OSHA vs. Old Man Winter: What You’re Required to Do in Extreme Weather

When winter arrives, it brings more than just snow and ice—it brings a host of workplace hazards that can put employees at risk. Employers have a legal and ethical responsibility to protect workers from the dangers of extreme cold, ice, and winter storms. Understanding what OSHA requires during these conditions is essential for compliance and, more importantly, for keeping your team safe.

Why Winter Safety Matters

According to the U.S. Bureau of Labor Statistics, thousands of workers are injured each year due to ice, sleet, or snow, with slips, trips, and falls being the most common incidents. Cold stress, frostbite, and hypothermia are also real threats for those working outdoors or in unheated environments. OSHA does not have a specific standard for cold weather, but the General Duty Clause requires employers to provide a workplace free from recognized hazards, including those posed by winter weather.

OSHA’s General Duty Clause and Winter Hazards

The General Duty Clause (Section 5(a)(1) of the Occupational Safety and Health Act) states that employers must provide a workplace “free from recognized hazards that are causing or are likely to cause death or serious physical harm.” This includes hazards related to extreme cold, such as:

• Slippery surfaces from ice and snow
• Cold stress (hypothermia, frostbite, trench foot)
• Reduced visibility due to snowstorms
• Falling objects from snow or ice accumulation

Key OSHA Recommendations for Winter Weather

While OSHA does not have a specific “winter weather” standard, it provides clear guidance on how to protect workers:

1. Training and Awareness
   Train employees to recognize the signs of cold stress and how to prevent slips, trips, and falls. Ensure everyone knows how to report hazards and what to do in an emergency.
2. Proper Clothing and PPE
   Require workers to wear insulated, waterproof boots, gloves, and layered clothing. Provide high-visibility outerwear for those working near vehicles or equipment.
3. Safe Work Practices
   • Clear snow and ice from walkways, parking lots, and work areas.
   • Use salt or sand to improve traction.
   • Schedule outdoor work during the warmest part of the day.
   • Implement a buddy system for remote or isolated work.
4. Engineering Controls
   • Provide heated shelters or warming stations.
   • Use anti-slip mats in entryways.
   • Install handrails on stairs and ramps.
5. Administrative Controls
   • Rotate workers to limit exposure to cold.
   • Encourage frequent breaks in warm areas.
   • Monitor weather forecasts and adjust work schedules accordingly.

Cold Stress: What Employers Must Know

Cold stress occurs when the body can no longer maintain its normal temperature. OSHA identifies several types of cold stress:

• Hypothermia: Body temperature drops below 95°F, leading to confusion, loss of coordination, and potentially death.
• Frostbite: Freezing of skin and underlying tissues, often affecting fingers, toes, nose, and ears.
• Trench Foot: Prolonged exposure to wet and cold conditions, even above freezing.

Employers must recognize the symptoms and ensure prompt medical attention if cold stress is suspected.

Slips, Trips, and Falls: The Winter Risk

According to the National Safety Council, slips, trips, and falls account for nearly 20% of all workplace injuries, with winter weather significantly increasing the risk. Employers should:

• Inspect and maintain walking surfaces.
• Post warning signs in hazardous areas.
• Encourage the use of slip-resistant footwear.

Vehicle and Equipment Safety

Winter weather can make driving and operating equipment hazardous. OSHA recommends:

• Inspecting vehicles before use.
• Equipping vehicles with emergency kits.
• Training workers on safe driving in winter conditions.

Legal Consequences of Non-Compliance

Failure to address winter hazards can result in OSHA citations, fines, and increased liability. In 2022, OSHA issued multiple citations for employers who failed to protect workers from cold stress and winter-related hazards.

Best Practices for Winter Safety Compliance

• Develop a written winter safety plan.
• Conduct regular safety meetings and toolbox talks on winter hazards.
• Document all training and hazard mitigation efforts.

Conclusion

Old Man Winter is unpredictable, but your response to extreme weather shouldn’t be. By following OSHA’s guidance and implementing proactive safety measures, you can protect your workforce, maintain compliance, and keep your operations running smoothly throughout the winter months.

Reference Links:

• OSHA: Winter Weather
• U.S. Bureau of Labor Statistics: Injuries, Illnesses, and Fatalities
• National Safety Council: Slips, Trips, and Falls