Winter is Coming: Protecting Your Employees in Cold Weather

The winter season extends from December through February and will be here before you know it bringing the potential hazards associated with winter with them. According to the National Oceanic and Atmospheric Administration (NOAA), snow forecasts are generally not predictable more than a week in advance. So, it is not too early to prepare your business for winter weather events – even if you currently see blue skies and not a snowflake in sight.

“BUT WAIT!” you may think, “Aren’t I on the CANA blog? Why are they talking about the weather?” My response is – to keep your employees safe and your business protected from the cost of safety violations. Because that is what we do at Regulatory Support Services for CANA Members and the funeral profession. We want to remind you to be prepared for the effects of winter, particularly as NOAA predicts some areas of the hemisphere to feel colder and snowier than last year. Read on.

Although the Occupational Safety and Health Administration (OSHA) does not have specific standards which cover working in cold temperatures, employers have a responsibility to provide employees with a working environment which is free from recognized hazards, including winter weather related hazards, which are likely to cause death or serious physical harm to them (Section 5(a)(1) of the Occupational Safety and Health Act of 1970). Here are 8 ways you can prepare your employees for the winter weather ahead:

1. Train Employees to Recognize Cold Stress

What is cold stress?

Cold stress refers to environmental conditions (e.g., air temperature/humidity, windchill temperature, rain, and inadequate clothing for protection) in which body heat is lost to the environment at a rate that is faster than the body can produce heat. When the body is unable to warm itself, serious cold-related illnesses and injuries may occur, and permanent tissue damage or even death may result. Examples of cold stress include trench foot, frostbite, and hypothermia.

Cold stress and its effects can vary across different areas of the country. In regions that are not used to winter weather, near freezing temperatures are considered factors for “cold stress.” Increased wind speed also causes heat to leave the body more rapidly (wind chill effect). Wetness or dampness, even from body sweat, also facilitates heat loss from the body. OSHA provides a guide – Cold Stress Safety and Health Guide – which expands upon these topics and can assist in the recognition of cold stress and actions that can be taken to address it.

2. Train Employees to Respond

Use the resources made available to you to train your employees to respond effectively to the onset of cold stress including topics outlined below:

• How to recognize the symptoms of cold stress, prevent cold stress injuries and illnesses
• The importance of self-monitoring and monitoring coworkers for symptoms
• First aid and how to call for additional medical assistance in an emergency
• How to select proper clothing for cold, wet, and windy conditions
• How to navigate winter weather related hazards such as slippery roads and surfaces, windy conditions, and downed power lines
  

3. Implement Safe Work Practices

Safe work practices which can be implemented by employers to protect employees from injuries, illnesses and fatalities include:

• Providing employees with the proper tools and equipment to do their jobs
• Developing work plans that identify potential hazards and the safety measures that will be used to protect employees
• Scheduling maintenance and repair jobs for warmer months
• Scheduling jobs that expose employees to the cold weather in the warmer part of the day
• Avoiding exposure to extremely cold temperatures when possible
• Limiting the amount of time spent outdoors on extremely cold days
• Using relief employees to assign extra employees for long, demanding jobs
• Providing warm areas for use during break periods
• Providing warm liquids to employees
• Monitoring employees who are at risk of cold stress
• Monitoring the weather conditions during a winter storm, having a reliable means of communicating with employees and being able to stop work or evacuate when necessary
• Having a means of communicating with employees, especially in remote areas
• Knowing how the community warns the public about severe weather: outdoor sirens, radio, and television
• The National Oceanic and Atmospheric Administration (NOAA) provides multiple ways to stay informed about winter storms. If you are notified of a winter storm watch, advisory or warning, follow instructions from your local authorities: NOAA Weather Radio
  

4. Train Employees with High Weather Exposure Responsibilities to Dress Properly for the Cold

Dressing properly is extremely important to preventing cold stress. An employee should wear:

• At least three layers of loose-fitting clothing
• An inner layer of wool, silk or synthetic (polypropylene) to keep moisture away from the body
• A middle layer of wool or synthetic to provide insulation even when wet
• An outer wind and rain protection layer that allows some ventilation to prevent overheating
• A Knit mask to cover face and mouth as is appropriate for the situation
• A Hat that will cover both ears and will help reduce the loss of body heat
• Insulated gloves to protect the hands
• Insulated and waterproof boots to protect the feet
  

5. Consider Providing Protective Clothing that Provides Warmth

Employers must provide personal protective equipment (PPE), for example, fall protection, when required by OSHA standards to protect employees’ safety, and health. However, in limited cases specified in the standard, there are exceptions to the requirement for employers to provide PPE to employees. For instance, there is no OSHA requirement for employers to provide employees with ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen. However, depending on the employee’s assigned responsibilities, many employers provide their employees with winter weather gear such as winter coats/jackets and gloves.

Learn more about PPE requirements and how to design an effective PPE program: Personal Protective Equipment.

6. Prevent Slips on Snow and Ice

This may seem obvious, but it must be mentioned. To prevent slips, trips, and falls, employers should clear walking surfaces of snow and ice, and spread deicer, as quickly as possible after a winter storm. In addition, the following precautions will help reduce the likelihood of injuries:

• Wear proper footwear when walking on snow or ice is unavoidable because it is especially treacherous
• Wear a pair of insulated and water-resistant boots with good rubber treads should be worn for walking during or after a winter storm
• Take short steps and walk at a slower pace to optimize reaction time when it is necessary to quickly respond to a change in traction while walking on an icy or snow-covered walkway
  

7. Plan Ahead for Safe Snow Removal

• Provide required fall protection and training when employees are working on the roof, in trenches, or on elevated heights
• Ensure ladders are used safely
• Use extreme caution when working near power lines
• Prevent harmful exposure to cold temperatures and physical exertion
  

OSHA has prepared a guide to safe snow removal. You can find it here: Snow Removal: Know the Hazards (osha.gov)

Regulatory Support Services encourages you, at this time, to review your winter weather plans, assure your employees are properly trained, and determine whether the supplies and equipment needed to protect against winter hazards are available to you and your employees. Contact us if you need assistance in reviewing your winter hazards plan or would like additional information to assist you in enhancing your plan for protection. Stay warm. Stay safe.

This post, originally published in January 2021, is provided by Regulatory Support Services, Inc. for informational purposes only. Nothing contained in this publication should be construed as legal advice. It is always recommended that you consult your legal counsel for legal advice specific to your business.

CANA members receive a 10% discount on annual contract for OSHA and other training, services, and guidance from Paul Harris and Regulatory Support Services.
Not a member? Consider joining your business to access tools, techniques, statistics, and advice to help you understand how to care for your employees to care for your business.

Paul Harris is President and CEO of Regulatory Support Services, Inc., a company founded in 1994 and specializing in regulatory compliance consultation to the death care profession. He holds a North Carolina Funeral Service license and prior to joining the company was the Executive Director of the North Carolina Board of Funeral Service from 2004 until early 2012. Additionally, Paul served as the OSHA compliance officer for a large North Carolina-based funeral home and has 30 years of first-hand knowledge of regulatory compliance issues.