To the Members of the Virginia Safety and Health Codes Board,

On behalf of the more than 359,000 union members across the Commonwealth in industries such as construction, manufacturing, healthcare, transportation, airports, warehouse, retail, healthcare, education, utilities, mining, public works and infrastructure, we write in strong support of the Department of Labor and Industry (DOLI)’s promulgation of a comprehensive Heat Illness Prevention Standard for both indoor and outdoor workers.

Requiring employers to prevent and mitigate injuries and illnesses associated with heat exposure is urgent and critically needed. Heat has been recognized as a significant hazard for workers for decades, and as heat exposures have intensified, many already dangerous jobs have become unbearable. The summer of 2026 was the hottest ever measured, surpassing the previous record set in 2023, continuing to exacerbate extreme heat conditions across indoor and outdoor workplaces. The Commonwealth now has the opportunity to protect millions of our own constituents. 

Heat has long been recognized as a significant hazard and will only intensify with climate change

Extreme heat in outdoor and indoor work environments has been established as a workplace hazard for decades, with well-documented risks to workers across industries. In 1972, the National Institute for Occupational Safety and Health (NIOSH) first published criteria for OSHA to promulgate a federal standard. Despite decades of scientific and workplace research demonstrating the harm of occupational heat exposure, regulatory gaps still leave more than 50 million workers in America unprotected as global temperatures continue to rise with climate change. 

Indoor and outdoor workers in Virginia are at significant risk of heat-related disease, such as heat stroke, heat syncope, heat exhaustion, heat cramps, hyponatremia, heat rash, rhabdomyolysis and permanent organ damage. These illnesses often develop without obvious warning signs; symptoms can include rapid heart rate, lightheadedness, headache, dizziness, nausea, weakness, irritability, thirst, excessive sweating and decreased urine output. Ongoing exposure to hot conditions can exacerbate pre-existing health issues, diminish cognitive abilities and impair decision-making—making work environments much more dangerous for workers, their coworkers and the public. Hot working conditions also contribute to additional injuries from slippery sweat, the use of hot tools/equipment and issues with personal protective equipment and safety equipment. From 2023 to 2024, Virginia had 140 heat-related illnesses that led to days away from work, and in 2025, Virginia had more than 4,000 visits to emergency rooms due to heat-related illnesses. With 2026 being the hottest on record, the number of emergency visits could well exceed the 4,000 from 2025.

Virginia’s heat standard must emphasize prevention and be comprehensive.

A heat illness prevention standard should be proactive, not reactive. It must establish clear, preventative requirements that stop workers from dangerous heat exposure in the first place.  DOLI has the opportunity to set a strong model that requires employers to use evidence-based methods for evaluating heat exposure, implement effective control measures to address heat hazards, provide workers the protections and information they need to stay safe on the job and collect important information from employers through the agency’s recordkeeping authority to improve documentation of heat-related illness and awareness and target interventions. 

An effective standard that protects workers and addresses significant risk includes requirements for a written, comprehensive heat illness and prevention program with meaningful involvement of workers and their representatives; temperature thresholds that trigger employer actions; exposure monitoring (using WBGT to reflect actual risk from heat, humidity and air movement); the hierarchy of controls to implement feasible engineering and administrative measures; mandatory paid rest breaks; cool, clean and accessible water and shade; acclimatization; emergency response and planning; training; anti-retaliation protections; and strong recordkeeping requirements for immediate reporting of heat-related illness, a heat incident log and definition of heat-related illness for OSHA 300 logs. 

These requirements would ensure that control measures meant to reduce risk are actually effective, which requires some level of specificity for employers to follow, but still allow plenty of flexibility and adaptability for individual worksites. They also make it easier for DOLI to enforce. Virginia can look to and improve on other states with heat standard models such as Maryland, California, or Oregon.

No worker should ever face serious illness or death by going to work. Heat illness is preventable, and Virginia now has the opportunity to establish a strong and comprehensive Heat Illness Prevention Standard.

Thank you for your efforts to protect Virginian workers and their families.

Sincerely,

Doris Crouse-Mays

President, Virginia AFL-CIO