Your risk assessment document mentions noise, falls, musculoskeletal disorders. But what about 40°C in your warehouse this summer? Since July 2025, climate risk is an occupational risk in the legal sense of the term — with real penalties attached.
What You Will Learn
The summer of 2025 hit hard. Four heatwaves, 69 departments under heatwave alert, more than 5,700 deaths attributable to heat over the entire monitoring season, and 9 fatal workplace accidents directly linked to intense heat episodes, reported by France’s Directorate General of Labour. These victims were aged between 35 and 63. They worked primarily in construction, public works, and agriculture.
This is no longer a weather event. It is an occupational risk. And it is now written into French labour law.
A Summer 2025 That Changed Everything — And a Legal Framework Finally Catching Up
The summer of 2025 ranks 3rd among the hottest summers since 1900, with an average temperature 1.9°C above the historical norm. France experienced 4 heatwave episodes, including an early and prolonged one from 19 June to 6 July, and a particularly intense one in the South-West from 8 to 19 August.
Against this backdrop, the French government took an unprecedented legislative step: Decree No. 2025-482 of 27 May 2025 introduced, for the first time, a formal obligation in the Labour Code to prevent the effects of extreme heat — enforceable from 1 July 2025 for all employers, public and private.
In concrete terms: what was yesterday a matter of common sense or recommendation is today a legally enforceable obligation. This is exactly what C2D Prévention addresses in its Legal Roles and Responsibilities Conference: understanding what the law requires of you, before the labour inspectorate reminds you.
The Risk Assessment Document: Your DUERP Is Now Incomplete If Heat Isn't in It
This is the point that many employers haven’t yet grasped.
Extreme heat is now a fully-fledged occupational risk: employers are therefore required to include it in their Single Occupational Risk Assessment Document (DUERP). The new National Occupational Health Plan 2026-2030, launched on 5 June 2026, reaffirms the DUERP as the central tool of prevention and sets out the goal of better integrating heat-related risks into occupational risk assessments.
In plain terms: if your DUERP was last updated in 2024 or early 2025 without including the heat risk, it is already non-compliant. And the labour inspectorate can show up at your door. To learn how to structure a compliant and sustainable occupational risk prevention approach, this is precisely what C2D Prévention supports on a daily basis.
What the Law Actually Says: Three Alert Levels, Three Levels of Obligation
An intense heat episode is defined based on Météo-France’s vigilance thresholds: yellow alert (a heat peak lasting 1 to 2 days posing a health risk), orange alert (a prolonged heatwave likely to constitute a health risk for the population), or red alert (an exceptional heatwave in terms of duration, intensity, and geographic scale).
At each level, employers must activate graduated measures. The obligation to act begins as soon as the yellow alert is triggered: the employer assesses the risks linked to workers’ exposure to intense heat episodes, whether indoors or outdoors, and defines the corresponding prevention measures.
The concrete measures required by law are as follows:
Work organisation — adjusting schedules, shifting the hottest working periods, providing additional rest periods.
Technical adjustments — installing sun protection, improving ventilation, reducing heat build-up indoors (blinds, misting systems, air movers).
Access to water — employers must guarantee access to fresh, drinkable water throughout the day, with a minimum of 3 litres per worker per day for outdoor positions.
Reporting protocols — employers must define how workers report any concerning physiological signs, episodes of discomfort, or distress, and communicate these protocols to staff and to the occupational health service.
Protection of vulnerable workers — older employees, pregnant women, people with fragile health conditions, and young workers, for whom it is prohibited to assign them to positions exposing them to extreme temperatures that could harm their health.
These general principles of prevention — assess, prioritise, act — apply here as a matter of course. Heat is not a separate risk category: it follows exactly the same legal logic as every other occupational risk.
The Sanction That's Changing the Game
As of 1 July 2025, the labour inspectorate can issue a formal notice to companies, giving them 8 days to define a list of prevention measures against risks linked to intense heat episodes. After this deadline, a formal violation report can be issued.
And the stakes go well beyond an administrative fine. In the event of an accident or heat-related illness, an employer who hasn’t updated their DUERP, hasn’t trained their teams, and hasn’t provided water or a reporting protocol exposes themselves to civil, administrative, and criminal liability. That liability can extend all the way up to company executives — gross negligence, endangerment of others, even involuntary manslaughter.
This is precisely why C2D Prévention designed its Legal Roles and Responsibilities Conference — with concrete legal case studies and real examples of companies held liable.
Industry, Construction, Logistics: The Most Exposed Sectors
Make no mistake: indoor heat can be just as dangerous as on a construction site. A poorly ventilated open-plan office, a warehouse with no air conditioning, a restaurant kitchen — indoor heat causes the exact same conditions: dehydration, cramps, fainting, heatstroke, reduced alertness.
In warehouses, high ceilings allow heat to accumulate in the upper part of the building, while logistics operations and frequent door openings amplify temperature fluctuations. In factories and workshops, machinery and industrial processes add internal heat sources on top of outdoor temperatures.
The Impact on Performance: An Economic Reality Management Still Overlooks
This isn’t just a regulatory issue. It’s an economic one. Above 20°C, productivity drops by 2 to 3% per degree, according to research by the WHO and the World Meteorological Organization. And at 33-34°C, it falls by 50% — what’s known as heat stress. For a warehouse, a construction site, or a production line running at full capacity in July, the cost is immediate, measurable, and undeniable.
French statistics confirm this trend: the construction sector recorded 149 deaths in 2023 and 8 million lost working days. Heat compounds the pressure on sectors already facing high accident rates. To better understand the broader dynamics of workplace accidents in France, our article Work Accidents & Occupational Diseases 2024: Key Figures, Causes, and Actions offers a comprehensive overview.
The National Occupational Health Plan 2026-2030: The Political Signal HR and Managers Must Read
The National Occupational Health Plan (PST) 2026-2030 was published on 5 June 2026, the result of a collaborative effort between the State, social partners, and institutional stakeholders. It sets out the new strategic and operational roadmap for improving workers’ health over the next five years.
The plan’s five priorities are: serious and fatal workplace accidents, women’s health at work, climate change among other emerging risks, absenteeism, and mental health. It calls for stronger support for companies in addressing the effects of climate change, with better integration of heat into occupational risk assessments and into the selection of personal protective equipment.
This plan isn’t just another document. It’s the roadmap that will guide labour inspectorate audits, regional health insurance fund (CARSAT) priorities, and employment tribunal cases for the next five years. This is exactly what C2D Prévention closely monitors in order to support companies with their compliance.
What Management Must Change — Now
Here’s the problem in most companies today: heat is still treated as a seasonal inconvenience, not a structural risk to be managed. Bottled water gets handed out in July, a fan gets installed in the warehouse, and everyone hopes it’ll be enough.
Since Decree No. 2025-482, work organisation, breaks, hydration, and workstation adjustments are no longer just common sense — they are structured prevention requirements. This shift means moving from static prevention to a dynamic approach. A DUERP updated once a year is no longer sufficient if conditions keep changing.
Here’s what management must concretely put in place:
Before the summer season
- Update the DUERP to formally include the heat risk, broken down by work unit (warehouse, workshop, construction site, non-air-conditioned office).
- Develop a heat action plan that can be activated as soon as the yellow Météo-France alert is triggered.
- Train frontline managers to recognise warning signs (dizziness, nausea, confusion, cramps).
During heat episodes
- Activate the plan as soon as the yellow level is reached — don’t wait for orange.
- Reorganise schedules: work early in the morning, take breaks during the hottest hours.
- Ensure access to cold water near workstations (minimum 3 litres/day/worker for outdoor positions).
- Monitor isolated workers with a formalised reporting protocol.
- Identify and protect vulnerable employees in coordination with the occupational physician.
On an ongoing basis
- Plan ahead for investments: thermal insulation, air movers, misting systems, blinds.
- Keep written evidence: updated DUERP, training records, proof of compliance.
A thorough assessment of your current prevention approach is often the most effective starting point to understand exactly where you stand — and what remains to be done before the first heatwave hits.
The Key Role of the Frontline Manager
Procedures don’t protect employees. Managers who enforce them on the ground do. That’s where real prevention happens.
A frontline manager who doesn’t know how to spot heatstroke, who doesn’t dare adjust the schedule because production targets are under pressure, who doesn’t know they can halt activity in case of danger — that’s a line of defence that doesn’t exist.
Training managers on heat risk follows exactly the same logic as training them on chemical hazards or fall prevention. Climate change doesn’t change the logic of prevention — it expands its scope. To go further on what a strong safety culture means in practice for managers on a daily basis, our resources offer directly actionable tools.
What You Risk by Doing Nothing
- A labour inspectorate audit, with a formal notice issued within 8 days.
- A formal violation report if no measures are in place.
- Criminal liability for the employer or executive in the event of a fatal accident.
- Employees collectively exercising their right to withdraw during the next heatwave — legally justified and non-sanctionable.
- Costly operational disruption, compounded by rising accident rates.
To better understand how psychological safety and trust play a role in surfacing on-the-ground information — particularly during high-risk episodes like heatwaves — our article on cognitive biases and human error in workplace safety offers concrete insights for managers.
Key Takeaways
- An unprecedented legal framework since July 2025
Decree No. 2025-482 of 27 May 2025 created, for the first time, a dedicated chapter on heat in the French Labour Code. This is no longer a recommendation — it is a legally enforceable obligation. - The DUERP must be updated
Every employer must integrate heat risk into their risk assessment document, broken down by exposed work unit. A DUERP that doesn’t mention it has been non-compliant since 1 July 2025. - The obligation begins at the yellow alert
There’s no need to wait for an orange or red heatwave alert. From the first Météo-France warning level, prevention measures must be activated. - Every sector is affected
Construction, logistics, industry, hospitality, non-air-conditioned offices, public administrations — no one is exempt. Indoor heat is just as dangerous as outdoor heat. - The penalties are real and immediate
The labour inspectorate can issue a formal notice within 8 days. In the event of an accident, the employer’s civil, administrative, and criminal liability is engaged. - Productivity takes a measurable hit
Above 20°C, productivity drops by 2 to 3% per degree. At 33-34°C, it’s cut in half. Heat risk is also an economic risk. - The 2026-2030 National Occupational Health Plan makes it a national priority
Launched on 5 June 2026, the new plan places climate change among its five strategic pillars. This issue will shape inspections and prevention policy for the next five years.
FAQ
At what temperature is an employer legally required to act?
There is no fixed Celsius threshold defined as an absolute legal trigger in the French Labour Code. Obligations are activated based on Météo-France’s heatwave vigilance levels — yellow, orange, or red — not a fixed thermometer reading. The benchmarks of 30°C indoors and 33°C outdoors are recommendations from France’s national occupational safety institute (INRS), but are not legal obligations in themselves. It is therefore the national weather alert system that applies, not the thermometer in your warehouse.
My company has air-conditioned offices. Am I still affected?
Yes. The decree applies to all enclosed workspaces, including offices. The law now requires these spaces to be maintained at a temperature appropriate to the work being carried out — no longer just “as far as possible,” as the previous wording allowed. If your air conditioning fails during an orange alert, you have immediate obligations. Better to have anticipated them.
Does heat risk need to be in the DUERP even outside of summer?
Yes. The DUERP is an annual, ongoing risk assessment document. Heat risk must appear in it year-round, with a stronger update before and during the summer season. It must identify exposed work units, assess critical periods, and detail prevention measures that can be activated at each alert level. C2D Prévention’s support modules can help you structure this approach sustainably.
Can an employee exercise their right to withdraw if the heat is excessive?
Yes, provided they believe they are facing a serious and imminent danger to their health or safety. This right is guaranteed under French labour law. If conditions justify it, the employer cannot sanction the employee, withhold their pay, or demand they return to work as long as the danger persists. An employer who has implemented a solid prevention plan — water, schedule adjustments, rest areas — significantly reduces this risk. And a culture where ground-level reporting is encouraged makes it possible to detect risky situations well before they become critical.
What is the heatwave-related “bad weather” compensation scheme for construction?
Since a June 2024 decree, heatwaves are officially recognised as a form of “bad weather” in the construction sector, allowing companies to access the bad-weather compensation scheme starting from the orange alert level. But be careful: this scheme is conditional on the employer being up to date with their prevention obligations. You cannot place teams on partial unemployment due to heat if the DUERP doesn’t mention heat risk and no measures have been implemented.
What penalties apply in the event of non-compliance?
The labour inspectorate can issue a formal notice within 8 days. Without a response, a formal violation report is issued. In the event of a heat-related accident or death, the employer’s liability is engaged on three levels: administrative (fines, injunctions), civil (compensation for harm suffered by the employee or their dependents), and criminal (endangerment of others, gross negligence, involuntary manslaughter). Liability can extend all the way up to company executives. Our Legal Roles and Responsibilities Conference covers these legal mechanisms in detail, with real case law examples.
Where should my company start if we haven’t done anything yet?
Three priority actions, in order: first, update the DUERP to include heat risk for every exposed work unit; second, develop an action plan that can be activated as soon as the yellow alert is triggered (water, schedules, reporting, PPE); and third, train frontline managers to recognise warning signs and activate the plan. This isn’t a six-month project — it’s a structured approach that can be launched within a few weeks with the right support. C2D Prévention offers an assessment to start from your actual situation, not a generic template.
Conclusion
Just two years ago, discussing climate change in a DUERP or an annual prevention plan seemed like forward-thinking environmental commitment, not a regulatory necessity. That time is over.
Since 1 July 2025, heat is an occupational risk on par with noise, chemical hazards, or falls from height. It has its own chapter in the Labour Code, its own alert thresholds, its own mandatory measures, and its own penalties.
The 2026-2030 National Occupational Health Plan, launched on 5 June 2026, makes it one of its five national priorities.
The question is no longer whether your company is affected. It is. The question is whether your management is ready.
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