Colorado signed House Bill 26-1272, “Extreme Temperatures Worker Protections,” into law on June 4, 2026, establishing a phased framework for protecting all Colorado workers from extreme heat and cold conditions. The law significantly expands the state’s existing temperature protections, which previously applied only to agricultural workers (7 CCR 1103-15), to cover indoor and outdoor workers across all industries. The law takes effect on August 12, 2026.

Background

Colorado has had heat-related protections for agricultural workers since 2022. Those rules require agricultural employers to implement heat illness and injury prevention measures when worksite temperatures reach 80 degrees Fahrenheit, including providing potable water, shade, rest breaks, acclimatization procedures, and annual training. However, those protections did not extend to workers in other industries, and no cold weather-related protections existed for any workers. House Bill 26-1272 addresses these gaps by establishing a phased framework that applies temperature protections to all Colorado workers regardless of industry.

Key provisions

1. Data collection requirements (by January 15, 2027). The Division of Labor Standards and Statistics must begin collecting data, including temperature-related injury, illness, or emergencies at worksites. This includes developing a platform on the Colorado Department of Labor and Employment’s (CDLE) website for users to report temperature-related incidents, obtaining data from the Department of Public Health and Environment’s syndromic surveillance program, and working with the Division of Workers’ Compensation and the Center for Improving Value in Health Care.
2. Model prevention plan (by July 1, 2028). The division must develop a model Temperature-Related Injury and Illness Prevention Plan (TRIIPP) that will be made available on the CDLE website for employers to use as a resource. The division must review and update the model TRIIPP at least every five years.
3. Rulemaking authority. The law grants the division authority to adopt rules necessary to implement its provisions. While the current law does not mandate that employers develop their own site-specific TRIIPPs or prescribe specific temperature thresholds, this rulemaking authority preserves the possibility of future enforceable standards informed by the data collected under the act.

Federal landscape

Employers should understand the interaction between this state law and federal OSHA authority. OSHA’s proposed federal heat standard (published in 2024) remains pending with no finalization timeline, and the current administration has not signaled intent to advance it.

For a broader discussion of the federal enforcement landscape, and practical tips for employers preparing for heat-related hazards, please see our related client alert, Don’t shvitz it: What employers should know before temperatures rise.

Implications for employers

Employers operating in Colorado should be aware that:

• The new law does not currently impose specific temperature thresholds, mandatory rest break requirements, or prescriptive workplace protocols for non-agricultural workers. However, the division’s rulemaking authority means that binding requirements could follow once data collection is complete and the model TRIIPP is developed. Employers should anticipate the possibility that future rulemaking may require site-specific prevention plans encompassing monitoring conditions, cool-down or warm-up breaks, potable water, climate-appropriate rest areas, emergency procedures, and worker training.
• Employers in agricultural sectors remain subject to the existing Agricultural Labor Conditions Rules, which already mandate comprehensive heat protections at 80 degrees Fahrenheit, with heightened requirements at 95 degrees Fahrenheit depending on risk conditions.

Practical recommendations

Employers should consider the following steps to prepare for compliance:

Proactively evaluate worker temperature exposures. Even before the state’s data-collection platform is operational in January 2027, employers may find it useful to begin documenting heat- and cold-related workplace incidents internally to establish baseline data. 

Examine current heat and cold exposure safety practices. The law does not yet mandate specific protocols for non-agricultural workers; however, employers should consider assessing their current practices, including water availability, shade or warming areas, rest break policies, and acclimatization protocols. 

Explore available training resources for supervisors and workers. Consider familiarizing teams with heat and cold illness prevention training, drawing on the agricultural sector’s existing requirements or OSHA’s educational resources.

Plan to review and gap assess against the model TRIIPP. Once the division publishes the model TRIIPP (due by July 1, 2028), employers should review and consider adopting it as a baseline for their own site-specific plans, particularly in industries with extreme temperature exposure.

Next steps

The law takes effect on August 12, 2026. Key compliance milestones are:

• August 12, 2026: Act becomes effective.
• January 15, 2027: Division begins data collection on temperature-related injuries, illnesses, and emergencies.
• July 1, 2028: Division publishes model TRIIPP on CDLE’s website.
• Ongoing: Division reviews and updates the model TRIIPP at least every five years and may adopt additional rules as needed.

We will continue to monitor developments as the division begins its data-collection and rulemaking activities and will provide updates as additional guidance becomes available.

Client Alert 2026-140