What Nevada’s rule requires
Nevada’s regulation, R131-24, defines occupational heat exposure by whether working conditions create a “reasonable likelihood” of heat illness, considering factors that include temperature, humidity, radiant heat, workload and protective clothing. The regulation does not set a single temperature at which protections begin, according to Nevada Current. Under the rule, employers required to maintain a written safety program must prepare a one-time job hazard analysis for relevant work conditions, as described in the approved regulation.
The regulation’s flexible approach leaves employers assessing the specific circumstances of a job. Nevada Current reports that business and industry groups have supported that flexibility, while regulators have said one temperature standard would not suit every job or industry. The outlet also reports that the rule does not set a single temperature at which protections begin.
What the complaint records show
An analysis commissioned by the Natural Resources Defense Council and conducted by Harvard T.H. Chan School of Public Health researchers examined 2,561 Nevada OSHA heat-complaint and referral records filed from January 2015 through November 2025, Nevada Current reported. In the researchers’ analysis, complaint counts began increasing at about 90°F across nearly all industries. The odds of a complaint were more than three times higher between 90°F and 100°F and nearly eight times higher at 105°F.
The analysis found that hotels, casinos and restaurants accounted for 23% of the records, retail for 14%, and warehousing and delivery for nearly 8%. More than 80% came from Clark County, according to Nevada Current. These are shares of the records analyzed, not estimates of all workers or heat illness incidents in those industries or places.
Complaints and inspections are separate measures
The Nevada Division of Industrial Relations’ FY2025 fourth-quarter complaint log lists complaints received separately from inspections conducted and complaints for which no inspection was conducted, according to its Advisory Council meeting materials. Complaint totals therefore are not inspection totals. The information cited here does not establish how often complaints led to inspections or citations.
The records leave gaps
Harvard researcher and analysis co-author Barrak Alahmad told Nevada Current that official complaint records likely miss some workers’ heat-related problems. Sara Evans, chair of SEIU Local 1107’s climate justice caucus, told the outlet that workers in small, nonunion or precarious workplaces may hesitate to report hazards for fear of retaliation. Evans also said unionized workers may be more likely to file complaints because they know their rights and have greater protection from retaliation. About 13% of Nevada private-sector workers are represented by unions, the outlet reported.
Alahmad told Nevada Current he began examining Nevada’s records after industry groups promoted the state’s rule as a possible national model. He said the analysis supports specific temperature thresholds, including triggers for water and rest breaks, and clear, data-based requirements. The analysis counts reports to OSHA; it does not establish the temperature at which an individual worker becomes ill or prove that a fixed trigger would prevent every complaint.
How other standards use temperature triggers
A separate study discussed by the Harvard T.H. Chan School of Public Health examined workplace injuries nationwide, not Nevada OSHA heat complaints. It found injury risk began increasing when the heat index reached 80°F and rose sharply above 90°F; the researchers estimated that about 28,000 heat-related workplace injuries go undetected nationally each year. Because the study measured injuries using a different dataset and method, its results are not a direct comparison with the Nevada complaint analysis.
The federal OSHA proposal described by Harvard would require access to water, shade and opportunities to cool down at a heat index of 80°F, and paid 15-minute breaks every two hours at 90°F. California’s heat illness prevention standard also uses an 80°F trigger and requires training, water, shade and planning, according to OSHA.
Nevada Current reported that the U.S. Small Business Administration’s Office of Advocacy asked the Department of Labor to use Nevada’s flexible approach in a federal rule, citing regulatory flexibility. The department intends to issue a revised proposal by the end of 2026 and expects to finalize a standard by October 2027, but those deadlines are not mandatory, the outlet reported. Alahmad told Nevada Current that the proposed 80°F requirement is not yet law and that he saw little appetite for adopting it.
Nevada’s Safety Consultation and Training Section maintains a public heat complaints dashboard covering reports from 2014 through August 2025, with breakdowns by region, month, industry and complaint source.
