OSHA's own math says its heat rule saves more than it costs. It's been stalled since 2024.

OSHA wrote the rule, ran the numbers, and the numbers said yes.▸ On August 30, 2024, the agency proposed its first-ever comprehensive heat standard, and its own Preliminary Economic Analysis put a number on the tradeoff: employers would pay about $7.8 billion a year to comply, and the rule would prevent enough deaths and injuries to be worth $9.2 billion a year — benefits outrunning costs by OSHA's own accounting. The informal public hearing on the rule concluded July 2, 2025, and the post-hearing comment window closed October 30, 2025. Since then: nothing. The rule hasn't been withdrawn. It also hasn't moved.

Federal rulemaking usually gets fought on whether the benefits are worth the cost.▸ OSHA's own analysis says this one clears that bar with room to spare.

The $7.8 billion annual cost — averaging $3,085 per covered establishment — buys water, shade, paid rest breaks, and acclimatization protocols for new and returning workers.▸ OSHA sets the benefit side against it in the same document: $7.31 billion a year in avoided deaths, valued using the Department of Transportation's standard value of a statistical life, plus $1.87 billion a year in avoided injuries and illnesses. Total: $9.18 billion — a rule that, on OSHA's own terms, returns more than it costs.

The benefit side of that math rests on a claim most people find hard to believe: that official heat-death counts are wrong by more than an order of magnitude.

The Bureau of Labor Statistics recorded 479 heat-related deaths from 2011 through 2022 — an average of about 40 a year, by OSHA's tally of that data.▸ But heat deaths are notoriously undercoded: a worker who collapses from heat stroke and later dies of cardiac arrest gets classified under cardiac arrest, not heat. OSHA concluded the true rate is undercounted by a factor of 14, putting the actual toll at an estimated 559 heat-related deaths a year. Against that corrected baseline, OSHA estimates its own proposed standard — cool water, shade, breaks, acclimatization — would be 95% effective, preventing 531 of those deaths annually. For scale: 531 is roughly a tenth of the 5,070 total fatal workplace injuries BLS counted across every cause in 2024, a year in which overall workplace deaths fell 4.0% from 5,283 in 2023.

The proposed standard has been in post-hearing review since October 2025, and the most recent entry in the federal government's unified regulatory agenda carries no target date for final action.▸ OSHA's separate heat-related National Emphasis Program — the enforcement directive that lets inspectors target heat inspections under the general duty clause in the absence of a specific standard — was reissued April 10, 2026, replacing a version that had just expired, and is scheduled to run for five more years. That keeps enforcement alive. It doesn't replace a rule. Employers who want a specific, litigable heat standard, and workers who want a legal floor rather than a discretionary citation, are both waiting on the same stalled docket.

Cost and benefit figures are OSHA's own preliminary estimates from the 2024 proposed rule and may change in a final rule, if one is ever issued; the agency has not published a supplemental or final economic analysis as of this writing.