OSHA Heat Rule Faces Challenge in Congress
ILMA welcomes the advancement of the Heat Workforce Standards Act of 2025 (H.R. 6213) —legislation that represents meaningful progress in the effort to ensure that OSHA’s heat injury and illness rulemaking is precise, targeted and grounded in the operational realities of diverse work environments, including lubricant manufacturing.
Background
OSHA proposed a heat injury and illness prevention standard in August 2024 that would impose sweeping requirements on employers across virtually all industry sectors, from installation of on-site temperature monitoring equipment to highly prescriptive air movement and air conditioning mandates. The proposal uses a rigid framework with no meaningful accommodation for regional climate variation or industry-specific operational realities.
ILMA has been vocal in its opposition to this one-size-fits-all approach, which fails to account for the unique conditions of indoor manufacturing environments like lubricant plants and imposes disproportionate burdens on small businesses without adequate evidentiary justification. The Association has urged the agency to reconsider its proposal to granularly address meaningful occupational risks where data support regulation.
In addition to submitting written comments, last year, ILMA CEO Holly Alfano and Regulatory Counsel Jorge Roman testified before OSHA, urging the agency to withdraw the proposed rule. In their testimony, ILMA argued that the agency has not demonstrated that heat stress poses a significant risk warranting such broad federal intervention in the lubricants industry and that any future rulemaking must assess risk on a granular, sector-specific basis rather than relying on unsupported assumptions.
The Heat Workforce Standards Act of 2025
H.R. 6213, introduced by Representative Mark Messmer (R-IN) and supported by more than 60 co-sponsors, would prohibit OSHA from finalizing, implementing or enforcing its proposed standard or any similar standard. In other words, the bill would force OSHA’s heat rulemaking to be precise and sector-specific, ensuring that enforcement and compliance assistance resources are directed toward the most at-risk industries and workers rather than spread indiscriminately across all workplaces. Senator Bill Cassidy (R-LA) has introduced equivalent legislation in the Senate. ILMA joined a coalition earlier this year to support this legislative fix.
The bill’s advancement out of the House Committee on Education and Workforce is a meaningful step forward. ILMA encourages the full House of Representatives to take up and pass this legislation.
“Lubricant manufacturing facilities do not present the same heat risk profile as outdoor or heavy industrial worksites, and a regulation that treats them identically misses the mark,” said CEO Holly Alfano.
“ILMA takes heat safety seriously and actively supports members in building effective risk mitigation programs, but a rigid federal mandate that ignores operational realities and imposes disproportionate burdens across the board is not the answer,” Alfano added.
“The Association supports Congress in asserting its regulatory authority to ensure that occupational safety regulation in this area is grounded in flexibility, risk data, and respect for the operational diversity of the American industry,” said Regulatory Counsel Roman.
ILMA will continue to engage both OSHA and Congress to ensure that any heat illness prevention framework is evidence-based, appropriately scoped, and respectful of the distinct conditions and existing safety practices of the lubricant manufacturing sector. Members will be kept informed as the rulemaking and legislative processes develop.
Even without a final federal heat standard, OSHA is using its existing authority under the General Duty Clause to address heat-related workplace hazards. Lubricant manufacturers should review their occupational risk management programs to account for heat exposure risks.
