OSHA doesn’t have a specific standard for cold (or heat) stress. But OSHA doesn’t need one to hold you liable for failing to protect workers from extreme cold.
That’s because the OSHA General Duty Clause, Sec. 5(a)(1) of the Occupational Safety and Health Act, says that every employer must safeguard workers against “recognized hazards” that can cause great bodily harm or death. Although more vocal on the heat stress side, OSHA has long taken the position that cold stress may be a “recognized hazard” covered by the GDC. As a result, it expects employers to take steps to protect their workers against cold stress.
Cold Stress—What Does OSHA Require?
Over the years, OSHA has had much more to say about heat stress than cold stress. But there is some OSHA guidance we can use to figure out what’s expected. The closest thing to official OSHA guidance is a Safety and Health Guide on Cold Stress that OSHA issued a few years back.
The first thing the Guidance clarifies is when cold stress becomes a recognized hazard. It’s not temperature alone, the Guidance says. It’s how cold the air actually feels on the body. The Guidance cites 4 factors that employers must consider in determining how cold is too cold:
Mere lack of comfort isn’t determinative. A cold stress hazard exists when the working climate makes the risk of cold-induced problems a real one. The Guidance cites 3 of the most common problems:
The Guidance lists 4 kinds of protective measures that employers should take to prevent workers from suffering cold stress:
1. Require Protective Clothing
First, you need to ensure workers exposed to cold stress wear protective clothing. The Guidance sets out 6 things employers must make workers do:
2. Implement Work Practices
The Guidance calls on employers to implement steps to ensure the work is done safely such as:
3. Use Engineering Controls
Employers should use things like radiant heaters, shields, insulating materials and other engineering measures to make the air warmer.
4. Provide Safety Training
Last but not least, employers need to train workers about the dangers of cold stress, how to recognize when cold stress occurs and how to respond if they experience or see one of their co-workers experiencing such symptoms.
One of the best ways to comply with these requirements is to adopt a written cold stress exposure plan for your workplace. Although you need to tailor the plan to your own particular circumstances, the Model Policy in TOOLS is a good illustration of what to include. Like ours, your plan should:
Explain Purpose. Help workers understand the dangers they are trying to prevent, such as frostbite and hypothermia, by explaining them in the policy.
Require Periodic Monitoring of Temperature, Wind Chill, and Other Factors. The obligation to protect workers against cold stress involves monitoring temperature and wind chill levels.
Require Supervisors to Protect Workers Subject to Cold Exposure. Your supervisors should also monitor workers performing light, moderate or heavy work. While moderate work provides a warming effect, heavy work produces perspiration which makes workers more vulnerable to cold stress injuries. Another important factor is whether working conditions are wet — which would require additional protection — or dry.
Make Workers Work in Groups. Cold stress problems can creep up on a worker before he realizes what’s going on. The best way to protect your workers is to have them work together, putting each worker in charge of another’s safety.
Provide for Worker Training. The plan should require somebody at your facility to train all workers and supervisors about the signs, symptoms and prevention of cold stress. Too many workers regard being cold as a mere discomfort, something a “real man” (or woman) wouldn’t complain about.
Go to the SafetySmart Compliance Heat and Cold Stress Compliance Center to get more help complying with OSHA electrical safety requirements: