Employer responsibilities and worker exposure

OSHA emphasizes that, even without a specific “cold stress” standard, employers are obligated under the General Duty Clause (Section 5(a)(1)) to provide a workplace free from recognized hazards and must comply with PPE requirements in 29 CFR 1910.132. Workers commonly exposed to cold stress include:

Applying the hierarchy of controls to prevent cold stress

When the temperature drops, quick action matters. The hierarchy of controls gives employers a step-by-step plan to reduce cold stress risks before they turn into emergencies. Below are practical steps and examples for each level of the hierarchy from most protective to least:

Elimination/substitution - Remove or replace the hazard entirely.

• Reschedule non-essential outdoor work for milder days.
• Move tasks indoors when feasible (e.g., plan maintenance for warmer seasons).

Engineering controls - Modify the work environment to reduce exposure.

• Provide heated shelters or warming stations near work areas.
• Install windbreaks or temporary enclosures to reduce wind chill.
• Use enclosed or semi-enclosed equipment to minimize manual exposure during tasks like de-icing.

Administrative controls - Change how work is performed to limit risk.

• Implement work/rest cycles and enforce warming breaks.
• Train workers to recognize symptoms (shivering, confusion, numbness) and monitor each other.
• Rotate staff, limit time outdoors on extreme days, schedule fine motor tasks for the warmest part of the day, and
• Monitor forecasts/NOAA alerts for wind chill thresholds.

PPE - Provide gear when other controls can’t fully eliminate risk.

• Supply PPE at no cost per 29 CFR 1910.132;
• Layer clothing: moisture-wicking base, insulating mid-layer, windproof/waterproof outer shell;
• Choose insulated, dexterous gloves that preserve grip and function;
• Protect the head, face, and neck with balaclavas or thermal liners;
• Equip workers with waterproof, insulated boots and moisture-wicking socks;
• Use high-visibility outerwear per ANSI/ISEA 107 for low-light winter conditions; and
• Ensure PPE fits, stays dry, and is replaced when wet or worn; damp gear accelerates heat loss and increases cold stress risk.

Wind chill and why it matters

Wind chill is the temperature your body “feels” when wind speed and air temperature are combined. Wind strips away the thin layer of warm air next to the skin, accelerating convective heat loss. As wind speed rises, exposed skin cools faster, dramatically increasing frostbite and hypothermia risk.

OSHA and the National Oceanic and Atmospheric Organization (NOAA) use Wind Chill Advisories and Warnings to signal when conditions are hazardous or life-threatening. As an example, at 20 °F with a 20-mph wind, the wind chill is ~4 °F, meaning cold stress sets in much faster than the air temperature alone would suggest.

Key to remember: By integrating wind chill awareness with the hierarchy of controls, supervisors can drastically reduce cold-related injuries by keeping crews safe and productive throughout the winter season.