Trent Cotney, Attorney & Partner, Adams & Reese
Roofing contractors and crews in Florida face a yearly safety crisis driven by extreme heat. As temperatures climb well above 100°F and humidity presses past 70 percent, roofers laboring on sun-soaked decks and exposed surfaces endure conditions that can quickly become life-threatening. Even routine work becomes hazardous when heat stress leads to dehydration, heat exhaustion or full heat stroke. OSHA reports that heat is the leading weather-related cause of workplace fatalities in the United States. In construction trades like roofing where prolonged exposure to sun and reflective surfaces is common, the need for robust heat
illness prevention strategies cannot be overstated.
OSHA estimates nearly 480 worker deaths from heat exposure occurred between 2011 and 2022, along with more than 33,000 reported heat-related illnesses demanding time away from work. However, experts caution that those figures dramatically understate the true scope of the problem. Heat-related illnesses often go unreported or are misclassified, particularly among subcontracted or migrant labor forces who may lack access to medical care or fear retaliation for reporting injuries.
Currently, OSHA relies on its General Duty Clause and an expanded Heat-Related Hazards National Emphasis Program (NEP) to inspect high-risk industries, including roofing, during heat waves. Even though a formal federal heat standard has not yet been finalized, OSHA continues issuing citations when inspectors determine employers have failed to provide adequate protection against recognized heat hazards. In Florida’s roofing sector, where outdoor labor and direct sun exposure are a given, proactive compliance is essential.
OSHA published its Notice of Proposed Rulemaking (NPRM) for a Heat Injury and Illness Prevention Standard on August 30, 2024. The proposed rule would require employers in construction and other sectors to implement a written Heat Illness and Injury Prevention Plan (HIIPP), monitor ambient conditions, provide drinking water, shaded or cooled break areas, acclimatization programs for new workers and mandatory rest and monitoring when the heat index exceeds specified thresholds (80°F initial trigger, 90°F high-heat trigger). The proposed rule would also require heat safety coordinators, training in heat illness symptoms, communication plans and emergency response protocols.
However, as of July 2025, the rulemaking remains pending. OSHA conducted its public hearing on the proposal from June 16 through July 2, 2025, and the post-hearing comment period remains open through September 30, 2025. Stakeholders from industry, labor, safety professionals and public interest groups provided testimony and OSHA may revise the rule prior to issuance of a final standard, which could arrive in late 2025 or early 2026. Until then, nothing yet has taken effect.
For Florida roofing employers, the safety implications are clear. Even before the standard is finalized, OSHA expects compliance through its NEP and the General Duty Clause. Given Florida’s climate, jobsites are inherently subject to heat hazard scrutiny. Contractors should immediately assess and implement best practices: provide clean, cool and accessible drinking water at the rate of one quart per hour per worker; ensure there are shaded or airconditioned rest areas near active work zones; rotate crews or limit exposure during peak hours; train supervisors and workers to recognize early symptoms of heat illness and document these safety measures thoroughly in written policies even if a formal standard is still pending.
Foreseeing the enhanced regulatory environment, adoption of a Heat Illness and Injury Prevention Plan now delivers dual benefits: it reduces worker harm and demonstrates good faith, a critical factor that can mitigate OSHA enforcement action and liability risk. Particularly on large roof jobs, subcontractors and crew leaders should be integrated into cooling schedules and communications, with shifts planned to avoid worst-case heat windows. Put protocols in place for monitoring vulnerable employees, including new hires or those with pre-existing conditions.
Heat illness does not discriminate and experienced veterans can succumb, especially when roofing materials absorb and radiate solar energy. As roofing professionals in Florida plan for extended seasons and more extreme temperature patterns, the fundamentals of heat illness prevention become non-negotiable safety essentials. By training crews, implementing prevention plans, providing resources and fully documenting actions, employers protect their workers and their business. OSHA is watching — and as Florida summers continue to intensify, the stakes couldn’t be higher.
The information contained in this article is for general educational information only. This information does not constitute legal advice, is not intended to constitute legal advice, nor should it be relied upon as legal advice for your specific factual pattern or situation.
Trent Cotney is a Partner and Construction Team Leader at the law firm of Adams & Reese and FRSA General Counsel. You can reach him at trent.cotney@arlaw.com or 866-303-5868.
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