# Heat Illness Prevention Plan Template for NEMT Companies: Water, Cool-Down Breaks, Hot Vans, and State Rules

Canonical URL: https://nemtguide.com/templates/heat-illness-prevention-plan/ · Updated 2026-10-30

A heat illness prevention plan template is a fill-in written plan that keeps drivers safe in heat: free water in every van, cool-down rest, working air conditioning, a close watch on new drivers, and a 911 plan. California, Oregon, Washington, Maryland, and Nevada require a written heat plan once their rules cover your drivers. Federal OSHA has no final heat standard as of October 2026.

- Find your state trigger first: 80 degrees outdoors in Washington, a heat index of 80 in Oregon and Maryland, and 82 degrees inside a van in California.
- Give every driver free, cool water, at least 1 quart for each hour of the shift, or a way to refill it during the route.
- A van parked in the sun with the air off is not a cool-down spot. A van running with working air conditioning is.
- Watch every new driver, and every driver back after 7 or more days off, closely for their first 14 days of hot routes.
- Check the air conditioning on every pre-trip inspection, and pull a van whose air fails until it is fixed.

A driver loads a power chair at a dialysis center curb at 3 p.m. in July, walks the rider inside, and climbs back into a van whose air conditioning quit an hour ago. Five states now require a written plan for days like that one, and federal OSHA uses its general duty clause to cite heat hazards. This template is that plan for a NEMT company: who runs it, when it switches on in your state, water, cool-down rest, air conditioning failures, new drivers, emergencies, training, and a yearly review.

## How to use this template

1. **Find your state's trigger** in the table under [Which heat rule reaches your vans](#which-heat-rule-reaches-your-vans) and write it in Part 2. In a state with no heat rule, a heat index of 80 degrees is a sound starting point: it is the trigger in Oregon and Maryland and the one OSHA proposed in 2024.
2. **Name one person who runs the plan** in Part 1, usually the owner or the lead dispatcher. Nevada's rule requires a designated person, and OSHA's 2024 proposal would call this person a heat safety coordinator.
3. **Fill in Parts 3 to 7** with what your drivers really do: where the water rides, where they cool down between trips, and who answers the phone when the air fails.
4. **Put the plan where your state wants it.** California lets it sit inside your [Injury and Illness Prevention Program](https://nemtguide.com/templates/california-iipp/). Washington requires the outdoor heat program inside your accident prevention program, and Part 7 of the [Washington accident prevention program template](https://nemtguide.com/templates/washington-accident-prevention-program/) already is that plan. Nevada wants it in your written safety program.
5. **Write it in the languages your drivers read.** California requires English and the language most of your employees understand.
6. **Train everyone before the first hot shift** and record it in Part 8. Washington, Oregon, and Maryland require the training again every year.
7. **Review it every spring and after any heat illness** in Part 9. Maryland requires retraining right after any incident involving a suspected or confirmed heat illness.

This plan protects your employees. For riders on hot days, which trips run and how you tell the broker, use your [NEMT bad weather policy](https://nemtguide.com/guides/nemt-bad-weather-policy/).

## The template

### Part 1: Plan details and who runs it

| Field | Entry |
|---|---|
| Company name | |
| Effective date | |
| Plan lead, with authority to stop a route or pull a van: name, title, phone | |
| Backup plan lead | |
| Heat rule we follow (state and section) | |
| Where this plan is kept (each van, dispatch, inside our IIPP or safety program) | |
| Languages it is written in | |
| Approved by the owner, signature and date | |

### Part 2: When this plan switches on

| Level | Our trigger | What changes |
|---|---|---|
| Heat plan on | Heat index or temperature of ____ degrees where drivers work | Water, cool-down rest, and close watch on new drivers start (Parts 3, 4, and 6) |
| High heat | ____ degrees | Dispatch checks in with each driver every ____ minutes, and the rest schedule in Part 4 starts |
| Heat wave day | Forecast high at or above our trigger and at least 10 degrees above the average high of the past 5 days | Dispatch checks in with every driver, not only new ones |
| Air conditioning fails in a van | Any day at or above our trigger | The steps in Part 5 start at once |

How we check the heat each morning and at midday: ______ (National Weather Service forecast, the OSHA-NIOSH Heat Safety Tool app, or a thermometer in the van).

### Part 3: Water

| Item | Our procedure |
|---|---|
| How much | Free, cool drinking water for each driver: at least 1 quart (32 ounces) for each hour of the shift, or a starting supply plus a way to refill |
| Where it rides in the van | ______ (for example, a cooler strapped down behind the driver's seat, clear of the lift and the aisle) |
| Where drivers refill | ______ |
| Water for riders | Kept apart from driver water: ______ |
| Reminders | Dispatch reminds drivers to drink small amounts often on heat plan days |

### Part 4: Shade and cool-down rest

| Item | Our procedure |
|---|---|
| Where a driver cools down | A van running with working air conditioning, or a cool indoor spot at the stop: ______. A van sitting in the sun with the air off does not count. |
| When | Any time a driver feels the need. A driver who takes one is asked about symptoms and stays until they pass, never less than 5 minutes plus the time to get there. |
| Pay | Cool-down rest is paid work time |
| High heat rest schedule | ______ minutes every ______ hours at ______ degrees, no less than our state's minimum |
| Curb work in direct sun | After a long load, a ramp wait, or a door-through-door walk on a day of ______ degrees or more, the driver cools down before the next pickup |

### Part 5: Air conditioning, and what to do when it fails

| Check | When | Who | Passes when |
|---|---|---|---|
| Front and rear air blow cold | Every pre-trip inspection | Driver | Cold at the rear within ______ minutes |
| Cabin thermometer reading | Each stop on heat plan days | Driver | Below ______ degrees |
| Air conditioning repair or recharge | Each repair | Fleet lead | Van stays out of service until fixed |

When the air conditioning fails with riders on board:

1. The driver calls dispatch at once with the exact location and the number of riders on board.
2. Dispatch sends the nearest working van and decides which riders move first: older riders and riders on dialysis or oxygen come first.
3. No rider waits in a parked van. The National Weather Service warns never to leave disabled adults in a parked vehicle, says heat illness can set in on a mild day in the 70s, and says cracked windows barely slow the heating. Follow the steps in [what to do when a NEMT van breaks down](https://nemtguide.com/guides/nemt-vehicle-breakdown/) to move riders.
4. The driver and dispatcher watch every rider, and the driver, for the signs in Part 7.
5. The van comes out of service until the air conditioning is fixed, and the failure goes in Part 9.

California only: when a van without working air conditioning reaches 87 degrees by temperature or heat index with a driver in it, we measure and record the heat and use controls to bring it down. We keep these records 12 months or until the next measurements, whichever is later.

| Date and time | Van and location | Temperature or heat index, whichever is higher | What we did to bring it down |
|---|---|---|---|
| | | | |
| | | | |
| | | | |
| | | | |

### Part 6: New and returning drivers

We closely watch, for 14 days, any driver new to hot routes and any driver back after 7 or more days away. Their first days get shorter routes or more breaks: ______.

| Driver | First hot shift or return date | Watched by | How (ride-along, call every ____ minutes, buddy) | 14 days done |
|---|---|---|---|---|
| | | | | |
| | | | | |
| | | | | |
| | | | | |
| | | | | |

### Part 7: Signs of heat illness and what to do

| Signs | What the driver or dispatcher does |
|---|---|
| Heat stroke: confusion, slurred speech, passing out, seizures, hot dry skin or heavy sweating | Call 911 at once and stay with the person. Move them somewhere cool and cool them fast with cold water, wet cloths, or ice on the head, neck, armpits, and groin. |
| Heat exhaustion: headache, nausea, dizziness, weakness, irritability, thirst, heavy sweating | Stop work, move to a cool place, sip water, and cool the head, face, and neck with cold water. Get a medical check, and call 911 if care is not close. |
| Fainting or dizziness after standing | Sit or lie down somewhere cool and slowly drink water or a sports drink |
| Heat cramps | Rest somewhere cool, drink water or a sports drink every 15 to 20 minutes, and get medical help if cramps last more than an hour |
| A driver feels sick with riders on board | Pull over where it is safe, call dispatch, and call 911 for any heat stroke sign. Dispatch sends a relief driver and calls the broker. |

Dispatch phone: ______. A driver who calls 911 gives the exact address or cross streets, and dispatch sends someone to meet the ambulance when the stop is hard to find. No one with symptoms is left alone or sent home without first aid. No one is punished for reporting symptoms or taking a cool-down rest.

### Part 8: Training record

Topics, before the first hot shift and every year: what raises heat risk (age, health, medicines, not being used to heat, hard work in the sun), the water, rest, and cool-down rules in this plan, drinking small amounts often, up to 4 cups an hour, getting used to the heat, the signs and first aid in Part 7, reporting symptoms right away, and how to call 911 and give directions. Supervisors and dispatchers also learn how to read the forecast, respond to heat advisories, and run Part 5.

| Employee name or ID | Date | Language | Topics covered | Trainer |
|---|---|---|---|---|
| | | | | |
| | | | | |
| | | | | |
| | | | | |
| | | | | |
| | | | | |

### Part 9: Yearly review and heat log

We review this plan every ______ (month, before the hot season) and after any heat illness, air conditioning failure with riders on board, or near miss.

| Date | What happened, or yearly review | What we changed | By |
|---|---|---|---|
| | | | |
| | | | |
| | | | |
| | | | |
| | | | |

## Which heat rule reaches your vans

Five states have heat rules that can reach a NEMT driver: California, Oregon, Washington, Maryland, and Nevada. Each reaches the time a driver spends outside the van, and each treats a van whose air conditioning fails differently from one whose air works. Minnesota's rule covers indoor work, Colorado's covers farm work, and New Mexico's is still a proposal.

| State | When the rule applies | Does the van count |
|---|---|---|
| California | Outdoors: always, with shade required over 80 degrees. Indoors: 82 degrees or more. | Yes. A van is an indoor workplace, and broken air removes the 15-minute exception. |
| Oregon | Heat index of 80 or more, indoors or out (since June 15, 2022) | Drivers mostly in air-conditioned vans, outside 15 minutes an hour or less, are exempt |
| Washington | Outdoors at 80 degrees or more for over 15 minutes an hour (since July 17, 2023) | A cab may count as outdoors when air conditioning does not manage its temperature |
| Maryland | Heat index of 80 or more, indoors or out (since September 30, 2024) | Exempt while ventilation or a fan keeps the heat index under 80 |
| Nevada | Employers with more than 10 employees, for jobs with over 30 minutes of heat an hour (enforced from April 29, 2025) | Exempt while climate control works properly |
| Minnesota | Indoor work above set heat limits | Indoor workplaces only, and vehicles are not named |
| Colorado | Agricultural work at 80 degrees or more | Farm work only |

### California

California has two rules, and a NEMT driver works under both. The indoor rule, [8 CCR 3396](https://www.dir.ca.gov/title8/3396.html), operative July 23, 2024, defines indoor as a space under a ceiling and enclosed by walls, doors, windows, or other barriers, whether open or closed. That describes a van, and the rule names vehicles in its exceptions. It applies at 82 degrees with employees present. Short exposures of less than 15 minutes an hour between 82 and 95 degrees are excused, but not in vehicles without effective and functioning air conditioning. At 87 degrees by temperature or heat index, you must measure, record, and control the heat. Vehicles with working air conditioning skip the measuring step but not the controls.

Everything that is not indoor falls under the outdoor rule, [8 CCR 3395](https://www.dir.ca.gov/title8/3395.html): loading at the curb, walking a rider to the door, waiting at the yard. It requires fresh, free, suitably cool water, enough for 1 quart per employee per hour, and shade when it is over 80 degrees. A car sitting in the sun is not shade unless it is running with air conditioning. A driver who takes a cool-down rest is watched for symptoms and is not ordered back for at least 5 minutes plus the time to reach the shade. On a heat wave day every employee is closely watched. Passenger transportation is not on the list of industries that must follow the extra high-heat procedures at 95 degrees.

Both rules require a written plan in English and in the language most of your employees understand, and both let you put it in your IIPP. A new employee assigned to a hot work area, 87 degrees or more indoors, is closely watched for the first 14 days.

### Oregon

[OAR 437-002-0156](https://osha.oregon.gov/OSHARules/div2/div2J.pdf) applies whenever an employee works where the heat index is 80 degrees or more, indoors or out. It exempts exposures of no more than 15 minutes in any hour, and buildings whose ventilation keeps the heat index under 80. Oregon OSHA's questions and answers (May 2023) say employees who spend most of the day inside air-conditioned vehicles, and are not exposed to excessive heat for more than 15 minutes in an hour, are fully exempt. Once loading and door-through-door help pass 15 minutes an hour, the rule applies.

At a heat index of 80, provide shade and enough cool or cold water for up to 32 ounces an hour per employee. At 90, keep reliable contact with drivers working alone, name someone at each worksite who can call for emergency medical services, and follow a written rest schedule. The simplest option in the rule starts at 10 minutes every 2 hours at a heat index of 90 and 20 minutes every hour at 95. Employers whose employees do only rest or light work are exempt from most of the rule below a heat index of 90. The rule's appendix lists driving a car as light work but pushing and pulling light carts as moderate, so do not count on that exemption if your drivers push wheelchairs. You also need a written acclimatization plan, a written heat plan, training every year before heat exposure, and a record of the most recent training for each employee.

### Washington

Washington's outdoor heat rule applies at 80 degrees (52 degrees in nonbreathable clothing) when an employee is required to work outdoors for more than 15 minutes in an hour ([WAC 296-62-09510](https://app.leg.wa.gov/WAC/default.aspx?cite=296-62-09510)). A vehicle cab may count as outdoors when air conditioning or other engineering controls do not manage its temperature ([WAC 296-62-09520](https://app.leg.wa.gov/WAC/default.aspx?cite=296-62-09520)). The program goes inside your accident prevention program, cool-down rest is paid, and at 90 degrees drivers get mandatory rest of 10 minutes every 2 hours unless air conditioning or scheduling keeps their exposure under 90. The [Washington accident prevention program template](https://nemtguide.com/templates/washington-accident-prevention-program/) explains how the rule reaches a van and holds the full plan, so use its Part 7 instead of this template.

### Maryland

[COMAR 09.12.32](https://www.labor.maryland.gov/labor/mosh/09.12.32.pdf), in effect since September 30, 2024, applies when work, indoors or out, exposes employees to a heat index of 80 degrees or more. It does not apply to vehicles whose ventilation system or fan keeps the heat index below 80, to exposures of 15 consecutive minutes or less in an hour, or to emergency operations. What it requires:

- **Monitoring.** Track the heat index through the shift with your own readings, National Weather Service data, or the NIOSH heat app.
- **A written plan** with 13 listed elements, from water and rest breaks to emergency response, available to employees and to MOSH on request.
- **Acclimatization** for up to 14 days for any employee newly exposed to heat or back after 7 or more consecutive days away, on a written schedule. One option the rule names raises exposure gradually over 5 to 14 days, by no more than 20 percent a day.
- **Water.** At least 32 ounces per hour for each exposed employee, free.
- **High heat at a heat index of 90.** Rest of at least 10 minutes every 2 hours, or 15 minutes every hour above 100, unless other cooling measures protect employees as well. Rest is taken in shade, and drivers are checked by phone, radio, or a buddy.
- **Training** before the first exposure, every year, and right after any heat illness incident, with records kept 1 year.

### Nevada

Nevada's heat regulation, [R131-24](https://www.leg.state.nv.us/Register/2024Register/R131-24AP.pdf), became effective when filed on November 15, 2024, and Nevada OSHA began enforcing it on April 29, 2025. It covers employers that must keep a written safety program, which means more than 10 employees. They do a one-time written job hazard analysis listing every job in which most employees are exposed to heat for more than 30 minutes of any hour, not counting breaks. If a job qualifies, the safety program adds water, rest for anyone showing symptoms, a way to cool down, monitoring, training, emergency procedures, and a designated person who can get emergency medical services to a sick employee. Monitoring is not required while loading or unloading a vehicle that runs on public highways.

The analysis, plan, and training do not apply to employees working in a climate-controlled space, including a motor vehicle with a properly functioning climate control system. When the system fails, you must make a good faith effort to fix it as soon as practicable and protect employees from the heat until it works. State law keeps Nevada OSHA's authority out of working conditions in motor vehicles operating on public highways (NRS 618.315), so in Nevada the rule matters most for curb work, the yard, and the office. Nevada OSHA's guidance (January 29, 2025) adds that employers with 10 or fewer employees must still protect workers from recognized heat hazards. Its offices are at 702-486-9020 in Las Vegas and 775-688-3700 in Reno.

### Minnesota, Colorado, Arizona, New Mexico, and every other state

- **Minnesota.** [Rule 5205.0110](https://www.revisor.mn.gov/rules/5205.0110/) limits indoor heat by wet bulb globe temperature, a measure that adds humidity and radiant heat, with a two-hour average limit of 86 degrees for light work, and requires training for exposed employees. It covers indoor workplaces and does not name vehicles.
- **Colorado.** The heat protections in 7 CCR 1103-15, last revised effective February 1, 2026, apply on days when a worksite for agricultural work reaches 80 degrees. They do not reach a ride company.
- **Arizona.** The governor's [Executive Order 2025-09](https://azgovernor.gov/office-arizona-governor/executive-order/2025-09) of May 22, 2025 asked ADOSH to form a task force to recommend heat guidelines for employers by December 31, 2025, for the Industrial Commission of Arizona to approve. The order itself created no rule.
- **New Mexico.** The state's job safety bureau has [proposed a heat rule](https://www.env.nm.gov/occupational_health_safety/heat-illness-and-injury-prevention/) (11.5.7 NMAC), but it is not in force. On July 24, 2026 the bureau asked to move the adoption hearing from September 21, 2026 to the week of March 22, 2027, and said it will keep enforcing the general duty clause against heat hazards until then.
- **Everywhere else.** Where no state heat rule applies, federal OSHA or your state plan can still cite a serious heat hazard under the general duty clause. A written plan you follow is your best evidence.

## Where the federal OSHA heat rule stands

There is no final federal heat standard as of October 30, 2026. OSHA proposed one on August 30, 2024 ([89 FR 70698](https://www.federalregister.gov/documents/2024/08/30/2024-14824/heat-injury-and-illness-prevention-in-outdoor-and-indoor-work-settings)). Comments closed January 14, 2025, an informal hearing ran from June 16 to July 2, 2025, and post-hearing comments closed October 30, 2025. The 2026 regulatory agenda lists a supplemental proposal for December 2026 and a final action for October 2027.

What the 2024 proposal would do, if adopted as written:

- Start protections at a heat index of 80 degrees and add high-heat steps at 90.
- Treat vehicles driven outdoors as outdoor work areas unless air conditioning consistently keeps the cabin below 80 degrees.
- Require a written plan from employers with more than 10 employees, a named heat safety coordinator, and a review at least once a year.

Until a final rule exists, OSHA relies on the general duty clause and runs a National Emphasis Program on indoor and outdoor heat hazards (CPL 03-00-024, April 10, 2026). When heat sends a driver to the hospital, the reporting rules in the [OSHA guide for NEMT companies](https://nemtguide.com/guides/osha-for-nemt/) apply, and a heat illness that needs treatment beyond first aid belongs in your [employee injury report](https://nemtguide.com/templates/employee-injury-report-form/).

## Frequently asked questions

### Does a small NEMT company need a written heat illness prevention plan?

In five states, yes, once the rule covers your drivers. California, Oregon, Washington, and Maryland require a written plan from every covered employer, whatever its size. Nevada's rule applies to employers with more than 10 employees. Everywhere else, federal OSHA or your state plan can cite a serious heat hazard under the general duty clause, so a written plan is still the simplest way to show you planned for heat.

### Does an air-conditioned van count as shade or a cool-down area?

Yes, while it is running with working air conditioning. California's and Washington's rules say a car sitting in the sun is not shade unless it is running with air conditioning, and Oregon's rule adds that the air conditioning must be working. A van parked with the engine off, or with broken air, does not count.

### What happens in California when a van's air conditioning breaks?

The van loses a key exception. Under 8 CCR 3396, short heat exposures of less than 15 minutes an hour are excused, but not in vehicles without effective and functioning air conditioning. Once the van reaches 87 degrees by temperature or heat index with a driver in it, you must measure and record the heat and use controls to bring it down. Vans with working air conditioning skip the measuring step.

### How much water do I have to give each driver?

At least 1 quart (32 ounces) for each hour of the shift, free and cool, in California, Oregon, Washington, and Maryland. You may start the shift with less if you have a way to refill it during the route, such as a cooler at the base or stops where drivers can refill. Keep driver water separate from water for riders.

### Is there a federal OSHA heat rule for NEMT drivers?

Not yet. OSHA proposed one on August 30, 2024, held hearings from June 16 to July 2, 2025, and its 2026 regulatory agenda lists a supplemental proposal for December 2026 and a final action for October 2027. Until a final rule exists, OSHA uses the general duty clause and its heat National Emphasis Program (CPL 03-00-024, April 10, 2026).

### Does Arizona have a workplace heat rule?

The governor's executive order of May 22, 2025 (2025-09) did not create one. It asked the state job safety agency, ADOSH, to form a task force to recommend heat guidelines for employers by December 31, 2025, for the Industrial Commission of Arizona to approve. ADOSH can still cite a serious heat hazard under the general duty clause, so a written plan like this one is how you show you protect drivers.

## Official resources

- [Cal/OSHA: Heat illness prevention](https://www.dir.ca.gov/dosh/heatillnessinfo.html)
- [Oregon OSHA: Heat illness prevention questions and answers](https://osha.oregon.gov/OSHAPubs/5866.pdf)
- [Washington: WAC 296-62-095, outdoor heat exposure rules](https://app.leg.wa.gov/WAC/default.aspx?cite=296-62-09530)
- [Maryland: COMAR 09.12.32, Heat Stress Standards](https://www.labor.maryland.gov/labor/mosh/09.12.32.pdf)
- [Nevada OSHA: Heat illness prevention guidance](https://dir.nv.gov/uploadedFiles/dirnvgov/content/OSHA/Guidance/2025-01-29%20(Heat%20Illness%20Prevention%20Guidance).pdf)
- [OSHA-NIOSH Heat Safety Tool app](https://www.cdc.gov/niosh/heat-stress/communication-resources/app.html)
- [NIOSH: Signs and first aid for heat-related illnesses](https://www.cdc.gov/niosh/heat-stress/about/illnesses.html)
- [National Weather Service: Heat index calculator](https://www.wpc.ncep.noaa.gov/html/heatindex.shtml)