Nearly half of heat complaints in Nevada came from just three sectors: hotels, casinos and restaurants; retail; and warehousing and delivery. (Stock photo via Canva)
Business and industry groups have held up Nevada’s worker heat protection standard as a national model, but Nevada’s own workers say otherwise, according to an analysis released last month.
In Nevada, there is no specific temperature at which employee heat protections are required to start. Instead, employers have sole discretion to decide when to provide heat protections for their workers.
Nevada’s heat standard kicks in when working conditions create “the reasonable likelihood that heat illness could occur” and requires employers to prepare their own “one-time, written job hazard analysis to assess working conditions that may cause occupational exposure to heat illness.”
In practice, that means two construction crews performing the same task on the same day could be subject to different temperature thresholds.
Employers and industry groups argue that flexibility is needed to ensure regulations don’t burden businesses, while allowing more tailored standards across states with different climates.
But a new analysis commissioned by the Natural Resources Defense Council and conducted by researchers at the Harvard T.H. Chan School of Public Health calls that model into question.
The analysis — which reviewed 2,561 records of heat complaints and referrals logged by Nevada OSHA from Jan. 2015 through Nov. 2025 — found that workers’ heat complaints across almost every industry in Nevada start climbing at about 90°F air temperature, contradicting Nevada regulators’ claim that no single threshold works.
The analysis found that the odds of a complaint more than tripled between 90°F and 100°F, and were nearly 8 times higher at 105°F.
Barrak Alahmad, a senior research scientist for the Harvard T.H. Chan School of Public Health, said that decades of scientific evidence show that thresholds are a foundational component of an effective heat standard.
“We don’t think this should be the model going forward, and that the Nevada model, in fact, if anything, should have some basic thresholds that, when exceeded mandate water rest breaks and basic stuff,” Alahmad said.
Alahmad, who co-authored the study, said he was motivated to analyze Nevada’s heat complaints after industry groups held up Nevada’s heat standard as a possible national model.
That findings reveal there is a data-driven threshold when working in extreme heat without protections becomes dangerous, said Alahmad.
“What we showed is that, yeah, even in Nevada, these thresholds exist,” Alahmad said.
Temperature thresholds were at the center of federal OSHA hearings last year, and proved unpopular among employers and industry groups.
In September, the U.S Small Business Administration Office of Advocacy sent a letter to the U.S. Department of Labor, asking federal regulators to model any new federal regulations on Nevada’s model, citing the need for “flexibility.”
The Department of Labor indicated it intends to publish a revised proposal by the end of the year, with expectations for a finalized standard by October 2027. Although the deadlines are not mandatory.
Under the current OSHA proposed standards, when workplace conditions reach a heat index of 80°F, employers would be required to implement heat hazard protection. However, Alahmad said “that is not the rule of the land right now, and there doesn’t seem to be an appetite for it with the current administration.”
Alahmad said his analysis revealed the need for clear state and federal workplace heat standards based on specific, data-driven temperature thresholds.
Nearly half of heat complaints in Nevada came from just three sectors: hotels, casinos and restaurants (23%), retail (14%), and warehousing and delivery (nearly 8%). Just over 80% of complaints came from Clark County, Nevada’s most populous region and home to Las Vegas.
But official records almost always undercount heat-related issues among workers, Alahmad said.
Many workers, particularly those in small, nonunionized, or precarious workplaces, may never report dangerous heat hazards out of fear of retaliation, said Sara Evans, the chair of SEIU Local 1107’s Climate Justice Caucus.
Evens argued Nevada’s regulation focused on “reasonable likelihood” is subjective and allows too much employer discretion, adding that workers without union support may be less likely to report concerns because of retaliation fears and economic pressures.
Unionized workers are more likely to lodge health and safety complaints with OSHA than nonunionized workers, likely because they have a better understanding of their rights on the job and are better protected from illegal retaliation by employers, said Evans.
Only about 13% of private sector workers in Nevada are represented by unions.
Evans said she got involved with advocating for stronger heat protections in Nevada after seeing that Nevada’s standards were not enough to protect more vulnerable workers.
“It’s super alarming that the only people that are reporting heat-related concerns at work are usually people within unions,” Evans said. “We don’t even know what’s going on in these non-unionized areas.”
