U.S. Department of Labor / Occupational Safety and Health Administration Form 301 — Injury and Illness Incident Report

Public reporting burden for this collection of information is estimated to average 22 minutes per response.

Case Number	Unassigned
Establishment Name	American Southwest (see attached: Arizona, California, Nevada, Utah, Idaho, New Mexico, Colorado, Wyoming, Nebraska, Kansas, South Dakota, Iowa, Minnesota, Missouri; expanding)
Employer	Civilization (general contractor). Multiple subcontractors. See Section 9.
Date of Incident	March 18–25, 2026 (ongoing at time of filing)
Time Employee Began Work	Continuous occupancy

Field 14: What was the employee doing just before the incident occurred?

Living. Working. Residing in structures rated for historical climate conditions. Approximately 5.2 million persons occupied the Phoenix metropolitan area. Approximately 2.3 million occupied Las Vegas. Occupants were not acclimatized to extreme heat. Acclimatization requires approximately two weeks of sustained exposure. Air conditioning units in many residences were winterized or not yet operational. The season, per all historical records, was spring.

Field 15: What happened?

A high-pressure ridge 3.5 to 4 standard deviations above normal settled over the Desert Southwest beginning March 18. Temperatures ran 20–30°F above average. On March 20, four stations recorded 112°F: Yuma and Martinez Lake, Arizona; Winterhaven and Buttercup, California. This exceeded the previous all-time U.S. March record by 4°F and fell 1°F short of the national April record. Fourteen states recorded their hottest March day in history. The NWS noted that Phoenix's average first 105°F day normally occurs May 22nd. Phoenix reached 105°F on March 19. NWS meteorologist Gregg Gallina: "Basically the entire U.S. is going to be hot. The area of record temperatures is extremely large."

Field 16: What was the injury or illness?

Unknown. Maricopa County's heat surveillance system generates reports weekly during heat season. Heat season has not officially begun. No confirmed fatality or hospitalization count exists for this event as of filing. For reference, Maricopa County recorded 608 heat deaths in 2024. Clark County recorded 513. Those occurred during the recognized season.

Field 17: What object or substance directly harmed the employee?

Heat. World Weather Attribution analysis found the event "virtually impossible without human-induced climate change," with likelihood increased by a factor of approximately 800.

Root Cause

See Field 17.

Corrective Actions Taken

An Extreme Heat Warning was issued for the Desert Southwest, effective Thursday through Sunday evening. Maricopa County encouraged residents to seek public indoor spaces. The county's Heat Relief Network, which coordinates free cooling centers, is scheduled to open May 1.

Corrective Actions Not Taken

The Occupational Safety and Health Administration does not have a standard that specifically addresses outdoor or indoor heat exposure. The National Institute for Occupational Safety and Health first recommended such a standard in 1972. A Notice of Proposed Rulemaking was published on August 30, 2024. The rule was not finalized. Legal observers do not expect the current administration to pursue rulemaking activity other than deregulatory actions. The Bureau of Labor Statistics reports an average of 41 occupational heat deaths per year between 2011 and 2023. No enforceable federal standard applied to any of them. The interval between recommendation and standard is now 54 years.

FEMA's Building Resilient Infrastructure and Communities program, which funded pre-disaster mitigation at up to 75% of project cost, was terminated April 4, 2025. A federal judge ruled the termination unlawful on December 11, 2025, and issued an enforcement order on March 6, 2026, with a compliance deadline of approximately March 20. As of this filing, no confirmation of compliance has been reported. The agency cited staffing shortages.

The Low Income Home Energy Assistance Program, serving approximately 6 million households, saw its entire federal staff fired on April 1, 2025. The FY2026 presidential budget proposed eliminating the program. Congress appropriated $4.045 billion. Staff have not been rehired. States are operating without federal guidance. One in six American families is behind on energy bills. Total owed: approximately $21 billion.

NOAA climate research spending was reduced from $219 million to $165 million in FY2026, a 25% cut. The FY2027 proposed budget allocates $0 for climate research.

Maricopa County's expanded heat relief efforts, which reduced deaths from 645 in 2023 to 427 in 2025, were funded by the American Rescue Plan Act. That funding expires this year. Clark County's cooling centers are not open 24 hours.

The heat dome accelerated snowmelt across the Sierra Nevada and Colorado River basin. There is no corrective action for snowpack that melts in March. There is no form for that either.

Former FEMA administrator Craig Fugate, speaking to the Associated Press on March 20, 2026:

No field on this form is designed to contain that observation. No field exists for a surveillance system that activates when heat season begins, in a year when the event arrived two months before the season. No field exists for the 22 million Americans who live in manufactured housing rated for conditions that no longer obtain in the geography where the housing sits. No field exists for snowpack that was scheduled to supply municipal water through September and is already gone. No field exists for the interval between a hazard identified in 1972 and a standard not adopted in 2026. The form was built to describe an incident. Fifty-four years is not an incident.

This form was designed to be completed in 22 minutes.

Filed by: _______________ Date: March 25, 2026