The American Apparel & Footwear Association has issued guidance to address heat stress—the first fashion trade group to set maximum workplace heat thresholds, recommend structural mitigation strategies and promote shared responsibility between buyers and suppliers.

The move was a long time coming, said Nate Herman, AAFA’s executive vice president. As the world gets warmer and garment workers in the global South continue to bear the brunt of rising temperatures, protecting them has never been more urgent. Amid increasingly dire reports, a growing body of pilot projects and best practices is also beginning to emerge, though clear direction on how to scale them remains elusive.

The numbers also lay bare a mounting crisis: garment manufacturing hubs in South and Southeast Asia now regularly record more than 100 days each year with temperatures at or above 35 degrees Celsius, or about 95 degrees Fahrenheit. A study of garment workers in Cambodia found that 64 percent of 100 surveyed workers recorded core temperatures above 38 degrees Celsius—considered unsafe—at least once in a seven-day work period. In India, 87 percent of 115 garment workers polled reported heat-related ailments such as headaches, dizziness, weakness and muscle cramps in the past year. In Bangladesh, one woman described her predicament in stark terms: “My body is burning.”

At the same time, “there’s no major guidance,” Herman said. “There have been recommendations in many of these reports, but no guidance on how to implement those recommendations or what specifically you should do to operationalize efforts to protect workers from heat stress.”

The AAFA didn’t create its recommendations in a vacuum, instead consulting a range of expert stakeholders such as Cornell ILR School’s Global Labor Institute, the Fair Labor Association, the International Labour Organization’s Better Work program, the International Accord for Health and Safety in the Textile and Garment Industry, the AFL-CIO, the International Trade Union Confederation and individual brands, retailers and manufacturers. Nor did it want to take a cookie-cutter approach to different geographies with their own national laws—or, in some cases, a lack thereof.

Factories also vary widely in capability, Herman said. Not all can jump in with the expertise or resources to install monitors that track temperature and humidity. Few, aside from the largest suppliers, can afford air conditioning.

“We didn’t want this to be something that the buyers are imposing on suppliers,” he said. “This is something that can work and hopefully will work for everyone involved in the supply chain.”

Jason Judd, executive director of the Global Labor Institute, which has spearheaded extensive research on heat stress and garment workers, agreed that extreme heat in apparel production, much like building safety, isn’t a “should” or “nice to have” issue.

“The science is clear,” he said. “The rules aren’t complicated. The tech is well-known. So the measure that matters will be the share of workers in high heat stress factories who are safe in 12 and 24 months and able to cope—at work and at home—with what comes next.”

Even so, Judd said he would like to see the framework go beyond informed suggestions. For starters, the AAFA and its members could join binding agreements that address these issues. They could also begin collecting—within weeks, not years—real-time heat stress data and work with workers, management and governments to determine how best to enforce the rules.

Other central questions: Who pays to put the recommendations into practice? And which ones?

Herman said the AAFA strongly recommends that buyers work with suppliers to support responsible purchasing practices that enable heat mitigation measures, including covering the associated costs. Suppliers, in turn, must engage directly with workers on the front lines of the issue.

“They know the parts of the factories that are the hottest at certain times here, and the reasons why, and so the suppliers need to be working with the workers and the buyers need to be working with the suppliers,” he said. “Because in order to protect workers from heat stress, sometimes you have to change timelines or change processes.”

For Sonia Mistry, director of climate and labor at the Solidarity Center, the largest U.S.-based international worker rights organization, technical fixes alone aren’t enough. Ensuring workers can organize and bargain collectively across the supply chain, she said, is just as crucial.

“Based on our research, we know that unionized workers experience half as much heat stress as non-unionized workers because they are able to bargain over these issues,” Mistry said. “Ensuring that workers have an enforceable mechanism for raising concerns, participating in the design and implementation of protections, and reporting gaps in enforcement will ensure these guidelines deliver real results for impacted workers.”

From guidance to action

What that guidance looks like in practice is still evolving. For now, the AAFA advice outlines specific temperature and humidity thresholds to identify high-risk conditions and inform workplace safety protocols. Global occupational guidelines generally set maximum temperatures of 29-30 degrees Celsius (84.2-86 degrees Fahrenheit) for high-intensity work, 30-31 degrees Celsius (86-87.9 degrees Fahrenheit) for moderate-intensity work, and 31.5-32.5 degrees Celsius (88.7-90.5 degrees Fahrenheit) for low-intensity work.

In the long term, however, it says the best approach is to place Wet Bulb Globe Temperature monitors at various factory locations, collect and track data over five years, and develop excessive heat thresholds based on that data. This ensures the thresholds are tailored not only to each facility but also to the most at-risk processes and areas within it.

“Thresholds are an important step in limiting the rampant impacts of excess heat in the global workplace, but heat stress is too complex to be reduced to a single number,” said Laurie Parsons, senior lecturer in human geography at Royal Holloway, University of London. 

He noted that the interplay of three factors—ambient environmental temperatures, local heat sources and physical exertion—can significantly amplify heat stress within the same room, sometimes by a factor of 10, meaning that “these kinds of occupational nuances need to be accounted for more fully.”

While the AAFA emphasizes that rest is a mandatory safety intervention, not just a production break, Parsons said the ability of workers to self-pace is also important in mitigating heat stress.

“The more pressure workers are under to work faster, the greater their risk of heat stress,” he said. “Conversely, the more power workers have in the workplace to report issues around heat and manage their own workload, the lower their risk of heat stress. So, these labor questions need to be taken seriously and incorporated to a much greater degree into any effective policy.”

Getting everyone on the same page wasn’t easy, Herman admitted. While thermometers are generally cheap and easy to install, some manufacturers were concerned about creating additional audits. As such, the guidance is designed to be woven into existing workflows rather than forcing new systems that could pose additional burdens.

Still, he said he found it enlightening that factories often don’t need “complicated, super-expensive” measures to mitigate the impact of heat stress. Adding extra water breaks and accommodating additional bathroom use also doesn’t necessarily reduce productivity, as workers may ultimately be more productive than they would be otherwise.

“And actually, not doing anything as the heat issue becomes worse is going to impact your ability to meet timelines and other things,” he said. “Also, by not addressing it, you’re going to go into situations where you’re going to have to impose an additional shift or create excess working hours, and then you’re in violation of brands’ other requirements for social responsibility, and that’s going to create other issues for you.”

Herman said the document is meant to be a “living” one, with an annual review process that incorporates new research and best practices so it stays “as relevant as possible.”

While guidance without binding mandates can amount to little more than a suggestion, he said the AAFA aims to make it easy for companies to integrate the recommendations into existing health and safety systems rather than treat them as a standalone requirement. The next step: extensive outreach, including an upcoming webinar, training sessions and conference programming.

“We already started outreach to the same organizations that provided input into the guidance, and we’re going to continue and expand those conversations over the next few months to try and get as much industry-wide adoption as possible,” Herman said. “The responsibility for protecting workers from heat stress must be shared across the supply chain.”