January 14th, 2025

Public Comment to the U.S. Occupational Safety and Health Administration Regarding Heat in the Workplace

Ashley Otilia Nemeth

CLX Director of Programs Ashley Otilia Nemeth and Latino Justice PRLDEF Southeast Regional Managing Attorney Roberto Cruz submitted a public comment to the U.S. Occupational Safety and Health Administration (OSHA) regarding the proposed rule Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings.

The proposed standard would clarify employer obligations and the steps necessary to effectively protect employees from hazardous heat. The proposed standard would apply to all employers conducting outdoor and indoor work in sectors where OSHA has jurisdiction, with the ultimate goal of preventing and reducing the number of occupational injuries, illnesses, and fatalities caused by exposure to hazardous heat.

Relying on the best available science, existing state rules, and feedback from community partners, the public comment provided recommendations on how to revise the rule to better protect workers exposed to hazardous heat. CLX Director of Programs Ashley Otilia Nemeth supported this effort in her capacity as Supervising Attorney for the Earth Rights Research & Action (TERRA) Clinic at NYU Law and was assisted by law students Joelle Besch, Andrew Liu, and Elizabeth Marcinkowski.