If you watched the 2026 FIFA World Cup this summer, you may have noticed something unusual: mandatory hydration breaks. For the entirety of the tournament, FIFA required cooling and hydration breaks in addition to the standard halftime break. While skeptics argued that these breaks were added for increased ad time, they also allowed players the opportunity to cool off when on-field conditions became dangerously hot, such as during the Fourth of July weekend heat dome.

These measures reflect a broader reality: Organizations are building formal heat-safety protocols – mandatory breaks, hydration access, shade and monitoring – directly into their operations as extreme heat becomes more frequent and more dangerous. The World Health Organization identifies heat stress as the leading cause of weather-related deaths globally. If the world’s top athletes require structured protections from heat, the implications for employers with workers exposed to high temperatures are clear.

The urgency of workplace heat safety is not hypothetical. The Maryland Department of Health has recorded 34 heat-related deaths in the state so far in 2026. For context, Maryland recorded 36 heat-related deaths in all of 2025, the highest annual figure since 2012.

These numbers underscore a simple point: heat kills, and it is doing so with increasing frequency. Employers who fail to implement adequate heat-safety measures are not just risking regulatory penalties – they are risking lives.

What Employers Should Know 

Maryland is one of seven states (California, Colorado, Minnesota, Nevada, Oregon and Washington are the others) that have implemented statewide heat safety standards, and Virginia will soon join the ranks after passing legislation that directs the Virginia Safety and Health Codes Board to adopt heat stress standards that would go into effect no later than May 1, 2028. Employers in states that do not have such regulations generally are required to safeguard their workforces under OSHA’s General Duty Clause (Section 5(a)(1) of the OSH Act).

Maryland’s Occupational Safety and Health (MOSH) Division of Labor and Industry’s Heat Illness Prevention Standard has been in effect since 2024. Here’s a refresher on the key requirements:

Coverage. The standard applies to all Maryland employers with employees exposed to a heat index equal to or exceeding 80°F, measured where employees actually work whether indoors or outdoors. Additional “high-heat procedures” are triggered above 90°F and above 100°F.

Water and Shade (80°F and above). Employers must provide at least 32 ounces of water per hour to each exposed employee and ensure access to shade (blockage of direct sunlight) for outdoor workers.

Monitoring. Above 90°F, employees must be monitored for signs of heat illness via phone, radio, a buddy system or other effective observation methods. Monitoring needs to be done by a designated “competent person” trained in heat illness prevention.

Mandatory Rest Breaks (90°F and above). Between 90°F and 100°F, employers must provide at least one 10-minute rest period every two hours. Above 100°F, employers must provide at least one 15-minute rest period every hour. These breaks may coincide with scheduled breaks or meal periods but otherwise must be paid.  

Acclimatization. Employers must acclimatize new employees and those returning after seven or more days away from the workplace. The acclimatization period may last up to 14 days, during which employers must observe workers for signs of heat-related illness. The National Institute for Occupational Safety and Health (NIOSH) recommends a written acclimatization schedule increasing exposure over 5-14 days with a maximum 20% daily increase or a schedule combining gradual introduction with alternative cooling measures.

Training. Employers must train employees and supervisors before first heat exposure, annually thereafter and again following any incident involving suspected or confirmed heat-related illness. Training must cover environmental and personal risk factors, acclimatization, water and rest break importance, types and symptoms of heat illness, first aid and emergency response, reporting procedures and the employer’s specific compliance procedures.

Recordkeeping. Training records must be maintained for at least one year and include names of those trained, training dates and a content summary. Records must be available to MOSH upon request.

Written Plan. Employers must develop and implement a written heat-related illness prevention and management plan and an emergency response plan incorporating the standard’s requirements.

These regulations are particularly thorny for businesses that make use of subcontractors and even subcontractors of subcontractors, many of whom utilize day labor to fulfill those contracts. These joint employer arrangements create questions that require individualized legal analysis as to what the best course of action is for the entity that controls the worksite. Both enforcement and publicity issues abound in these contexts, especially if a heat-related fatality occurs on the worksite.  

Act Before the Heat Does

The World Cup’s hydration breaks are a visible reminder that heat stress demands proactive, systematic responses not just in professional sports but in every workplace where employees face high temperatures. In more jurisdictions, compliance is not optional, and the consequences of inaction can be severe. Employers should review their current heat-safety policies, assess gaps against the standard’s requirements and consult employment counsel to ensure full compliance before conditions and enforcement intensify further.

Miles & Stockbridge’s labor and employment attorneys are well versed in navigating compliance with heat-illness and injury prevention obligations and can provide guidance on how to properly prepare for your workforce for these new demands.

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