etween 1979 and 2002, an average of 689 U.S. workers died as a result of exposure to extreme cold. Of course, construction, fishing, maritime, farming and other outdoor workers are particularly vulnerable; but what you may not realize is that cold stress deaths aren’t just a winter phenomenon; many of the workers who succumb to cold stress work in freezers, cold storage facilities and other indoor workplaces.
Here’s a look at the risks posed by cold stress all year-round and the 8 practical measures necessary to manage them.
Liability for Cold Stress
OSHA Cold Stress Requirements
Although it’s recognized as a work hazard, cold stress isn’t covered in any specific OSHA standard. But that doesn’t mean employers can ignore the hazard. The duty to protect workers—indoors or outdoors—from cold stress comes not from an OSHA standard but the so called General Duty Clause (GDC), Sec. 5(a)(1) of the Occupational Safety and Health Act.
The GDC requires employers to protect workers from other “recognized hazards” likely to cause death or serious bodily harm. Over the years, OSHA has made it abundantly clear that cold stress may be a “recognized hazard” covered by the GDC. (See, for example, OSHA’s Safety and Health Guide on Cold Stress.)
Compliance Game Plan: 8 Steps to Take
There are 8 basic steps to take to protect workers from cold stress:
The first step is to perform a cold stress hazard assessment. To identify cold stress hazards you need to understand that the human body functions normally when it has a “core” temperature of 98.6° F. Although 1° or 2° doesn’t generally make a big difference, if core temperature drops too low it can lead to problems such as:
The next step is to figure out if the environmental conditions of the work place create cold stress dangers. Degree of exposure to cold stress is based not on comfort but what’s called thermal comfort, or how the air actually feels to the worker since it’s how the air feels that determines the impact on core body temperature. Risk factors to consider:
The key to controlling workers’ exposure is to figure out where the thermal comfort danger line is and ensure that workers aren’t exposed to such levels (or if they are exposed are only exposed for a short, safe period). Unfortunately, the OSHA guidance doesn’t specify how cold is too cold.
Best practice dictates limiting exposure to safe levels using Threshold Limit Values (TLVs), a measurement created by a nongovernment organization called the American Conference of Industrial Hygienists (ACGIH) to define the maximum exposure limits for cold.
The next step is to use appropriate instruments to continually monitor temperature and wind chill levels to ensure that thermal conditions are within safe ACGIH TLV levels.
As with other hazards, the preferred method of protecting workers from cold stress is to adopt engineering controls to eliminate or reduce the hazard. In the context of cold stress, engineering controls would involve use of methods to change the environment to ensure that exposure is kept at safe TLVs including:
The next layer of controls to use when cold stress hazards can’t be eliminated or engineered away is to change how the work is done so that it’s safer. So called work and administrative controls for cold stress include:
The last line of defense, which should normally be used in combination with rather than in lieu of engineering controls, is to ensure workers have and use appropriate protective clothing and PPE. For cold stress, this would include dressing in layers and wearing:
A proper cold stress training program should include:
Implementation Strategy: Create a Cold Stress Plan
One of the most effective ways to implement all these measures is to incorporate them into a Cold Stress Plan. There’s no such thing as a one-size-fits-all plan. Details of your own plans will vary according to your industry, facility type, work process, etc. But the Model Plan in the TOOLS section of the SafetySmart Heat and Cold Stress Compliance Center lays out the fundamental elements a basic plan should include and can be adapted for your own workplace.