Arizona’s New Heat Safety Executive Order: What to Know as Temperatures Rise

Quick Hits

• Arizona Governor Katie Hobbs recently signed Executive Order 2025-09 to enhance worker safety amid rising summer temperatures.
• The Industrial Commission of Arizona’s Division of Occupational Safety and Health will establish a Workplace Heat Safety Task Force to draft guidelines by the end of 2025.
• The new guidelines, set to be completed by December 31, 2025, will provide detailed, industry-specific recommendations for managing heat risks in the workplace.

Executive Order 2025-09 builds on Governor Hobbs’s Extreme Heat Preparedness Plan, launched in 2023, which aims to address the increasing temperatures in Arizona. ADOSH also implemented its heat State Emphasis Program (SEP), allowing inspectors to focus on heat-related injury and illness prevention, such as ensuring access to water, rest, and shade. Together, the preparedness plan, SEP, and EO position Arizona as an aggressive advocate against heat illness. In contrast, federal Occupational Safety and Health (OSHA) standards have only gone as far as to recognize heat as a safety hazard, but no specific guidelines have been implemented.

The task force’s guidelines, set to be completed by December 31, 2025, will clarify what constitutes a heat safety hazard under the Occupational Safety and Health (OSH) Act’s General Duty Clause. These guidelines will inform how ADOSH’s compliance safety and health officers (CSHO) enforce heat safety standards. While the specifics of the guidelines are still being developed, the task force will use heat data compiled for the SEP to go beyond basic recommendations like water, rest, acclimatization, and shade. The guidelines will offer detailed, industry-specific recommendations to help employers develop practical and effective heat safety plans.

Once completed, the guidelines will be recommended for approval by the ICA, with the intent to implement them by summer 2026. Therefore, the EO does not have an immediate impact on employers or their responsibilities under the OSH Act’s General Duty Clause. In the meantime, ADOSH CSHOs will continue to evaluate worksites for potential heat hazards during inspections, in line with the SEP. Employers may want to prepare to address heat-related hazards by developing safety programs, consistent with the recommendations set forth by the SEP, in advance of the implementation of the new guidelines. Employers can also sign up for email notifications to receive updates directly from ADOSH as the task force progresses.

Ogletree Deakins’ Phoenix office and Workplace Safety and Health Practice Group will continue to monitor developments and provide updates on the Arizona and Workplace Safety and Health blogs as additional information becomes available.

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