Protections from the Cold if ‘Proactive Scheduling’ Isn’t Feasible

The Occupational Safety and Health Administration (OSHA) recommends protecting employees from the cold by scheduling work during the warmest part of the day. But such proactive scheduling isn’t always feasible. Here’s why employers might need to consider other options and some examples of those alternatives.

When Proactive Scheduling May Not Work

Sometimes changing scheduled maintenance or repair jobs will be reasonably possible and other times it will not, said John Ho, an attorney with Cozen O’Connor in New York City.

For example, a building maintenance team may decide it can push off a new paint job for a building until the spring. In other situations, certain maintenance jobs can’t be delayed, so the employer will need to take protective measures against cold stress, he said.

Cold exposure may be unavoidable in energy work, outdoor construction and even manufacturing, said Courtney Malveaux, an attorney with Jackson Lewis in Richmond, Va. “In addition, some indoor employers require cold indoor environments for perishable food product storage and other cold processes year-round, and having at least limited employee exposure to cold may be necessary to maintain product,” he said.

Emergency response, overnight security, power line repair and road construction frequently must be performed at night when weather often is colder, Malveaux added.

Utility workers barely scratch the surface for employees who work in cold environments, said Travis Bennett, associate director, national casualty loss control leader with Risk Strategies Company, headquartered in Boston. Airport baggage handlers, delivery drivers, farmers, municipal workers “and so many more who we take for granted” often must work in extreme cold, he said.

If teams are scheduling regular maintenance in power or electricity and the maintenance requires systems to be shut down temporarily, the middle of the afternoon into the evening wouldn’t be an ideal time because that’s when the peak demand for power is, explained Duane Duhamel, director of health, safety and environment at ISN, a contractor and supplier information management company headquartered in Dallas. “These jobs might need to be scheduled during the colder overnight hours,” he said.

Any work involving water or that has the possibility for an employee getting wet should be done during the warmest part of the day, according to Bennett.

Alternatives to Proactive Scheduling

OSHA recognizes that when an employer cannot eliminate a hazard through proactive scheduling, feasible engineering and administrative controls can be effective. “[Those] include rest breaks in heated areas such as vehicles with interior heating; outdoor heat radiators; personal heating devices; and warm, dry clothing,” Malveaux said. OSHA notes that while warm clothing generally is not considered personal protective equipment that must be provided by employers, some organizations provide it as a precaution.

Some alternatives to proactive scheduling, Bennett said, include controls such as:

• Tents or other objects to block the wind and limit the employees’ exposure to wind chill.
• Insulated gloves, hats, waterproof boots, wool socks, scarves, coats and overalls, and dressing in layers.
• Job rotation.

The National Oceanic and Atmospheric Administration Wind Chill Chart “is a great resource,” Bennett said. “It outlines the length of time an employee should be in the elements based off the wind speeds and temperature.” If it is 10 degrees Fahrenheit with a wind speed of 60 miles per hour, the wind chill would make it feel like -19 degrees. The chart also provides the length of time before frostbite is a concern. In this example, it would be 30 minutes.

“Administrative cold weather controls include limiting the time outdoors, allowing more frequent breaks indoors to warm up and hydrate, and assigning a buddy system so that no one is working alone and [workers] can keep an eye on one another to watch for signs of cold stress,” he said.

Stay Vigilant

If employees must work in extreme cold, proper cold weather training and clothing can be lifesaving. “Being sedentary can cause cold stress and cold-related conditions to set in quicker, so it’s important for workers to be active and move around when in the cold,” Duhamel said.

Employers should educate employees on how to spot the signs of hypothermia, frostbite and dehydration, as these can set in quickly when working in the cold for extended periods, he said.

The primary cold stress symptoms to look for are fatigue, confusion, disorientation, excessive shivering and loss of coordination, Bennett said.

When frostbite starts, feeling is lost in the affected area and the frozen tissue may take on a pale or gray appearance. If a worker suspects they are experiencing frostbite, they should hold the frostbitten area closely against warm skin to return blood flow and warmth to the affected area.

“The first step is to get the employee out of the cold environment and have a first-aid-trained employee check the employee,” Bennett said. If the employee’s clothes are wet, get them dry and wrapped in a blanket or other warm items. “If the employee is conscious and still responsive, warm liquids should be slowly given to the employee to help with the warming process.” Sometimes, the employer should call 911 and follow the organization’s emergency action program.

Cold stress and mitigation steps should be included in daily pre-task meetings, Bennett said. “Each day employees need to be prepared for the weather environment they will be working in,” he said.

OSHA flags remote workers as a particular concern. Two-way radios, panic buttons, periodic check-in calls, videoconferences, text messages, smartwatches, sirens and a buddy system may help alert employees to hazards, Malveaux said.

“Cold weather is dangerous and can lead to health emergencies,” Bennett noted. He said employers should know the signs of cold stress, monitor employees’ physical condition, use proper engineering controls and safe work practices, and provide employees with warm gear.

See also: SHRM hub page—Weather & Natural Disasters