Colorado Enacts Extreme Temperature Worker Protections

On June 4, 2026, Colorado Governor Jared Polis signed House Bill 26-1272 (HB 26-1272), Extreme Temperatures Worker Protections, expanding Colorado’s temperature-related workplace protections beyond agriculture to address both extreme heat and extreme cold across industries.

The law does not establish immediate operational requirements or specific temperature thresholds. Instead, it directs the Colorado Department of Labor and Employment (CDLE) to collect workplace temperature incident data by January 15, 2027, and develop a model Temperature-Related Injury and Illness Prevention Plan (TRIIPP) by July 1, 2028.

This update applies to covered employers operating in Colorado, including employers subject to the federal Fair Labor Standards Act (FLSA), agricultural employers, state and local governments, and entities that contract with five or more independent contractors in Colorado annually. The law takes effect on August 12, 2026.

What Employers Need to Do

• Review current heat and cold safety practices for temperature-exposed roles (outdoor, warehouse, construction, agricultural, transportation, landscaping, etc.) to identify potential gaps ahead of future CDLE rulemaking.

• Monitor CDLE developments, including the public reporting platform launching by January 15, 2027, and the model TRIIPP due July 1, 2028, to stay informed on future thresholds, procedures, and employer obligations.

• Evaluate existing training materials on heat-related and cold-related injury symptoms, since the model plan is expected to address both types of temperature exposure.

• Identify which roles at the organization involve temperature-exposed work (outdoor, warehouse, construction, agricultural, transportation, landscaping, etc.), so that once CDLE issues implementing rules, the organization has a clear scope for applying new requirements.

Overview

What the Law Does

• Expands Colorado’s temperature-related workplace protections beyond agriculture to address both extreme heat and extreme cold across industries.

• Directs CDLE, through the Division of Labor Standards and Statistics, to (1) collect data on temperature-related workplace injuries, illnesses, and emergencies; (2) develop a model TRIIPP; and (3) adopt rules necessary to implement the law.

• “Worker” includes an employee under Colorado wage law and an individual who works for an entity that contracts with five or more independent contractors in Colorado each year

Data Collection (By January 15, 2027): CDLE must create a public reporting platform on its website where users can report temperature-related workplace injuries, illnesses, or emergencies, and obtain data from the Colorado Department of Public Health and Environment’s (CDPHE) syndromic surveillance program, the Division of Workers’ Compensation (DWC), and the Center for Improving Value in Health Care (CIVHC).

• Model TRIIPP (By July 1, 2028): The model must include written procedures addressing:
  • No-cost access to cool, potable drinking water.
  • Cool-down or warm-up rest areas
  • Workplace temperature monitoring
  • A 14-day acclimatization process for new or returning workers
  • Training on symptoms of temperature-related injuries and illnesses
  • Emergency response procedures

• CDLE must review and update the model plan at least every five years.

Rulemaking Authority: CDLE may adopt rules to implement the law, which may result in additional employer obligations through future rulemaking.

Why This Matters

This law establishes the foundation for Colorado’s future workplace temperature-safety standards, expanding coverage beyond agriculture and reaching both extreme heat and extreme cold — a broader scope than most state heat-illness laws. While the law does not impose immediate operational requirements, employers with temperature-exposed workforces should closely monitor future CDLE developments because the model TRIIPP and any future CDLE rules may shape employer obligations by 2028.

Key Risks for Employers

• HB 26-1272 does not establish penalties for employers today because CDLE has not yet issued implementing rules. Once rules are adopted, non-compliance will be enforceable through CDLE’s existing authority under Colorado labor standards.

• The public reporting platform launching by January 15, 2027, may raise state-level scrutiny of temperature-related workplace injuries and illnesses, even before enforceable standards exist.

• Employers may have limited time to evaluate and respond to future requirements if CDLE issues implementing rules after the model TRIIPP is published.

• Federal OSHA continues to enforce the General Duty Clause for heat-related hazards, so Colorado employers may face federal enforcement even before state rules are issued.

Additional Information

Key Definitions

• Heat-related injury or illness and cold-related injury or illness cover serious medical conditions caused by the body’s inability to cope with heat or cold stress, including symptoms such as headache, nausea, dizziness, elevated body temperature, numbness, confusion, and excessive shivering.

• Acclimatized means the body’s gradual adaptation to working in heat or cold, reducing strain from heat or cold stress and reducing the chance of temperature-related injury or illness.

• Heat-temperature trigger and cold-temperature trigger are temperatures at which an individual, if exposed for a prolonged period, may be at risk of a temperature-related injury, illness, or emergency.

Source References

• Colorado HB 26-1272 – Extreme Temperatures Worker Protections

This communication is intended solely for the purpose of conveying information. The present post might incorporate hyperlinks directing readers to websites managed by third-party entities. The inclusion of any links within this communication is meant to serve as points of reference and could encompass opinion articles from various law firms, articles from HR associations, official websites, news releases, and documents of government agencies, and other relevant third-party sources. Vensure has no authority over these external websites and bears no responsibility for their content. Furthermore, Vensure does not endorse the materials present on these websites. The contents of this communication should not be interpreted as legal advice or as a legal standpoint concerning specific facts or scenarios. Nor should it be deemed an exhaustive compilation of facts potentially pertinent to federal, state, or local laws. It is strongly advised that employers solicit legal guidance from an employment attorney when undertaking actions in response to any legal updates provided. This is due to the possibility of future alterations occurring in federal, state, and local laws, regulations, as well as the directives and guidelines issued by governing agencies. These changes may transpire at any given time, potentially rendering certain portions of the content within this update void or inaccurate.