We have a number of employees who, as part of their duties, need to work outside intermittently. Although we provide the appropriate wet and cold weather PPE, some of them are complaining of the cold, especially during evening and night time work. We believe we have fulfilled our obligations with regard to PPE, but should we provide more clothing?
The obvious answer to this particular problem is to supply more PPE to those who may be exposed to the cold. Indeed, if your work was of such a nature that your employees were constantly exposed to very low temperatures, this is the route that might be appropriate to you.
However, given the transient nature of these cold spells; and the fact that you are already supplying PPE it may be better to use different control measures for the work, especially as there is a limit to the amount of warm clothing an individual can wear!
The best advice regarding cold weather clothing is to wear multi layers as these can be added or removed depending on each individual’s metabolism.
Primarily, you should ensure that the task, environment and personnel involved have been assessed to ascertain if all hazards and risk, together with potential solutions have been investigated, i.e. if the task involves loading or unloading vehicles, could a vehicle port/covered area be constructed to provide protection from the worst of the weather
You could consider limiting the amount of time individuals spend out in the cold. This could be achieved by rotating the work and / or by training more staff. Both of these options could help to reduce the amount of time an individual is exposed to the cold.
Similarly, you could look at limiting the amount of work that is carried out in cold weather – perhaps be rescheduling work to the day time or postponing non-urgent activity until the cold spell has passed.
Employers should consider the avoidance of their employees working in water when it’s cold. As well as making the body colder quicker there is also an increased chance of conditions such as trench foot if there is prolonged contact.
Where work in the cold is still required, you should ensure that those exposed have access to welfare facilities where they can warm up in-between and after work in the cold. You could also consider giving them extra break time or heating so that they can recover faster. In addition access to warm drinks should be provided to ensure better recovery and efficiency.
Where individuals are being exposed to very cold conditions, a certain amount of supervision would be prudent; and training given to managers and supervisors on the signs and symptoms of hypothermia and other conditions associated with the cold. This training need not be formal or paid for, and could be delivered by your qualified first aiders.
Finally, returning to the subject of PPE: you should ensure that any PPE is compatible with other safety wear, that it is being used properly and that it is suitable for the purpose.
So, it would be expected for you to supply a certain amount of PPE in order to protect your employees from temperatures associated from normal and seasonal weather. In cases of extreme or unseasonal weather, you could choose to either supply extra PPE (such as thermal undergarments) or alternatively, change your working practices to reduce exposure to the cold during these periods.