#0092 "We have air conditioning, so we're fine"—The reason why that CEO's complacency might invite a corrective recommendation from the Labor Standards Inspection Office

#0092 | Version V2 | Character count: 10,277 characters | Updated: 2026.08.17

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"Our offices and factories have air conditioning, so heatstroke prevention is something for companies with field workers to worry about"—honestly, there are quite a few fellow business owners who think this way.

If you read this article and check your company's heatstroke prevention system today, you may be able to prevent corrective recommendations from the Labor Standards Inspection Office, potential document referrals to prosecutors in the worst-case scenario, and even the risk of civil liability amounting to millions of yen that could arise in the event of a labor accident.

If you are currently thinking, "It doesn't apply to us because we have air conditioning," please stop for a moment.

In fact, it is not widely known that the state of "having air conditioning" does not necessarily mean you are exempt from the requirements.

If you are about to just hit 'like' on this article and move on, could you spare just a little more time?

From this point on, I will write about what exactly President Sasamoto, who runs a printing company, was pointed out by the Labor Standards Inspection Office, and where the difference lay compared to President Miyazono of a logistics company in the same region who took proactive measures.

Table of Contents

• Chapter 1: "We have air conditioning, so we're fine"—What CEOs who think this way often overlook

• Chapter 2: June 2025, the content of the Industrial Safety and Health Regulations that changed quietly

• Chapter 3: It's not just "outdoor sites," the real line for the scope of application

• Chapter 4: The fact that penalties are imposed not just "after an accident occurs," but even for "simply lacking a system"

• Chapter 5: The points raised to fellow business owner President Sasamoto of the printing company

• Chapter 6: In contrast, the case of President Miyazono of the logistics company who took action in advance

• Chapter 7: Original checklist "5-Stage Diagnosis for Heatstroke Prevention and System Development"

• Chapter 8: What was the score for President Sasamoto's company after the diagnosis?

• Chapter 9: Three practical responses you can start today

• Chapter 10: Concrete methods to prepare WBGT measurements and procedure manuals without spending money

• Chapter 11: Starting September 2026, how to reduce countermeasure costs with the Business Improvement Subsidy

• Chapter 12: The fact that freelancers and sole proprietors will also be covered starting April 2026

• Chapter 13: The first step you can take today before closing this article

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Chapter 1: "We have air conditioning, so we're fine"—The more a president thinks this, the more they are overlooking

When midsummer arrives, the topic of heatstroke prevention comes up more frequently among fellow business owners.

However, most of these conversations are about fellow business owners in the construction or transportation industries, such as "reminding outdoor field workers to hydrate" or "setting up rest areas at construction sites."

Presidents of companies focused on office work or those with air-conditioned factories often respond by saying, "That has nothing to do with us."

However, a story I recently heard from a fellow business owner made me realize that this very perception is becoming outdated.

"Heatstroke prevention has already become a 'duty.' And it's not limited to outdoor field work," they said.

Honestly, when I first heard this, I found it hard to believe.

The conventional wisdom has always been that if you have an air-conditioned office or a factory with air conditioning, you are immune to heatstroke.

However, upon investigation, I found that due to the regulatory changes enacted in June 2025, this very perception is already becoming obsolete.

Chapter 2: June 2025, the quietly changed contents of the Industrial Safety and Health Regulations

On June 1, 2025, the revised Industrial Safety and Health Regulations were enforced, making it mandatory for business operators performing work in hot environments to take measures to prevent heatstroke, with penalties for non-compliance.

This amendment applies to all business operators, regardless of the size of the company.

The content of the mandate is broadly composed of three stages: "detecting," "judging," and "responding."

"Detecting" refers to establishing a system to discover early signs of distress in workers who may be at risk of heatstroke.

It is necessary to pre-establish a mechanism where workers who feel unwell during work can immediately report it to those around them or their supervisors, and a system where others can contact someone if they notice any abnormalities.

"Judging" refers to ensuring that on-site personnel can appropriately determine whether the abnormality is due to suspected heatstroke.

And "responding" refers to preparing written procedures in advance for specific emergency measures, such as stopping work, cooling the body, and transporting the worker to a medical institution if necessary, once it is judged that there is a suspicion of heatstroke.

What was previously limited to the realm of mental fortitude and voluntary goals, such as "it's hot, so let's be careful," has been upgraded by this amendment to a legal obligation to establish the system itself.

The background to the Ministry of Health, Labour and Welfare's decision to implement this amendment is the reality that the number of deaths from occupational accidents due to heatstroke has remained high in recent years.

It was judged that there were limits to the effectiveness of mere appeals and awareness-raising, and the direction was shifted toward a more proactive form of regulation that mandates the system itself.

With the average summer temperature itself continuing to rise year by year, it is best to assume that this trend is unlikely to ease in the future.

In other words, regardless of whether a heatstroke incident has actually occurred, the situation has changed so that the mere lack of such systems or procedure manuals can already constitute a violation of the law.

Chapter 3: The true scope of the target, which is not limited to "outdoor sites only"

The most easily overlooked aspect of this amendment is the scope of work covered.

The mandate applies to work expected to be performed for one hour or more continuously, or for a total of more than four hours per day, in an environment where the WBGT (Wet Bulb Globe Temperature) is 28 or higher, or the temperature is 31 degrees Celsius or higher.

WBGT is an index for measuring heatstroke risk that is calculated by including not only air temperature but also humidity and radiant heat (the influence of sunlight and heat from the surroundings), and it is considered to show a level of danger closer to reality than simple thermometer readings.

What is important here is that this condition does not distinguish between "outdoors or indoors."

Even in an office with air conditioning, environments with a WBGT of 28 or higher or a temperature of 31 degrees Celsius or higher can actually occur in areas where the air conditioning is weak, in conference rooms where large numbers of people gather, or in work areas near heat-emitting equipment such as printers or kitchen appliances.

Workplaces such as warehouses and factories, areas near loading docks, work at heights where air conditioning is difficult to reach, or environments that tend to become hot and humid like kitchens and dry cleaning plants are all typical examples that could be subject to these regulations.

The assumption that "it doesn't apply to us because we are indoors" or "we are exempt because we have air conditioning" may be nothing more than a presumption made without actually measuring the temperature and humidity.

What the system requires is not such assumptions, but rather objectively determining whether the work is subject to the regulations based on actual WBGT value measurements.

Chapter 4: The fact that penalties are imposed not just "after an accident occurs," but simply for "lacking a system"

Another point often overlooked in this system revision is the conditions under which penalties are imposed.

Many fellow business owners think, "As long as no actual accident occurs, such as a worker collapsing from heatstroke, we won't be subject to penalties."

However, in reality, the mere fact that the mandated systems and procedure manuals are not in place is grounds for a citation by the Labor Standards Inspection Office.

The penalty for a violation is imprisonment for up to 6 months or a fine of up to 500,000 yen for the individual responsible (such as a site manager), and under the dual punishment provision, the corporation is also subject to a fine of up to 500,000 yen (the corporation itself is not subject to imprisonment).

Furthermore, even before reaching the stage of applying penalties, if deficiencies are found during an on-site inspection (labor inspection) by the Labor Standards Inspection Office, corrective recommendations or guidance will be issued.

While a corrective recommendation itself does not carry a direct penalty, if the pointed-out issues are left unaddressed, the risk of more serious administrative guidance or eventual referral to the public prosecutor's office increases.

In addition, should a worker actually fall into a serious condition due to heatstroke, the business operator may face civil liability for damages based on a breach of the duty to ensure safety.

Such civil damages, depending on the degree of residual disability and the calculation of lost earnings, often reach a scale of several million to over ten million yen.

In other words, what is truly being questioned by this system is not "whether an accident occurred," but the single point of "whether the necessary systems were in place before an accident could occur."

Labor Standards Inspection Office on-site inspections are not necessarily conducted with the sole purpose of checking heatstroke countermeasures.

There is an increasing number of cases where, when an investigation is triggered by other labor issues such as long working hours or unpaid overtime, the status of heatstroke countermeasure systems is also checked.

If you are complacent, thinking "it's unlikely they will come to investigate just for heatstroke countermeasures," you may find yourself confronted with deficiencies in an unexpected situation.

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