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Cold weather doesn’t mean you’re not losing water

It’s easy to associate dehydration with hot, sweaty summer days, but cold weather can be just as dehydrating. In low temperatures, the body’s thirst response is lowered, meaning you may not feel thirsty even when you're losing fluids. By the time you feel thirsty, you may already be mildly dehydrated.

Your body still loses fluids through perspiration—especially when wearing heavy gear or performing strenuous work. Combined with moisture that may be lost through respiration (like when you see your breath in the cold air), and you’ve got a recipe for dehydration.

Hydration matters in cold conditions

Hydration matters in the comfort, safety, and performance of workers. Dehydration can increase fatigue and reduce mental clarity leading to slips, falls, or incidents behind the wheel.. Here’s why hydration matters, even in the cold:

• Maintains core temperature: Water helps regulate body temperature. Dehydration can impair your ability to stay warm, increasing the risk of hypothermia.
• Supports circulation: Proper hydration keeps blood flowing efficiently, which is crucial for keeping extremities warm and preventing frostbite.
• Boosts energy and focus: Dehydrated workers may experience fatigue, dizziness, and reduced concentration—hazardous conditions in any work environment.
• Improves physical performance: Cold weather already stiffens muscles and joints. Dehydration compounds this, making movement more difficult and increasing injury risk.

Integrating hydration into your cold weather safety plan

OSHA may not have a regulation specific to cold weather safety; however, employers still must provide a workplace free of recognized hazards, including cold stress. Besides, it’s the right thing to do!

Hydration strategies to include in your winter preparedness initiatives should be:

• Providing warm, hydrating beverages (hot water, tea, broth) on-site;
• Educating workers on cold-weather dehydration risks, such as not drinking enough fluids or drinking caffeinated beverages;
• Ensuring access to clean, unfrozen water sources;
• Adjust work schedules to warmer parts of the day;
• Encouraging regular hydration breaks, especially during physically demanding tasks.

Key to remember: While thermal gear and wind protection are essential, don’t underestimate the power of hydration as part of your cold weather work preparation.

OSHA HazCom

HazCom applies to “any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.” The OSHA regulation has requirements for hazardous chemical manufacturers, importers, distributors, and employers.

HazCom-covered employers must ensure containers of non-exempt hazardous chemicals are labeled, SDSs are readily accessible to employees in their work areas, and effective information/training is provided for exposed employees. They must also prepare and implement a written HazCom program (which includes a chemical inventory), unless they only have exempted operations under 1910.1200(b)(3) and/or (b)(4).

Covered employees have a right to understand the chemical hazards in their workplace. Training is key to ensuring employees have that understanding. Employees must be trained prior to initial assignment with hazardous chemicals and whenever a new chemical hazard is introduced. Employers must cover the elements in 1910.1200(h).

DOT Hazmat

The hazmat regulations apply to those involved in three primary types of activities: pre-transportation functions, transportation functions, and hazmat packaging. Pre-transportation functions include activities performed by the hazmat shipper and deal largely with paperwork. Transportation functions, on the other hand, include activities performed by those directly involved in transporting hazmat, including drivers.

“Hazmat employees” must be trained per 49 CFR 172.704 within 90 days of employment or job function assignment, and refresher training is mandated at least once every three years. Employees are considered hazmat employees if they directly affect hazmat transportation safety. See 49 CFR 171.8 for a detailed definition of hazmat employee.

The DOT says, “Training conducted by OSHA, EPA, and other Federal or international agencies may be used to satisfy the training requirements in 172.704(a) to the extent that such training addresses the components specified in paragraph (a) of this section (general awareness/familiarization; function-specific; safety; security awareness; in-depth security training, if a security plan is required; and driver training for each hazmat employee who will operate a motor vehicle).”

EPA HazWaste

Every business deals with waste and must know how to properly dispose of it. Most states are authorized to run their own HazWaste programs, so a facility needs to be aware of state (and often local) HazWaste regulations. When waste is generated, the facility must identify the waste and determine if it is HazWaste by definition.

EPA’s HazWaste generator regulations at 40 CFR 262 apply differently depending upon the “generator category” (large quantity (LQG), small quantity (SQG), and very small quantity (VSQG)), which is determined by how much HazWaste a facility generates each month. Therefore, under Part 262, employee training requirements too are based on the generator category.

SQGs must train employees according to 40 CFR 262.16. SQGs have basic training requirements. They must ensure employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and emergencies. LQG personnel training requirements are found at 40 CFR 262.17. Being large, these generators are required to meet much more extensive training requirements. It’s a best practice for VSQGs to train employees to safely handle HazWaste, but it’s not specifically called out in EPA’s HazWaste generator regulations. However, other training regulations, such as those for OSHA and DOT may come into play.

Key to remember: No matter what you call them, hazardous chemicals are regulated by OSHA, DOT, and EPA depending what you’re doing with those chemicals. Employers must understand what regulations apply to their situation and train employees accordingly.

Stools are working surfaces

The regulation at 1910.21 defines a walking-working surface as “any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.” This broad definition likely covers all plastic or aluminum stools that employees climb on and work from.

Having employees conduct pre-use inspections would fulfill the regular inspection obligation. Employees would need training on what defects require removing the stool from service. Defects might include damaged or missing non-slip feet, loose or missing treads, cracks in a plastic stool, loose bolts or damaged rivets on metal stools, or bent legs on metal stools.

Employees don’t need to document these inspections, but if OSHA asks them to demonstrate the process, employees should be able to describe what defects they look for and how they deal with a problem, such as tagging and removing the stool from service. Employers might want inspection documentation for various reasons, but employees who can demonstrate how they perform inspections should be able to convince an OSHA inspector that they do so regularly.

Training should also cover when to perform an “as necessary” inspection. After all, damage to a stool typically occurs during use, not while the stool is sitting unused overnight. Employees should perform another inspection if they hear a crack when stepping up, see a rubber foot come off, or notice something else that doesn’t look or sound right.

For more information on ladder safety, see our article, Portable ladder users must comply with OSHA and the law of gravity.

Attention to safety

Make sure employees know how to remove a damaged stool from service and how to get a replacement quickly. Employees should not use a damaged or unsafe stool because they “just needed one quick thing” and couldn’t find another stool.

If an OSHA inspector sees a damaged stool in use, the inspector could potentially cite 1910.22(d)(1) for a working surface that was not “maintained in a safe condition.” Moreover, if the inspector asks whether someone regularly inspects all walking-working surfaces, including stepstools, the employer should be able to answer affirmatively. In addition to avoiding a possible OSHA citation, these procedures help improve worker safety by ensuring that employees do not attempt to climb on damaged stools.

Key to remember: Train employees to regularly inspect stepstools, including stools that do not meet OSHA’s definition for portable ladders, since those devices are still walking-working surfaces.