Much of Europe is currently sweltering. Warnings of extreme heat and ‘red alerts’ have been issued in countries such as the UK, France, Italy, Germany and the Netherlands in recent days. However, this is not just a European issue. Around the world, heatwaves are increasing in terms of frequency, duration and intensity.
For employers, this is not only an environmental concern. It is a workplace health and safety issue. High temperatures can affect employee wellbeing, concentration and productivity. In more severe cases, they can lead to heat-related illness. Organisations must therefore understand how existing legal frameworks apply.
In this four-part series, we examine key questions for employers during periods of extreme heat. These include whether there is a maximum working temperature, what practical steps should be taken by employers, whether dress codes may need to be relaxed, and when, if at all, employees can lawfully stop working. This first article focuses on whether there is a legally defined maximum working temperature; a specific temperature at which it becomes officially too hot to work. We explore some of high-level trends that emerge and then, on the right-hand side of the article, set out the insights from 18 countries.
Maximum working temperatures: what does the law say?
There is no single global approach to maximum working temperatures. However, and while the detailed position varies, three broad approaches can be identified.
Importantly, jurisdictions do not always fit neatly into one category. Some adopt a combination of approaches. For example, they may rely on general duties while also using guidance, trigger points or technical tools to assess risk.
Most countries do not set a fixed maximum temperature
This is the most common approach. Many jurisdictions do not set a legal maximum working temperature.
Instead, employers must ensure that working conditions are safe and suitable. This typically requires assessing and managing heat-related risks as part of broader health and safety obligations. Examples include New Zealand, Ireland and the Netherlands, where employers must ensure temperatures are ‘reasonable’ or do not pose a risk to health.
In practice, this means:
- Employers must carry out suitable risk assessments.
- They must take reasonably practicable steps to reduce heat exposure.
- The appropriate measures will depend on the nature of the work, the working environment and individual employee vulnerability.
We explore the practical measures that employers must or should take during periods of extreme heat in part two of our four part series.
Guidance and trigger points play an important role
Some jurisdictions use temperature thresholds or heat indices as triggers for employer action.
These may take the form of non-binding guidance or more structured, legally prescribed systems, but they do not usually set a single maximum temperature at which work must stop. For example:
- In France, official heatwave alert levels trigger employer obligations, supported by guidance recommending increased vigilance from 28°C for physical work and 30°C for sedentary work.
- In Belgium, heat is assessed using the wet bulb globe temperature (WBGT) index, which takes into account factors such as humidity and air movement. When thresholds are exceeded (which depend on the workload), employers must take protective measures.
In these systems, thresholds act as practical benchmarks or trigger points. They indicate when additional controls are required and may be used to assess whether employers have met their legal obligations.
Defined limits or technical assessment systems
A smaller number of jurisdictions go further by applying defined temperature limits or stricter rules in certain contexts. In these cases, exceeding a threshold can have direct consequences, including restrictions on work. For example in Hungary, maximum permissible temperatures vary by work type, and employees may stop working if those limits are exceeded.
Sector-specific rules may also impose limits. For example, in Greece, shipbuilding and ship-repair work collective labour agreements prohibit work above 36°C at certain hours of the day, usually midday and in the afternoon.
How is heat measured?
The approaches above are often supported by different methods for assessing heat risk. In several jurisdictions, measurement goes beyond a simple air temperature reading.
One widely used approach is the WBGT. This combines several environmental factors, including air temperature, humidity, radiant heat and air movement, to provide a more accurate assessment of heat stress. It is particularly relevant for outdoor work and physically demanding roles.
Other frameworks rely on more straightforward indicators. These may include:
- indoor temperature thresholds;
- weather-based alert systems or official heat warnings from authorised bodies;
- sector-specific benchmarks.
Some jurisdictions also take account of the ‘human element’. This includes the intensity of the work being carried out and the body’s ability to regulate heat. For example, assessments may consider metabolic rate or aim to prevent workers’ core body temperature from exceeding safe levels, such is the case in Chile.
These different approaches reflect a key point for employers: heat risk cannot be assessed by temperature alone. Effective risk management requires consideration of both environmental conditions and the nature of the work being performed.
Takeaway for employers
Even where no fixed upper limit applies, employers should not ignore high temperatures. In many jurisdictions, heat is dealt with through general health and safety duties, supported by guidance, sector-specific rules or technical assessment tools. In others, recommended thresholds or alert systems help indicate when stronger protective measures are expected.
The practical outcome is often similar. Employers must monitor conditions, assess the particular risks of the work being carried out and respond proportionately. This is especially important for outdoor work, physically demanding roles and workers who may be more vulnerable to heat.
The country insights therefore show a common direction of travel: even where regulation might take different forms, employers are increasingly expected to treat extreme heat as a foreseeable workplace risk.
In the next part of the series, we zoom in on precisely what practical measures employers should or must take during periods of extreme heat.
Meet Delphius, our AI-powered guide to global employment law for in-house legal and HR teams
Insights
Extreme heat at work: Is there a maximum working temperature?
Much of Europe is currently sweltering. Warnings of extreme heat and ‘red alerts’ have been issued in countries such as the UK, France, Italy, Germany and the Netherlands in recent days. However, this is not just a European issue. Around the world, heatwaves are increasing in terms of frequency, duration and intensity.
For employers, this is not only an environmental concern. It is a workplace health and safety issue. High temperatures can affect employee wellbeing, concentration and productivity. In more severe cases, they can lead to heat-related illness. Organisations must therefore understand how existing legal frameworks apply.
In this four-part series, we examine key questions for employers during periods of extreme heat. These include whether there is a maximum working temperature, what practical steps should be taken by employers, whether dress codes may need to be relaxed, and when, if at all, employees can lawfully stop working. This first article focuses on whether there is a legally defined maximum working temperature; a specific temperature at which it becomes officially too hot to work. We explore some of high-level trends that emerge and then, on the right-hand side of the article, set out the insights from 18 countries.
Maximum working temperatures: what does the law say?
There is no single global approach to maximum working temperatures. However, and while the detailed position varies, three broad approaches can be identified.
Importantly, jurisdictions do not always fit neatly into one category. Some adopt a combination of approaches. For example, they may rely on general duties while also using guidance, trigger points or technical tools to assess risk.
Most countries do not set a fixed maximum temperature
This is the most common approach. Many jurisdictions do not set a legal maximum working temperature.
Instead, employers must ensure that working conditions are safe and suitable. This typically requires assessing and managing heat-related risks as part of broader health and safety obligations. Examples include New Zealand, Ireland and the Netherlands, where employers must ensure temperatures are ‘reasonable’ or do not pose a risk to health.
In practice, this means:
We explore the practical measures that employers must or should take during periods of extreme heat in part two of our four part series.
Guidance and trigger points play an important role
Some jurisdictions use temperature thresholds or heat indices as triggers for employer action.
These may take the form of non-binding guidance or more structured, legally prescribed systems, but they do not usually set a single maximum temperature at which work must stop. For example:
In these systems, thresholds act as practical benchmarks or trigger points. They indicate when additional controls are required and may be used to assess whether employers have met their legal obligations.
Defined limits or technical assessment systems
A smaller number of jurisdictions go further by applying defined temperature limits or stricter rules in certain contexts. In these cases, exceeding a threshold can have direct consequences, including restrictions on work. For example in Hungary, maximum permissible temperatures vary by work type, and employees may stop working if those limits are exceeded.
Sector-specific rules may also impose limits. For example, in Greece, shipbuilding and ship-repair work collective labour agreements prohibit work above 36°C at certain hours of the day, usually midday and in the afternoon.
How is heat measured?
The approaches above are often supported by different methods for assessing heat risk. In several jurisdictions, measurement goes beyond a simple air temperature reading.
One widely used approach is the WBGT. This combines several environmental factors, including air temperature, humidity, radiant heat and air movement, to provide a more accurate assessment of heat stress. It is particularly relevant for outdoor work and physically demanding roles.
Other frameworks rely on more straightforward indicators. These may include:
Some jurisdictions also take account of the ‘human element’. This includes the intensity of the work being carried out and the body’s ability to regulate heat. For example, assessments may consider metabolic rate or aim to prevent workers’ core body temperature from exceeding safe levels, such is the case in Chile.
These different approaches reflect a key point for employers: heat risk cannot be assessed by temperature alone. Effective risk management requires consideration of both environmental conditions and the nature of the work being performed.
Takeaway for employers
Even where no fixed upper limit applies, employers should not ignore high temperatures. In many jurisdictions, heat is dealt with through general health and safety duties, supported by guidance, sector-specific rules or technical assessment tools. In others, recommended thresholds or alert systems help indicate when stronger protective measures are expected.
The practical outcome is often similar. Employers must monitor conditions, assess the particular risks of the work being carried out and respond proportionately. This is especially important for outdoor work, physically demanding roles and workers who may be more vulnerable to heat.
The country insights therefore show a common direction of travel: even where regulation might take different forms, employers are increasingly expected to treat extreme heat as a foreseeable workplace risk.
In the next part of the series, we zoom in on precisely what practical measures employers should or must take during periods of extreme heat.
Meet Delphius, our AI-powered guide to global employment law for in-house legal and HR teams
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