8. Natural Heat, Cold

Warm Up Your Workforce Using Hierarchy of Controls

Dec. 13, 2018
Using the hierarchy of controls to eliminate and minimize winter hazards can reduce risk and the potential for injuries.

Frosty weather forecasts and frigid wind chill warnings send many people to their closets for another layer of clothing. For employees who work outdoors in cold weather, more foresight, protection and preparation is required.

Frostbite, chilblains, hypothermia and trench foot are just a few of the hazards that cold weather inflicts upon employees working outdoors. Bulky clothing that impedes movement and inclement conditions that limit the amount of time that may be safely spent performing a task can also leave even well acclimated workers at risk.

Even though OSHA does not have a specific standard that addresses cold weather work, they do require employers to identify hazards that their employees face when performing work tasks and provide a safe workplace. Like other safety standards, even when hazards and risks cannot be eliminated, applying hierarchy of controls can help to prioritize the management of risks and minimize the potential for injuries.


When it comes to the hazards presented by cold weather, eliminating low temperatures from the equation is not possible because no one can control the weather. For utility workers, road maintenance crews, emergency medical providers and others whose job specifically involves being on the road or being outdoors, working in rain, sleet, snow, hail, wind and other inclement weather are hazards that need to be minimized using other risk management tools.

For some stationary operations, cold hazards can be eliminated by moving work that is typically performed outdoors indoors or under roof. For certain other jobs, work tasks that are performed outdoors can be postponed or suspended until spring or a time when the weather is more favorable.


Just as cold weather cannot be eliminated, it’s not possible to flip a switch and substitute warmer weather for the cold. Some substitutions can be made, however, to help minimize certain cold weather hazards.

In addition to cold injuries, the risk of slip and fall injuries greatly increases in winter months when snow and ice accumulate on walking surfaces. Substituting footwear with ice cleats for regular work shoes or boots will increase traction and reduce slip and fall risks for employees who need to walk over slippery surfaces.

Employees who need to climb ladders to perform work tasks already face multiple risks. Bad weather adds to that list. Substituting enclosed aerial lifts for ladders shields workers from the elements and eliminates the need to climb slippery ladder rungs.


Because cold weather can neither be eliminated nor can it be substituted with warm weather, the next possible way to minimize cold weather hazards is with engineering controls. Any device that helps to shield workers from the cold or helps them restore their body temperature should be considered.

One of the simplest engineering controls is wrapping the handles of metal tools to insulate them so that employees aren’t grasping cold handles. Another low-cost engineering control is to use plastic sheeting or tarps to help shield workers from drafts and cold winds.
When outdoor work is expected to take a long time, employees will need to take warming breaks. Provide mobile warming shelters or designate areas with radiant heaters to restore core body temperatures. These shelters can also be a place for providing warm beverages (which is an administrative control).

Providing warm portable toilets in addition to shelters or heaters is also an engineering control that encourages employees to stay hydrated. When faced with the reality of a chilly trek to a cold toilet, some workers will forego drinking a sufficient amount of liquids and allow themselves to become dehydrated.

Engineering controls such as warming shelters and radiant heaters are especially important for employees who are not fully acclimated to working in cold weather. Even for workers who have lived in a cold weather region for years, the first few weeks of cold weather still take some getting used to.


Although they are not as effective as engineering controls, substitution or elimination, when administrative controls are used effectively, they improve safety and minimize cold-related injuries.

Train supervisors to understand that both temperature and wind chill need to be considered when employees will be outdoors. The National Weather Service, OSHA and other national organizations have published temperature and wind chill calculators with recommended time limits to help keep anyone who will be outdoors safe. Scheduling outdoor work for the warmest part of the day, using these time limits, and requiring the use of the buddy system will minimize the chance for cold-related injuries.

Acclimating employees should begin in the early fall and should include training on proper nutrition. Workers who are well hydrated and who also avoid caffeinated or alcoholic beverages and nicotine will be less prone to dehydration, cold stress and other work-related injuries.

Employee training should also include stretching exercises and specific information to help them stay safe, such as the need to stay dry and to take frequent breaks to warm themselves. Teaching them how to recognize signs of cold stress in themselves and their coworkers, as well as basic first aid skills can prevent more serious injuries.

For employees who will be driving, develop procedures to help ensure that vehicles are ready for the day, including ice and snow removal, filling windshield washing fluid, keeping the gas tank at least half full, and packing supplies such as shovels, rock salt, emergency blankets and road flares. Employees should also be taught how to exit their vehicles properly to minimize the chance of slip and fall injuries.


In cold weather, the most visible form of protection and the last line of defense against the cold is warm, dry clothing. Dressing in loose layers helps to keep the body’s core warm and promote blood flow. Layers also allow workers to remove some clothing if they become too warm. Body extremities, including the head, hands and feet, also need to be covered because they are the first areas to become chilled.

OSHA does not require employers to provide winter clothing [29 CFR 1910.132(h)(4)(iii),] but if employees are required to provide their own to protect them from cold hazards, employers must ensure that it is adequate, properly maintained and sanitary [29 CFR 1910.132(b)]. Most employers provide winter outerwear for their employees because it allows them to incorporate other necessary safety elements such as hi-vis colors or reflective striping without adding another restrictive or bulky layer.

Adapting to working in cold weather conditions requires both employers and employees to be aware of the specific hazards that cold weather work adds to their job duties. It also requires a coordinated effort to make working conditions as tolerable as possible. Using the hierarchy of controls to eliminate and minimize hazards reduces risk and the potential for injuries. 

Karen Hamel, CSP, WACH, is a regulatory compliance professional and technical writer with New Pig Corp. (www.newpig.com), a provider of solutions that help companies manage leaks, drips and spills.

About the Author

Karen Hamel

Karen Hamel, CSP, WACH, is a regulatory compliance specialist and technical writer at New Pig Corp.

Sponsored Recommendations

10 Facts About the State of Workplace Safety in the U.S.

July 12, 2024
Workplace safety in the U.S. has improved over the past 50 years, but progress has recently stalled. This report from the AFL-CIO highlights key challenges.

Free Webinar: ISO 45001 – A Commitment to Occupational Health, Safety & Personal Wellness

May 30, 2024
Secure a safer and more productive workplace using proven Management Systems ISO 45001 and ISO 45003.

ISO 45003 – Psychological Health and Safety at Work

May 30, 2024
ISO 45003 offers a comprehensive framework to expand your existing occupational health and safety program, helping you mitigate psychosocial risks and promote overall employee...

Case Study: Improve TRIR from 4+ to 1 with EHS Solution and Safety Training

May 29, 2024
Safety training and EHS solutions improve TRIR for Complete Mechanical Services, leading to increased business. Moving incidents, training, and other EHS procedures into the digital...

Voice your opinion!

To join the conversation, and become an exclusive member of EHS Today, create an account today!