Marike SCHOONEVELDT

Policy advisor Safety and Health at the Netherlands Trade Union Confederation (FNV)

Across the EU, 33 per cent of workers report being exposed to at least one climate change risk factor at work. Unfortunately, the EU occupational safety and health (OSH) framework directive does not specifically address all emerging risks, including occupational heat. Guidance alone cannot ensure effective protection. That is why we need a dedicated directive to prevent occupational heat risks. 

Heat at work is a serious issue. Heat exposure poses significant risks to workers’ safety and health, particularly those engaged in outdoor or physically demanding work. Heat stress can immediately affect workers on the job, leading to illnesses such as heat exhaustion, heatstroke, and even death. In the longer term, workers can develop serious and debilitating chronic diseases, impacting their cardiovascular and respiratory systems, as well as kidneys. While fatal occupational injuries related to heat are currently estimated to be twice as high in Southern Europe, Central and Northern Europe have experienced an increase exceeding 50 per cent over the past two decades. The impact extends beyond individual health: heat stress slows productivity, increases the need for breaks, and raises the risk of errors and accidents, endangering lives and people’s livelihoods, and causing income loss in low-paid sectors due to work interruptions produced by unbearable working temperatures, for which they receive no compensation. 

Current regulatory frameworks in workplaces

The OSH framework directive establishes that employers are legally obliged to ensure the health and safety of their workers. While this general duty is clear, it does not specifically address all emerging risks – including occupational heat – and thus leaves important gaps in protection. Crucially, the framework directive itself provides the legal basis for creating new binding instruments when existing rules no longer adequately address emerging risks or reflect changes in society and the working environment.

Current EU OSH legislation recognises heat at work as a risk. For example, the workplace directive stipulates that “the temperature in rest areas, rooms for duty staff, sanitary facilities, canteens and first aid rooms must be appropriate to the particular purpose of such areas”. Heat exposure is therefore recognised in principle, but current EU OSH law does not specify the measurable triggers and physiological safeguards needed to control this hazard. The scope of the workplace directive is also limited and does not cover work settings such as forests, agricultural fields and means of transportation, all important work settings in terms of exposure to heat and climate change-related risks. 

Gaps between basic protection provisions and current EU OSH law

The International Labour Organisation (ILO) identifies ten basic protection requirements to address workplace heat stress (WHS). Comparing these ten requirements with the EU OSH directives, the Advisory Committee of Safety and Health at work (ACSH)  recognises that few EU OSH directives contain heat-related provisions, and that these are predominantly general OSH provisions. 

Two heat at work topics are not addressed at all in EU law:  the use of scientifically validated heat exposure indicators and the acclimatisation to heat. And two more heat at work topics are only partially addressed in EU law: hydration strategies, and rest, breaks or modified work schedules. The latter appear without any link to heat or a heat-related indicator. Legislative gaps therefore clearly remain. The current EU OSH laws are insufficient. 

EU directive on heat at work as remedy

At present, divergent national and sectoral approaches mean that the level of protection varies widely, leaving some workers far more exposed than others. An EU directive would remedy these deficiencies by establishing legal obligations that are binding on all employers; by ensuring consistent protection across every sector and member state; and by providing consistent, preventive and enforceable protection for all workers. Echoing this stance, the European Trade Union Confederation (ETUC) has adopted a resolution on The content of a Directive on the prevention of occupational heat risks, stressing that workers are dying from heat at work and that current protections are failing.

Technical guidance, by contrast, remains optional and advisory. Guidance alone cannot ensure enforceable, effective protection. If guidance were enough, the existing EU-OSHA Heat at Work-Guidance for Workplaces would suffice, but it clearly does not, as rising numbers of heat-related occupational accidents and deaths demonstrate. The European Survey of Enterprises on New and Emerging Risks illustrates why this distinction matters: 87 per cent of EU-27 companies report that their primary motivation for managing OSH is to meet legal obligations. Guidance can inform best practice, but it cannot create legal obligations or compel employers to implement protective measures. 

Climate change is more than heat at work

The OSH Pulse 2025 makes clear that heat is not the only problem due to climate change. Across the EU, one-third of workers (33 per cent) report being exposed to at least one climate change-related risk factor at work. More specifically, 20 per cent of workers report exposure to extreme heat (either indoors or outdoors), and 19 per cent report exposure to air quality issues such as pollen, dust, or smoke (either indoors or outdoors). Lower shares of workers report being affected by intense sun exposure (12 per cent) or extreme weather-related events like floods, wildfires, droughts or hurricanes (9 per cent). 

That is why it is also necessary to develop guidance and tools for climate change-related risks concerning issues other than heat – air quality for example, or UV radiation, extreme weather events, biological agents and hazardous substances. Employers should be prepared for extreme weather events. They should be in contact with national, regional and local authorities to establish plans of action. 

Last but not least, the effects of climate change may increase psychosocial risks, potentially harming workers’ health. The impact of climate change on mental health is still not sufficiently well known, due to the novelty of the subject. However, it is possible to advance that, in some specific sectors where effects of climate change are more extreme (such as emergency response, healthcare professionals and firefighters), the impact will be higher. Actions to prevent its consequences must therefore be adopted at the workplace level, as well as carrying out more research on the effects and their correlation to workers’ health at the EU and member state level. 

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