The winter season presents unique challenges to managing workforce safety, especially where they are expected to work outside or in unheated environments.
Attorneys for the law firm of Fisher Phillips point out that even in situations where no specific regulations apply, OSHA’s “general duty clause” requires employers to provide a safe and healthy workplace for employees.
Besides protecting your workers from expected threats like winter-weather exposure, you also have an obligation to rid your workplace of winter-related hazards like icy walkways and parking lots to avoid a citation under the general duty clause.
Cold weather offers its own challenges when it comes to worker safety, especially for employees who work outside. Prolonged exposure to freezing or cold temperatures can create serious health problems like trench foot, frostbite, hypothermia and, in extreme cases, death.
Trench foot is caused by long, continuous exposure to a wet, cold environment, including actual immersion in water. Work involving small bodies of water pose particular threats. Symptoms include a tingling or itching sensation, burning, pain and swelling, and even blisters in more extreme cases.
Frostbite occurs when the skin tissue actually freezes, causing ice crystals to form between cells
and draw water from them. This typically occurs at temperatures below 30 degrees F, but wind chill can cause frostbite at above-freezing temperatures. Initially, frostbite symptoms include uncomfortable sensations of coldness, and a tingling, stinging or aching feeling of the exposed area which is then followed by numbness.
Hypothermia occurs when the body’s temperature falls to a level where normal muscular and cerebral functions are impaired. While hypothermia is generally associated with freezing temperatures, it can occur in any climate where a person's body temperature falls below a normal level.
The first hypothermia symptoms begin when body temperature drops more than one degree and include shivering, an inability to perform complex motor functions, lethargy and mild confusion.
Employees should watch for these symptoms, including uncontrolled shivering, slurred speech, clumsy movements, fatigue and confused behavior. “If the employee exhibits these danger signs emergency help should be called,” the lawyers say.
Among the methods for protecting employees from the cold are wearing protective clothing (such as gloves and hats), engineering controls and common safe work practices.
OSHA has issued a Cold Stress Card including tips on handling cold weather. Free copies of it are available in both English and Spanish from the agency’s website or by calling 800-321-0SHA.
OSHA’s tips include:
- Recognize the environmental and workplace conditions that may be dangerous.
- Learn the signs and symptoms of cold-induced illnesses and injuries and how to help employees.
- Train employees about cold-induced illnesses and injuries.
- Encourage employees to wear proper clothing for cold, wet and windy conditions, including layers that can be adjusted to changing conditions.
- Be sure that employees in extremely cold conditions take frequent, short breaks in warm dry shelters to allow their bodies to warm up.
- Try to schedule work for the warmest part of the day.
- Avoid exhaustion or fatigue because energy is needed to keep muscles warm.
- Use the buddy system: Work in pairs so that one employee can recognize danger signs.
- Drink warm, sweet beverages (sugar water, sports-type drinks) and avoid drinks with caffeine (coffee, tea, sodas or hot chocolate) or alcohol.
- Eat warm, high-calorie foods like hot pasta.
- Remember: Employee risks increase when they take certain medications, are in poor physical condition, suffer from flu or chronic illnesses like diabetes, hypertension or cardiovascular disease.
Battling the Flu
Flu activity generally peaks in January, but people often contact it well before then. “The time to prepare for an outbreak is now,” the Fisher Phillips attorneys observe. Educate yourself about preventive steps you can take and plan for what to do if an outbreak hits your workplace this winter.
Some common sense measures are very easily implemented and cost-effective, such as urging workers to thoroughly wash their hands and to use proper cough and sneeze etiquette.
Employers also can supply of antibacterial or waterless soap and make sure to keep on hand cleaning supplies for telephones, keyboards and desks to limit the spread of germs.
“In the coming weeks, you should introduce these measures and train your workforce to take
advantage of them,” the attorneys say. “And of course, when the flu strikes, encourage those workers under the weather to stay at home in order to reduce the contagion.”
A more aggressive approach could involve changing some workplace policies to encourage workers to avoid spreading the flu. This includes temporarily altering paid-time-off or attendance policies to prevent sick employees from rushing back to work while they can still spread the disease.
If possible, you also could permit workers to telecommute or otherwise work from home during an outbreak so that their entire department doesn’t get wiped out for days or even weeks.
At the first sign of symptoms, the lawyers suggest employers consider sending sick workers home or providing them with protective gear, such as face masks, to help prevent the spread of germs.
The Fisher Phillips attorneys also believe it is a good idea to consider suggesting and even encouraging employees to get flu shots as soon as possible. You can even provide a qualified medical professional to administer shots at your workplace.
Requiring employees to get mandatory flu vaccinations is a controversial action. Many workers will refuse to comply. You must be prepared for objections to vaccination.
Is the worker objecting on religious grounds? Can the vaccine aggravate another health condition or set off an allergic reaction? Does the employee simply fear needles?
“You should consider creating forms for employees to fill out if they want to request exemptions from any required inoculations based on religious, disability or medically-related reasons,” they add. “Make sure you have a team available to review and resolve any such requests in a professional and expeditious manner.”