HEAT STRESS
A review of the legal regimes and why compliance is the floor NOT the ceiling
BRIEF
Heat Stress: From Occupational Health & Safety Issue to Human Rights Concern
Across much of the Arab States, extreme heat is not an occasional event, it is a defining feature of the working environment. From construction sites and agricultural fields to ports, logistics hubs, sanitation services and oil and gas operations, millions of workers perform physically demanding tasks in temperatures that can regularly exceed 45°C during the summer months. As climate change accelerates, heatwaves are becoming more frequent, more intense and longer-lasting, placing growing pressure on workers, employers and regulators alike.
Heat stress occurs when the human body can no longer effectively cool itself and maintain a safe internal temperature. The consequences extend far beyond discomfort. Exposure to excessive heat can lead to dehydration, heat exhaustion, heat stroke, kidney disease, cardiovascular complications, workplace accidents and, in severe cases, death. Heat also affects concentration, decision-making and physical performance, increasing the likelihood of occupational injuries while reducing productivity and operational efficiency.
The challenge is particularly acute across the Gulf and other parts of the Arab region, where high temperatures are often combined with intense humidity and demanding working conditions. Workers in outdoor occupations and poorly ventilated environments face heightened risks, especially where access to shade, drinking water, rest breaks, cooling facilities or medical assistance is limited. Migrant workers, subcontracted workers and low-income workers may face additional vulnerabilities where economic pressures, recruitment-related debts, insecure employment or restrictions on mobility limit their ability to stop work or report unsafe conditions.
Heat stress is therefore not only an occupational health and safety issue, but also recognised human rights concern. Excessive heat can affect the rights to life, health, safe and healthy working conditions, just and favourable conditions of work, and an adequate standard of living. As temperatures continue to rise across the region, businesses are facing growing expectations from governments, investors, international organisations and civil society to move beyond minimum legal compliance and adopt more effective measures to prevent heat-related harm.
June 2026
Insights from the ground:
Why legislation is not enough and businesses need to go beyond compliance?
Legal protections on heat stress, including midday work bans and occupational safety requirements, are an important baseline. However, experience from the ground shows that legislation alone does not always translate into effective protection for workers. In practice, risks often persist because of loopholes in the law, inconsistent implementation, limited enforcement, and operational pressures that encourage companies and contractors to treat compliance as a box-ticking exercise rather than a genuine prevention strategy.
Key risks observed in practice include:
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Displacement of risk rather than reduction of risk
Workers may be moved to earlier morning, late afternoon, or evening shifts to comply with midday bans. However, these shifts can become longer, more intensive, or still take place during periods of dangerous heat and humidity.
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Longer or more compressed working hours
In some cases, work that cannot be carried out during banned hours is compressed into fewer hours. This can increase physical intensity, reduce rest periods, and heighten the risk of dehydration, exhaustion, and accidents.
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Loopholes around “shaded” or “indoor” work
Some work may be classified as shaded or non-outdoor even when workers remain exposed to extreme heat, poor ventilation, radiant heat, or partially covered environments that do not provide meaningful protection.
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Narrow focus on certain sectors
Enforcement and company policies often focus on construction, while other exposed workers may be overlooked, including: security guards; delivery drivers; petrol station attendants; cleaners; maintenance workers; transport and logistics workers; subcontracted and outsourced workers.
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Limited visibility over subcontractors
Heat-stress controls may be stronger for direct employees than for workers employed by contractors, labour suppliers, or subcontractors. This creates a protection gap for workers who are often among the most exposed.
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Weak or inconsistent enforcement
Government inspections may be limited, fines may not always be imposed consistently, and enforcement may focus on visible breaches during fixed banned hours rather than actual heat exposure throughout the day.
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Pressure to meet deadlines
Project delays, supply-chain disruption, and crisis-related operational pressure can lead managers and contractors to prioritise delivery timelines over worker safety.
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Near misses treated as isolated incidents
Fainting, dizziness, dehydration, confusion, minor accidents, and heat exhaustion are often treated as individual incidents rather than warning signs of systemic failure in heat-risk management.
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Limited worker voice
Workers may hesitate to report symptoms, request rest, or stop work because of fear of wage deductions, disciplinary action, retaliation, or being seen as refusing work.
The regulatory landscape
Across the Arab States, dedicated heat stress regulations remain the exception rather than the norm. As of 2026, only the six GCC countries (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and the United Arab Emirates) have adopted specific heat stress measures, typically through seasonal midday work bans and associated worker protection requirements. Jordan also stands apart from much of the region, having developed a more explicit framework for occupational safety and health protection, although it does not have a dedicated heat stress regime comparable to those found in the GCC.
By contrast, most countries in North Africa and the Levant including Egypt, Algeria, Morocco, Tunisia, Libya, Mauritania, Lebanon, Syria and Palestine do not currently have specific heat stress regulations governing work in high temperatures. Similarly, Iraq, Yemen, Sudan, Somalia, Djibouti and Comoros do not have dedicated heat stress legislation. Instead, employers in these jurisdictions remain subject to general occupational safety and health obligations requiring them to provide a safe workplace and protect workers from foreseeable risks to health and safety. While these general duties can reasonably be interpreted as including heat-related risks, they rarely establish detailed requirements regarding heat monitoring, work-rest schedules, hydration, acclimatisation, temperature thresholds, or mandatory suspension of work during extreme heat events.
To learn more about the current heat stress regulations and government measures in the Arab States
What does good look like beyond compliance
Legal compliance is only a baseline, employers must manage actual heat risks, especially among subcontractors and suppliers where exposure is often less visible and less controlled.
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Conduct heat-stress risk assessments before work starts
Employers should assess all hot work, including outdoor work, indoor work in poorly ventilated areas, transport, logistics, maintenance, cleaning, security, delivery, and subcontracted activities. Assessments should consider temperature, humidity, radiant heat, workload, PPE, physical effort, access to water and rest, worker health, accommodation and transport conditions, and emergency preparedness.
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Use real-time heat monitoring, not only calendar-based rules
Employers should use appropriate heat-monitoring tools, such as Heat Index or preferably Wet Bulb Globe Temperature (WBGT), to determine when work should be modified, paused, or stopped. This helps ensure that controls respond to actual risk rather than relying only on fixed dates and hours.
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Adapt working hours and work-rest cycles
Heavy or strenuous tasks should be scheduled during cooler periods, and structured work-rest cycles should be applied based on heat exposure and workload. Employers should avoid simply shifting work to earlier or later hours if this results in longer shifts, compressed work, reduced rest, or equally hazardous exposure.
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Provide cool, shaded and ventilated rest areas
Rest areas should be close to the worksite, accessible to all workers, and genuinely cooler than the work area. Shade should not be treated as a technical loophole that allows unsafe work to continue; it should support actual recovery from heat exposure.
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Ensure hydration and electrolyte replacement
Cool drinking water should be available near the work location at all times, with clear encouragement to drink regularly. Where workers are exposed to prolonged sweating or heavy physical work, employers should provide appropriate salt or electrolyte replacement.
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Introduce acclimatisation for new or returning workers
Workers who are newly recruited, returning from leave, or assigned to hotter or more physically demanding tasks should be gradually exposed to heat. Workload and exposure should be increased progressively, with closer supervision during the first days or weeks.
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Reduce physical workload where possible
Employers should use mechanical aids, rotate tasks, split strenuous work, increase staffing, and use buddy systems to reduce heat strain. Work planning should aim to eliminate or reduce exposure first, rather than relying only on individual resilience or PPE.
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Identify and protect vulnerable workers
Employers should provide medical screening and health monitoring for workers who may be more vulnerable to heat stress, including those with hypertension, diabetes, kidney disease, heart conditions, or other relevant health risks. High-risk workers should be reassigned or given additional protections where needed.
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Train workers, supervisors and contractors
Training should cover the signs of heat exhaustion and heat stroke, hydration, safe work-rest practices, first aid, emergency escalation, and the right to report symptoms. Supervisors should be trained to stop work when warning signs appear and not to treat heat-related illness as a disciplinary or productivity issue.
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Enable worker voice and non-retaliation
Workers should be able to report symptoms, request rest, access water, and remove themselves from dangerous heat exposure without wage deductions, punishment, or retaliation. Worker input should be built into risk assessments and daily site monitoring.
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Extend protections across the supply chain
Heat-stress controls should apply to contractors, subcontractors, labour suppliers, outsourced workers, security, transport, cleaning, maintenance, delivery, and logistics workers. Contracts should require compliance with heat-stress controls, and companies should monitor implementation in practice.
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Track incidents, near misses and complaints
Employers should record heat-related symptoms, near misses, medical cases, worker complaints, rest breaks, hydration access, and heat readings. Fainting, dehydration, confusion, dizziness, and heat exhaustion should be treated as warning signs of systemic risk, not isolated incidents.
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