| Action | NOIRA for Heat Illness Prevention Standard |
| Stage | NOIRA |
| Comment Period | Ends 9/23/2026 |
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Virginia has an opportunity to close a significant gap in worker protection by requiring the use of Wet Bulb Globe Temperature (WBGT) as the official metric for evaluating the impacts of heat in the workplace. I urge the Commonwealth to adopt WBGT-based thresholds as the basis for setting work/rest schedules
This is by no means a novel or untested approach. Employers, regulators, and safety organizations across the country already rely on it. OSHA references it in guidance materials, the American Industrial Hygiene Association adopts it in creating their professional standards, and the American Academy of Pediatrics endorses it for protecting children involved in athletics. High school athletic associations in many states have built their own heat safety guidelines around WBGT’s flag-based alert system, giving Virginia’s employers an already proven, straightforward framework for workplace decision making.
The principal justification for this adopting WBGT comes down to accuracy. Unlike air temperature readings or conventional heat index calculations, which use a limited set of inputs, WBGT incorporates four separate environmental factors at once: temperature, humidity, wind speed, and solar radiation. Because heat-related illness in the human body is a product of all of these variables taken together, as opposed to any one variable alone, WBGT outperforms these simpler metrics in analyzing actual physiological risk for people working outdoors, in a climate that continues to produce hotter and hotter weather patterns.
It’s incredibly important to get this right. No other weather hazard kills more people in the U.S. than extreme heat, and warming temperatures, higher humidity levels, and more frequent and severe heat waves are all expected to make conditions more dangerous for Virginia’s workers in the coming years
Aside from the direct health benefits, there’s also a strong economic justification for this metric. A uniform, evidence-based system for monitoring and limiting heat exposure helps prevent sudden workplace absences, expensive work stoppages, and reduces the chances that outdoor activities or job sites need to cease operations entirely due to unsafe heat conditions. Protecting our workers and maintaining workplace productivity are not mutually exclusive.
For all these reasons, I strongly urge that Virginia move forward with WBGT-based heat safety standards.