Dubai recorded its highest temperature on record twice in two consecutive days in May 2025, reaching 51.6 degrees Celsius (124.9 degrees fahrenheit). That broke the previous record of 50.2 degrees set in 2009 by a margin that took the meteorological community by surprise. The events occurred in May, before the United Arab Emirates (UAE) and Kuwait had activated their standard midday work bans for the year. Those bans do not take effect until June 15 in most Gulf Cooperation Council (GCC) countries. The gap between where dangerous heat is arriving and where formal protections begin is widening every season.
This is not a localized phenomenon. Wet bulb temperature spikes have been documented in coastal areas of Pakistan, Bangladesh, India, and across the Persian Gulf over the past three years. Recent climate data confirms that dangerous heat and humidity combinations in the Gulf no longer dissipate after dark, occurring overnight as well as during peak afternoon hours. This shift in nighttime temperatures changes the operational calculus for facilities and industries running extended or overnight outdoor shifts.
In June 2025, Human Rights Watch (HRW) warned that millions of migrant construction and industrial workers across Saudi Arabia, the UAE, Qatar, and Kuwait are continuously exposed to life-threatening heat. The rights group noted that existing policy frameworks, such as calendar-based midday work bans, are inadequate and fail to protect workers from extreme temperatures.
What the Wet Bulb Globe Temperature Index Measures and Why It Changes the Standard
The Wet Bulb Globe Temperature (WBGT) index accounts for temperature, humidity, wind speed, and solar radiation simultaneously. It produces a single number that reflects physiological heat load more accurately than ambient temperature or heat index alone. At a WBGT of 32 degrees Celsius, research documents severe heat strain in acclimatized workers. At 35 degrees, the body's evaporative cooling mechanism fails, and heat illness becomes a near-certainty under sustained exposure.
Qatar is the only GCC country that has incorporated WBGT measurements into national labor legislation, requiring employers to use WBGT instruments in the field and adjust work-rest cycles based on real-time readings. All other GCC countries rely on calendar-based and hour-based bans. The Occupational Safety and Health Administration (OSHA) in the United States is moving toward a similar WBGT-anchored threshold framework through its proposed heat injury and illness prevention rule, which has been advancing through the regulatory process since the notice of proposed rulemaking opened in August 2024. The underlying science is converging on the same standard across jurisdictions. The compliance question for multinationals is whether their Gulf and South Asian protocols are ahead of that convergence or behind it.
Gulf Midday Bans Are Timed to the Wrong Part of the Day
Research conducted in Saudi Arabia and cited in HRW's 2025 analysis found that peak heat intensity for outdoor construction and industrial workers falls between 9 a.m. and noon. The standard GCC midday ban runs from noon to 3 p.m. Workers employed by companies that comply fully with the ban still face their highest physiological heat load in the hours immediately before it takes effect. The ban was designed around a commonsense assumption about when the day is hottest at ground level. Field measurement data shows that assumption is wrong for workers performing physical labor.
Bahrain's annual midday outdoor work ban for 2026 is set from June 15 to August 31, prohibiting outdoor labor under direct sunlight between 12:00 PM and 4:00 PM. While advocates and civil societies continue to campaign for the longer three-month window seen in 2025 (June 15 to September 15), the regulation still relies on fixed calendar dates and hours rather than dynamic heat thresholds. HRW documented cases in the same report of workers having wages deducted for resting during working hours outside ban periods, which points to a gap between written policy and operational enforcement that regulators and institutional buyers are increasingly scrutinizing.
Temperature Records in 2025 Signal That the Safe Working Window Is Contracting
The May 2025 Dubai temperature records arrived in a month when cooling infrastructure protections had not yet been activated and when internal corporate heat response plans at many multinational operations treat conditions as manageable. Kuwait recorded similarly extreme temperatures during the same period. Climate Analytics research notes that while 35 degrees Celsius wet bulb is widely treated as the outer physiological limit, direct-exposure models for workers performing physical tasks place the practical threshold closer to 32 degrees, a level that is being reached across the Gulf during daylight hours for longer periods each year.
The operational window during which safe outdoor work can be scheduled without active cooling and rest rotation protocols is narrowing from both ends of the day. Facilities that set summer operations schedules based on five-year-old ambient temperature baselines are carrying a gap between their formal protocols and actual site conditions.
Where the Legal and Reputational Exposure Lives for Multinationals
The EU Corporate Sustainability Due Diligence Directive (CSDDD), which entered a key operationalization phase in 2026, extends duty of care obligations to conditions at supplier facilities and contracted labor operations, not just direct employees. For any multinational with tier-one or tier-two supply chain operations in the Gulf or South Asia, heat-related worker harm at a contractor site is now a diligence question, not just a local regulatory matter.
The compliance review question for EHS and operations leaders is specific: has the heat safety policy governing each operating geography been reviewed against 2025 WBGT data for that location? Not against regulatory minimums, and not against internal policies written before the last three years of temperature records. The science on where the threshold is has been settled. The question is whether the policy reflects it.
