Environmental Regulations for Workplaces Section 2 – Thermal Requirements:
Subject to the provisions of sub regulation (2), no employer shall require or
permit an employee to work in an environment in which the time-weighted
average dry-bulb temperature taken over a period of four hours is less than 6°C, unless the employer takes reasonable measures to protect such employee
against the cold and further takes all precautions necessary for the safety of such
employee: Provided that, where outdoor work is performed, the employer shall
take such measures and such precautions in an environment in which the actual
dry-bulb temperature is less than 6°C at any time
What does this mean for my workplace?
The common misconception stands that cold stress as an Occupational Health Risk only exists in industries where refrigeration of food products is required. This is not necessarily true as cold stress can be a risk in buildings not designed for thermal comfort or where outside activities take place. This means loading and offloading of vehicles at warehouses as well as working in the construction and railway industry can result employee exposure to temperatures of 6 degrees and below especially if these employees work night shifts. Talking about night shifts what about security personnel? Security guards monitoring premises where routine walkabouts are required can be at risk as well. Opencast mining activities an also fall into this risk category especially mining operations taking place in the interior of our country?
How do I approach managing this risk?
- The first step will be to study average winter temperatures in your region and decide whether this risk should be part of your risk register.
- Next determine which activities on your site can result in employee exposure to cold temperatures.
- Include cold stress surveys in your Occupational Hygiene monitoring programme.
- These surveys must be conducted during winter months at the coldest time of the shift. Therefore night shift measurements must be taken during the very early hours of the morning and dayshift measurements must be taken during the first part of the shift or late afternoon-early evening period depending on shift times
As always the principle of reasonably practicable should prevail. Think about what you would want to keep you warm on a cold evening.
- Supplying winter jackets and gloves to forklift drivers who would experience more cold due to a wind-chill factor
- Providing facilities to make warm beverages during breaks
- Woollen socks, scarves and balaclavas depending on the activities performed
- Warming indoor workplaces
At the end of the day cold stress from ambient weather conditions is not a hazard that can be eliminated but effective control is not difficult to achieve.