A Hot California Summer Is Coming — Are You Prepared?

California is bracing for another year of intense summer heat, and regulators will be paying close attention to how employers respond. For HR leaders, that means heat safety isn’t just about checking compliance boxes — it’s about ensuring protections are visible, accessible, and consistently applied across the worksite.

A key enforcement trend is that many violations stem from breakdowns in the most basic protections, not complex regulatory misunderstandings. The simple provisions of water and shade continue to drive a large share of citations, according to Karen Tynan, an attorney with Ogletree Deakins in Sacramento. Her team regularly reviews OSHA data, and she notes that while some employers are cited for technical issues like failing to keep a plan on-site, “most often we see citations that allege a lack of shade or lack of access to water that is potable, suitably cool and close to the workers.”

This pattern reveals a gap between written policies and day-to-day execution. Even when employers have compliant plans, they may fall short in making those protections usable in practice — something inspectors can quickly identify during a site visit.

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Daily Reinforcement — Not Just Written Policies

Regulators increasingly expect heat safety to show up in routine workplace interactions, not just in a binder. Tynan underscored that “reviewing heat illness symptoms and procedures at morning safety meetings and during employee briefings is critical,” pointing to these touchpoints as evidence that a plan is actually in use.

She further emphasized that engagement itself is part of compliance, explaining that “employer and employee engagement around reminders and updates is an important part of what Cal/OSHA refers to as ‘implementing your heat illness prevention plan.’” In other words, consistent communication is not optional, but a core requirement.

Visible reminders can reinforce those expectations. “We like to see signage or other communications reminding employees to drink water and to take preventative breaks,” Tynan said. Even simple interventions can help normalize safe behaviors.

For HR teams, this means embedding heat safety into the cadence of the workday through supervisor-led check-ins, standardized messaging, and clear expectations that prioritize safety alongside productivity.

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The Importance of Recordkeeping 

When enforcement actions arise, the quality of an employer’s documentation often becomes the deciding factor. “Training documentation is such an important detail,” Tynan stressed. This is particularly the case at the onboarding stage. If employees receive heat illness training, “employers need to make sure that is documented,” she said. 

That obligation extends across the employee lifecycle. “Annual training, refresher training, and supervisor training must be accurately and effectively documented whether it’s an electronic system or papers kept in a file,” Tynan said. Gaps or inconsistencies in these records can weaken an employer’s ability to demonstrate compliance.

Beyond training, employers must also track environmental conditions and operational practices. Tynan pointed out that “for the indoor heat standard, the trigger temperature is 82 degrees Fahrenheit,” making it important to document when that threshold is reached. Without those records, it becomes difficult to show that appropriate steps were taken.

She also highlights the importance of documenting how water is managed on-site. “For both indoor and outdoor, documenting the water replenishment process is helpful,” she explained, adding that “recording reimbursement as well as how water is provided at a site can make a substantial difference during a Cal/OSHA inspection.” These apparently small details help demonstrate that access to water is not just theoretical, but consistently maintained.

Shifting Indoor Heat Rules 

The expansion of indoor heat standards is changing the compliance landscape, particularly in industries where heat exposure is less obvious but still significant. Tynan explained that while employers will recognize familiar requirements — such as providing water and encouraging breaks — “there are some substantial differences,” including “trigger temperatures, high heat procedures (none for indoor), and control measures.”

One of the most notable shifts is the expectation that employers address heat at its source when possible. “The indoor standard does require employers to implement engineering controls when feasible to try to lower the temperature,” Tynan said. This moves compliance beyond training and policy into physical workplace conditions.

Inspection trends reflect that shift. Tynan observed that in “the past year or so, indoor inspections typically focus on warehouse locations, manufacturing where heat processes are used, and restaurants,” signaling where regulators are concentrating their efforts.

For HR leaders, this evolution requires closer coordination with operations and facilities teams, particularly when evaluating whether engineering controls are feasible and sufficient.

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Focusing on Practical Protections 

Ahead of peak temperatures, the most effective compliance strategy is often the most straightforward: ensure employees are trained, supported, and equipped with the resources they need. Tynan advised employers to “train employees on your heat illness prevention plan” so they understand both the procedures and the risks.

That training should enable workers to identify early warning signs. It is important that employees can “recognize those symptoms in themselves and their co-workers,” allowing for faster intervention, Tynan said. 

At the same time, access to core resources must be consistent and reliable. Employers should “provide water to employees” and “make sure workers have access to shade or a recovery area,” Tynan said. These steps directly reduce the likelihood of heat illness.

Employers should take time to evaluate how those resources are delivered in practice, reviewing “methods and processes for ensuring adequate and proper water for employees” and confirming “how workers will access shade or a rest area,” according to Tynan. 

As temperatures climb, compliance will be judged not by the existence of a policy, but by how effectively it translates into daily protections. Organizations that focus on execution — reinforcing habits, maintaining strong documentation, and adapting to evolving indoor standards — will be best positioned to meet regulatory expectations and safeguard their workforce.