Even if the latest polar vortex has ended by the time you read this, employers in most parts of the continent should be worrying about protecting workers against winter weather. Occupational safety and health regulators include “environmental” hazards as those that may require employers to provide their employees with personal protective equipment (PPE), and employers also bear a “general duty” to protect workers against recognized hazards. These requirements cover potential harm from extreme temperatures including cold, as well as slippery surfaces and other hazards from frozen and melting snow or other precipitation.
Agency regulations cover many situations, and guidelines are available for more. For example, the U.S. Occupational Safety and Health Administration’s (OSHA) PPE standards address cold, and its working surface standards address slipperiness. OSHA also provides a Winter Weather web page with additional information.
How Cold Is Too Cold For Your Workers?
Cold forces workers’ bodies to work harder to maintain their internal temperature and protect their extremities. Whenever temperatures drop below normal and wind speed increases, heat tends to leave the body more rapidly. The agencies do not define “too cold,” and instead offer the sensible observation that temperature, humidity, wind chill, and duration of exposure all affect the degree of cold stress workers may experience (although the Centers for Disease Control and Prevention (CDC) note that hypothermia is a bigger risk in most situations colder than 40 o F). Workers’ degree of acclimatization to conditions also matters – are they working in a storm, during a cold snap, or in a period when they’ve had time to adjust to conditions (as a Californian, I’m likely to have more trouble adjusting than a Minnesotan)?
Different individuals respond differently to the same environmental conditions, so employers should consider members of their workforce individually. As noted by OSHA, individual risk factors that contribute to cold stress include:
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Wetness/dampness, dressing improperly, and exhaustion.
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Predisposing health conditions such as hypertension, hypothyroidism, and diabetes.
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Physical conditioning.
Individual activities also matter. In general, an active individual (chopping trees and removing obstructions after a storm, for example) will generate more body heat than someone who is more sedentary.
How Can Cold Stress Be Managed?
Agencies provide the following general guidance for management of cold stress:
Training. Employers should train workers how to prevent and recognize cold stress illnesses and injuries (including hypothermia, frostbite and trench foot), and how to apply first aid. Workers should be trained on the appropriate engineering controls, clothing and PPE, and work practices.
Engineering controls. Employers should provide engineering controls. For example, radiant heaters can be provided to warm workers in outdoor security stations. Work areas should be shielded from drafts or wind to reduce wind chill to the extent possible.
Equipment. For work below the freezing point, metal handles and bars should be covered by thermal insulating material. Also, machines and tools should be designed for operation without removing mittens or gloves.
Clothing and PPE. Proper dress is extremely important to preventing cold stress. The type of fabric also matters. For example, cotton loses its insulation value when wet, but wool, silk and most synthetics do not. OSHA recommend the following for working in cold environments:
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Wear at least three layers of loose fitting clothing, including an inner layer of wool, silk or synthetic to keep moisture away from the body, a middle layer of wool or synthetic to provide insulation even when wet, and an outer wind and rain protection layer that allows some ventilation to prevent overheating.
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Wear a hat or hood (half or more of body heat loss is from the head).
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Use a knit mask to cover the face and mouth (if needed).
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Use insulated gloves to protect the hands (water resistant if necessary).
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Wear insulated and waterproof boots (or other footwear) and warm socks.
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Wear face and eye protection; especially in extremely cold conditions, eye protection should be separated from the nose and mouth to prevent exhaled moisture from fogging and frosting eye shields or glasses. Select protective eye wear that is appropriate for the work, and for protection against ultraviolet light from the sun, glare from the snow, blowing snow/ice crystals, and/or high winds at cold temperatures.
Safe work practices. For example,
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Give workers frequent breaks, in warm areas.
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Allow (or even instruct) workers to interrupt their work if they are extremely uncomfortable.
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Pace work to avoid excessive sweating; if such work is necessary, provide proper rest periods in a warm area and allow employees to change into dry clothes.
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Allow warm-up time, should be provided at the start of each work shift.
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Allow new workers and those returning after time away from work to acclimatize by gradually increasing their workload, and allowed more frequent breaks in warm areas as they can build cold tolerance.
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Provide plenty of warm sweetened liquids to workers to prevent dehydration.
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If possible, schedule heavy work during the warmer part of the day.
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If possible, assign workers to tasks in pairs (buddy system), so they can monitor each other for signs of cold stress.
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Maintain walking and working surfaces to minimize slipping hazards.
Surveillance and Monitoring. The Canadian Centre for Occupational Health and Safety (CCOHS) recommends that every workplace where the temperature may fall below 16°C (60.8°F) should be equipped with a suitable thermometer to monitor any further temperature changes. For colder workplaces with temperatures below the freezing point, the temperature should be monitored at least every 4 hours. For indoor workplaces, whenever the rate of air movement exceeds 2 meters per second (5 miles per hour) it should be recorded every 4 hours. In outdoor workplaces with air temperature below the freezing point, both air temperature and wind speed should be recorded.
Emergency Procedures. Procedures should be established for providing first aid and obtaining medical care. For each shift, at least one trained person should be assigned responsibility to respond to cold-related emergencies.
How Do We Use This Information?
If employees work indoors in conditioned spaces, then employers’ primary concern is for travel, and emergency situations. If at least some employees work outdoors, then employers must also consider the range of conditions, including predicted or unexpected cold snaps and even the possibility of weather-related emergencies (in some areas, this can include extreme hot weather at other times; I wrote about these issues here).
Self-Assessment Checklist
Do any of the organization's workers work in situations where ambient temperature may create a hazard of cold stress:
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Outdoors (e.g., construction, utility, or post-storm work)?
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Indoors (e.g., work in refrigerators or in processes involving cryogenic materials or equipment)?
Does the organization conduct activities in areas subject to extreme cold weather, even if extreme conditions are not routine?
If so, does the organization provide appropriate:
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Training?
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Engineering controls?
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Equipment?
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Clothing and PPE?
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Safe work practices?
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Surveillance and monitoring?
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Emergency procedures?
Where Can I Go For More Information?
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OSHA Winter Weather webpage
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OSHA Cold Stress Guide webpage
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Centers for Disease Control and Prevention (CDC) “Natural Disasters and Sever Weather" webpage
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National Fire Protection Association (NFPA) educational documents:
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Canadian Centre for Occupational Health and Safety (COHS) Cold Environments webpage
Specialty Technical Publishers (STP) provides a variety of single-law and multi-law services, intended to facilitate clients’ understanding of and compliance with requirements.
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 25 years.
Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).
Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).
You may contact Mr. Elliott directly at: tei@ix.netcom.com