The business community consistent goal throughout has been to ensure that any guidance coming out of the process works in actual workplaces across manufacturing floors, construction sites, agricultural operations, and the full range of industries that make up Arizonas economy, Appelbe said.

The commission chairman described the vote as a beginning rather than an endpoint, noting that guidelines carry the advantage of taking effect immediately, allowing employers to act now while the state continues gathering data to inform any future rulemaking.

The commission will expand employer training on heat risks, encourage the development of workplace heat safety plans, and collect data on the effectiveness of heat safety interventions across the state. Commissioners plan to revisit the recommendations in December.