In brief
Most South African employers think of heat as a comfort complaint, not a legal duty. That is about to be the wrong way round. From 06 September 2026, the Physical Agents Regulations 2024 "stand alone", and they name heat and cold as physical agents that require a documented risk assessment by a competent person, exposure monitoring and health surveillance, on the same footing as noise or vibration. [1][2] At the same time, the International Labour Organisation has adopted its first-ever global conclusions on occupational safety and health in extreme weather, asking every workplace for documented heat risk assessments and emergency plans. [3][4] This article explains why heat is now a record you must be able to produce, what the duty actually asks for, and why the sectors most exposed to it are the least ready.
Why heat stopped being just the weather
Two things changed in 2026, one South African and one global, and they point the same way.
In South Africa, the Physical Agents Regulations 2024 replace the old Environmental Regulations for Workplaces 1987 in full on 06 September 2026. [1][2] The definition of a physical agent is a source of energy that may cause injury or disease after exposure, and it expressly includes heat and cold alongside vibration, illumination and non-ionising radiation. [1] That single definitional move takes the thermal environment out of the realm of general comfort and puts it inside a named regulation, with the same machinery the OHS Act uses for any other measured hazard: a documented risk assessment by a competent person, refreshed at least every two years, exposure monitoring where limits are approached, health surveillance under an Occupational Medicine Practitioner, and long-term record retention. The full dated duty and its evidence list are tracked in our companion article, the South African OHS Compliance Calendar, because 06 September 2026 is a fixed date.
Globally, the International Labour Organisation held a Meeting of Experts in Geneva from 20 to 24 April 2026 and adopted the first-ever tripartite conclusions on occupational safety and health in extreme weather events and changing weather patterns, to be submitted to its Governing Body in November 2026. [3][4] The workplace-level measures the conclusions name are strikingly close to the South African list: gender responsive documented risk assessments, defined preventive and control measures, and maintained emergency preparedness and response plans, with worker consultation throughout. [3] When a national regulation and a global benchmark ask for the same evidence in the same year, that is usually the shape of where audits and enforcement are heading.
The scale, in numbers
Heat is not a marginal hazard dressed up as one. The ILO records that more than 2.4 billion workers, over 70 percent of the global working population, are exposed to excessive heat. [3] The exposure is not spread evenly: Africa carries the highest regional exposure of all, at about 93 percent of its workers, which places South African workplaces near the top of the global heat-risk range rather than in the comfortable middle. [6] Its review of the science, Heat at work, attributes about 22.85 million occupational injuries and roughly 18,970 deaths each year to excessive heat, and estimates that better prevention could save up to 361 billion United States dollars a year in lost income and medical costs. [5][6]
The most useful figure for a South African employer is a quieter one. The same evidence base finds that around eight in ten heat-related occupational injuries happen outside formal heatwaves, during ordinary warm working conditions rather than declared extreme events. [5][6] That is the point that turns heat from a disaster-planning topic into a routine risk-assessment topic: the harm is done on normal hot days, on normal sites, to workers nobody thought were in danger.
What the duty actually asks for
The practical core is short, and none of it is exotic. Identify where heat exposure is real: outdoor work, roofs and unshaded sites, hot processes, kitchens, and enclosed spaces without ventilation. Assess it in a dated document written by a competent person, specific to the actual work rather than a generic template. Set the ordinary controls the ILO and good practice name: access to drinking water, rest and shade, work-rest cycling and pacing in the hottest hours, acclimatisation for new and returning workers, and training so that workers and supervisors recognise heat exhaustion and heat stroke early. Keep an emergency plan for the day it goes wrong, and keep the records where they can be produced. Review the assessment on its cycle, not once and never again.
GRC Shop view
This section is interpretation, kept separate from the sourced facts above.
Our view is that heat is the single most underrated compliance exposure facing South African outdoor and industrial employers, precisely because it does not feel like a compliance item. A missing fire extinguisher looks like a breach; a hot afternoon looks like a Tuesday. Yet South Africa is a warm country running a great deal of its economy outdoors and in un-air-conditioned workshops, and from 06 September 2026 the law will treat the thermal environment as a measured, documented duty rather than a matter of goodwill. The employers most exposed- construction, agriculture, warehousing, hospitality kitchens- are, on the whole, the least likely to hold a dated heat risk assessment today.
Our forecast, clearly marked as opinion, is that heat will become a routine audit and inspection question within the next two years, driven from three directions at once: the Physical Agents Regulations giving it a home in South African law, the ILO conclusions setting the global standard of care, and the ISO 45001:2027 revision widening hazard identification to reflect modern and climate-affected ways of working. An employer who already carries a dated heat risk assessment, its controls and an emergency plan in a live record is answering a question the rest of the market has not yet realised it will be asked. That is the whole case for holding this as a living register rather than assembling it after the first serious incident.
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Abbreviations
- ILO: International Labour Organisation
- ISO: International Organisation for Standardisation
- OHS: Occupational Health and Safety
- OMP: Occupational Medicine Practitioner
- SME: Small and medium enterprise
References
The sources below are external links to third-party websites. We link only to publicly accessible pages and check periodically that the links still work.
[1] ENSafrica, "South Africa: OHASA, Physical Agents Regulations 2024, Noise Exposure Regulations 2024, and Amendment of the General Safety Regulations 2025", 11 Mar 2025. https://www.ensafrica.com/news/detail/9836/south-africa-occupational-health-and-safety-a
[2] Webber Wentzel, "Recent amendments to the Occupational Health and Safety Act: new regulations", 2025. https://www.webberwentzel.com/News/Pages/recent-amendments-to-the-occupational-health-and-safety-act-new-regulations.aspx
[3] International Labour Organization, "Tripartite experts agree on measures to protect workers and enterprises from weather-related risks", 28 Apr 2026. https://www.ilo.org/resource/news/tripartite-experts-agree-measures-protect-workers-and-enterprises-weather
[4] Human Resources Online, "Extreme weather at work: ILO tripartite experts set global OSH measures to protect workers and businesses", 2026. https://www.humanresourcesonline.net/extreme-weather-at-work-ilo-tripartite-experts-set-global-osh-measures-to-protect-workers-and-businesses
[5] International Labour Organization, "Heat at work: Implications for safety and health", 25 Jul 2024. https://www.ilo.org/publications/heat-work-implications-safety-and-health
[6] La Isla Network, "Summary of the ILO Report Heat at work: Implications for safety and health", 2024. https://laislanetwork.org/summary-of-the-ilo-report-heat-at-work-implications-for-safety-and-health/