Warming Up to OSHA’s New Cold Stress Guide

by Blank Rome LLP

Unless you spent the last month on a Caribbean island, you know that a majority of the country was in a deep freeze in late December and early January. Numerous record lows were set and some states, such as the Dakotas and Minnesota, experienced wind chills significantly below zero.

Although temperatures have returned to average in most parts of the country, winter will be with us for a few more months; and the recent freeze is likely to be repeated. The extreme temperatures serve as an important reminder that employers need to take appropriate measures to protect workers from cold stress before it causes harm. While the Occupational Safety and Health Administration (“OSHA”) does not have a specific standard that covers working in cold environments, under the Occupational Safety and Health Act of 1970, employers have a duty to protect workers from recognized hazards, including cold stress hazards.

Here are four tips that employers should consider to protect employees:

1. Train workers to recognize cold stress

Employers should train their workers to recognize the most common types of cold stress and how to apply first aid if a fellow worker is showing symptoms of cold stress. OSHA’s website lists three types of cold stress: immersion/trench foot, frostbite, and hypothermia.

  • Immersion/trench foot:
    • A non-freezing injury of the feet caused by prolonged exposure to wet and cold conditions, which can occur in temperatures as high as 60°F. Symptoms include reddening skin, pain, swelling, leg cramps, numbness, and blisters.
    • First Aid Tips: Remove wet shoes/boots and wet socks, dry feet, elevate, and avoid working on them. Seek medical assistance as soon as possible.
  • Frostbite:
    • Caused by the freezing of the skin and tissues, which can cause permanent damage to the body and, in severe cases, lead to amputation. Symptoms include reddening skin with grey and white patches on the fingers, toes, nose, or ear lobes; tingling, aching, and blisters.
    • First Aid Tips: protect the frostbitten area by wrapping loosely in a dry cloth until medical help arrives. Do not rub the affected area, apply snow or water, or break blisters. Also, do not re-warm the frostbitten area by using heating pads or warm water.
  • Hypothermia:
    • Occurs when the body’s normal temperature drops to less than 95 degrees. Symptoms include uncontrollable shivering, loss of coordination, confusion, and slurred speech.
    • First Aid Tips: Remove all wet clothing and replace with dry clothing. Wrap the entire body in layers of blankets and add a barrier, such as a tarp or a garbage bag. Do not cover the face. Seek medical help immediately. If medical help is more than 30 minutes away, give the individual warm, sweetened non-alcoholic drinks (only if he or she is alert) to help increase the body temperature.

2. Provide engineering controls

Employers should provide engineering controls, such as radiant heaters to warm workers in outdoor security stations. If possible, employers should also shield work areas from drafts or wind to reduce wind chill.

3. Use safe work practices

Workers easily become dehydrated in cold weather, so employers should provide plenty of warm sweetened liquids. Employers should also schedule heavy work during the warmer part of the day and should create a buddy system for workers to monitor each other for signs of cold stress. OSHA recommends frequent breaks for workers, which should take place in a warm location.

4. Dress properly

Workers should be encouraged to wear warm fabrics such as wool, silk, or synthetics. Workers should wear at least three layers of loose fitting clothing to provide better insulation.

A full description of OSHA’s Cold Stress Guide can be found here: https://www.osha.gov/SLTC/emergencypreparedness/guides/cold.html.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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