Harvard analysis finds Nevada worker heat complaints climb near 90°F, challenging the state's no-threshold heat rule

What happened

A new analysis of worker heat complaints in Nevada is challenging the idea that the state's heat protection rule should serve as a template for the rest of the country, Nevada Current reported. The study was commissioned by the Natural Resources Defense Council and carried out by researchers at the Harvard T.H. Chan School of Public Health. It was released last month.

Business and industry groups have pointed to Nevada's approach as a national model. According to Nevada Current, the analysis suggests that the state's own complaint records point in a different direction.

How Nevada's heat rule works

Nevada does not set a specific temperature at which employers must begin protecting workers from heat. Instead, the standard applies when conditions create a reasonable likelihood of heat illness. Employers must prepare their own one-time, written job hazard analysis of conditions that could expose workers to heat illness.

Nevada Current noted that, in practice, two construction crews doing the same job on the same day could face different temperature thresholds. Employers and industry groups say that flexibility keeps regulations from burdening businesses and allows standards to be tailored to different climates.

What the analysis found

Complaints climb at about 90°F

Researchers reviewed 2,561 records of heat complaints and referrals logged by Nevada OSHA from Jan. 2015 through Nov. 2025. They found that complaints across almost every industry began rising at about 90°F air temperature, which Nevada Current reported contradicts Nevada regulators' claim that no single threshold works. 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 at the Harvard school and a co-author of the study, said he was motivated to do the work after industry groups held up Nevada's standard as a possible national model. "What we showed is that, yeah, even in Nevada, these thresholds exist," he told Nevada Current. He said the state model should include basic thresholds that, when exceeded, mandate water and rest breaks.

Most complaints come from Clark County

Just over 80% of the complaints came from Clark County. Nearly half came from three sectors: hotels, casinos and restaurants at 23%, retail at 14%, and warehousing and delivery at nearly 8%. Readers can follow more workplace and community safety coverage in our public safety section.

Concerns about underreporting

Alahmad said official records almost always undercount heat-related problems among workers. Sara Evans, chair of SEIU Local 1107's Climate Justice Caucus, said workers at small, nonunion or precarious jobs may never report hazards because they fear retaliation. Only about 13% of private sector workers in Nevada are represented by unions, according to Nevada Current.

Evans called the reasonable likelihood standard subjective and said it gives employers too much discretion. "It's super alarming that the only people that are reporting heat-related concerns at work are usually people within unions," she said.

The federal debate

Temperature thresholds were central to federal OSHA hearings last year and were unpopular with employers and industry groups, Nevada Current reported. In September, the U.S. Small Business Administration Office of Advocacy wrote to the U.S. Department of Labor urging that any new federal rule be modeled on Nevada's, citing the need for flexibility.

The current federal OSHA proposal would require heat protections once conditions reach a heat index of 80°F. Alahmad said that is not the rule now and that there does not appear to be an appetite for it under the current administration.

What to watch next

• The Department of Labor has said it intends to publish a revised federal heat proposal by the end of the year, though the deadline is not mandatory.
• The Department of Labor expects a finalized heat standard by October 2027, a timeline that is also not binding.
• Whether the revised federal proposal keeps the 80°F heat index trigger or follows the SBA Office of Advocacy's call to model the rule on Nevada's approach.