Stepping outside this week is a biting reminder that winter has arrived. OSHA has updated its website with information about winter hazards and the steps that can be taken to protect employees.  Although there is no specific standard covering winter weather, employees are protected by the Occupational Safety and Health Act (1970) General Duty Clause or Section 5(a)(1), which requires employers to provide employees a workplace free from recognized hazards.  This is a good time for employers to review their cold weather work practices.

In order to plan accordingly, it is essential that employers understand the potential dangers posed by the weather and familiarize themselves with the terminology used by meteorologists and the medical community.  Icy conditions or heavy snow can lead to slick or blocked roads and downed power lines.  Although people may be advised to stay off the roads in these conditions, such advice is impracticable for workers such as EMTs, snow plough operators, and power company employees.   According to OSHA, environmental cold exposes workers to the risk of cold stress. Any worker exposed to cold temperatures is susceptible to cold stress but extra attention should be paid to workers whose work necessitates them being outside, employees with health conditions such as heart disease or high blood pressure, new employees who may not be accustomed to the conditions, and workers who are returning to work after an absence.

In addition to OSHA’s webpage on “Winter Weather” there are other tools available to help an employer assess the situation and take the necessary precautions to protect their workers.  The American Conference of Governmental Industrial Hygienists (ACGIH) has published a chart entitled “Work/Warm-up Schedule for a 4-Hour Shift” which provides a clear model for employers to determine the length of time someone can work under decreasing weather conditions.

According to OSHA, employers can help alleviate the risks of cold stress by adapting work schedules to the weather conditions: implementing safe practices such as limiting the amount of time workers are outside, scheduling frequent breaks, providing hot, sweet drinks (e.g. tea but NOT alcohol); providing engineering controls, including providing radiant heat and protecting workers from drafts.  Additionally, employers should monitor workers for signs of cold stress, especially those employees previously mentioned.

Environmental cold can lead to cold stress which occurs when lower skin temperature gives way to a lower core temperature.  A person’s body temperature will cool down faster when there is a wind chill.  The most common types of cold stress include: frostbite (freezing, usually of the extremities, e.g. fingers and toes, which can lead to amputation of the affected area); hypothermia (characterized by a core body temperature falling below 95° F, can be fatal); chilblains (ulcers caused by repeated exposure of skin to cold temperatures); and trench foot (result of extended periods of cold, wet feet).  See NIOSH’s Fast Facts sheet –

According to OSHA employers should train employees about these hazards. Well-educated employees can contribute to a safer working environment.  Training should at a minimum cover the following areas:

  • What are the dangers?
  • How to recognize the symptoms associated with Cold Stress related conditions
  • Monitoring oneself and co-workers for signs of cold stress
  • How to dress appropriately for the weather (i.e. layers of loose clothing)
  • First Aid in the case of emergency.

OSHA’s Quick Card “Protecting Workers from Cold Stress” is a concise, easy to read reference sheet identifying the most common cold stress health hazards, how to recognize them, and the emergency measures to be taken if you suspect someone is suffering from cold stress.  See

Employers whose employees use company vehicles or who work around vehicles, it is also essential for vehicles to be properly maintained and equipped for severe driving conditions.  Depending on the work environment, additional training of employees may be advisable.  Suggested topics of training might include:

  • Work zone traffic safety
  • What to do if you are stranded in a vehicle
  • How to safely shovel snow
  • The use of equipment such as snow blowers
  • Working at heights
  • Walking safely to prevent slips, trips, and falls
  • Repairing downed or damaged power lines or being in the vicinity of downed or damaged power lines


OSHA has published comprehensive materials about winter weather.  These may be viewed at

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Photo of Tressi L. Cordaro Tressi L. Cordaro

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state…

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state OSHA enforcement agencies.

Ms. Cordaro has advised employers faced with willful and serious citations as the result of catastrophic events and fatalities, including citations involving multi-million dollar penalties. Ms. Cordaro’s approach to representing an employer cited by OSHA is to seek an efficient resolution of contested citations, reserving litigation as the option if the client’s business objectives cannot otherwise be achieved. As a result, she has secured OSHA withdrawals of citations without the need for litigation.

Ms. Cordaro’s unique experience with government agencies involved in OSHA enforcement enables her to provide employers with especially insightful guidance as to how regulators view OSHA compliance obligations, and evaluate contested cases.

Ms. Cordaro served as the Presidentially-appointed Legal Counsel and Special Advisor to the past Chairman and Commissioner Horace A. Thompson, III at the U.S. Occupational Safety & Health Review Commission (OSHRC) in Washington, DC, the agency that adjudicates contested federal OSHA citations. As the Commissioner’s chief counsel, Ms. Cordaro analyzed all cases presented to the OSHRC and advocated the Commissioner’s position during decisional meetings.

In addition, Ms. Cordaro worked at the U.S. Department of Labor’s Occupational Safety & Health Administration developing OSHA standards, regulations and enforcement and compliance policies, with emphasis on the construction industry. She has in-depth experience on technical issues including, in particular, issues related to cranes and derricks in construction.