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Working in the cold affects many workers, particularly in the construction and public works sector and the food industry. It represents a real danger to health and safety, and requires the implementation of preventive measures. In this article, you'll find a summary of the regulations governing cold work.
Working in the cold: what are we talking about?
Cold work involves exposing workers to low or very low temperatures. The French Labor Code does not specify a temperature limit to define cold work, but it is accepted thatbelow 10°C (Celsius), workers are exposed to a cold environment. In addition, below 5°C, workers can benefit from points on their professional prevention account.
🔍 Focus: There's a big difference between recorded temperatures and how people feel. Indeed, wind speed can greatly influence workers' feelings by several degrees. So, when working outdoors, you need to pay close attention to temperature fluctuations. In addition, the feeling of cold can be particularly important in static or sedentary work.
Nearly 100,000 workers are exposed to cold environments in the course of their work. This exposure may be due to artificial cold or to working outdoors.
Indeed, many sectors of activity, particularly in the food industry, use cold or air-conditioned rooms or refrigerated warehouses to preserve foodstuffs.
The construction, transport and agricultural sectors often require workers to work outdoors. The problem of working in the cold therefore arises mainly during the winter period.
🔍 Focus: There are occupations at altitude, in cold water or in regions with extreme temperatures that particularly expose workers to the cold. There are many such occupations (divers, mountain construction workers, ski instructors, etc.).
What are the risks of working in the cold?
Depending on the temperature, working in the cold can have a direct impact on workers' health and safety.
ℹ Note: When exposed to cold , the body regulates its temperature through bodily mechanisms (skin vasoconstriction, shivering, etc.). However, when this situation is prolonged, these mechanisms may no longer be sufficient, causing a drop in body temperature and creating health hazards.
Exposure to mild cold, between 5°C and 15°C, can cause real discomfort and considerably worsen working conditions. Below 5°C, cold can also cause pain and vascular acrosyndromes (numb extremities, numb fingers and feet, etc.).
In addition, below -25°C, there is a significant risk of hypothermia and frostbite for workers. Hypothermia is a serious condition that, in the worst case scenario, can lead to worker death. It is characterized by shivering, lack of energy or fatigue, and can disorientate or render workers unconscious.
In addition, work involving exposure to the cold increases the risk of developing musculoskeletal disorders (MSDs), and increases the risk of work-related accidents due to fatigue, arduousness, lack of dexterity (caused by sensitivity to the cold and the need to wear clothing and gloves) and possibly icy, slippery floors.
⚠️ Warning: For all these reasons, it is forbidden to assign young workers to activities exposing them to extreme temperatures likely to damage their health (Article D4153-36 C.trav.).
Compte professionnel de prévention
Exposure to extreme temperatures is considered to be a hardship factor, and entitles workers to points on the professional prevention account when certain thresholds are exceeded(Article L4163-1 C.Trav.).
🔍 Focus: Exposure to the cold is considered an occupational risk factor under the heading of an aggressive physical environment (Article D4161-1 C.trav.).
Employees exposed to temperatures of 5 degrees Celsius or less for 900 hours a year earn points on their professional prevention account(Article D4163-2 C.trav.).
The instruction of June 20, 2016 specifies that temperatures linked to the exercise of the activity itself are taken into account; outside temperatures are not taken into consideration.
Employers must make electronic declarations to their occupational health and pension insurance funds of workers exposed above the thresholds.
What can be done to prevent the risks of working in the cold?
To prevent the risks of working in the cold, employers must comply with the general principles of risk prevention, and in particular(Article L4121-2 C.trav.) :
- avoid exposing workers to the cold;
- assess cold-related risks;
- take collective protection measures ;
- use appropriate work equipment;
- act on work organization.
In addition, the employer must take all necessary steps to protect workers from the cold and bad weather (Article R4223-15 C.trav.). He must seek the opinion of the occupational physician and the social and economic committee (CSE) beforehand.
In addition, for outdoor workstations, the employer must, as far as possible, take measures to protect workers against atmospheric conditions and the risks of slipping or falling(Article R4225-1 C.trav.).
ℹ Please note: For workers who are not specially exposed to the cold, the French Labor Code specifies that enclosed premises used for work must be heated during the cold season and in such a way as to maintain a suitable temperature (Article R4223-13 C.trav.).
Risk assessment
To assess risks, the employer must first identify the situations in which workers are exposed to cold, and the duration and frequency of such exposure.
As mentioned above, cold can be natural when working outdoors, or artificial when working in artificially cooled premises.
So, as soon as a worker has to carry out a task in one of these two work situations, he or she must be considered to be exposed to cold-related risks.
Once the situations have been identified, the employer must analyze the risks to which workers are exposed , depending on the temperature and duration of exposure. Here are just a few examples of the risks involved in unprotected exposure to cold temperatures:
- temperatures between 5°C and 15°C are a source of discomfort and mild discomfort. They are also conducive to work-related accidents, chills, numbness, colds and RSI;
- temperatures between 5°C and -10°C represent a direct health risk for workers. Without protection, the risk of hypothermia and frostbite is low for exposure lasting less than an hour;
- temperatures between -25 and -40°C represent a risk of hypothermia and frostbite for unprotectedexposure of 10 to 30 minutes;
- temperatures between -40 and -55°C representa serious risk of hypothermia and severe frostbite for exposure of more than 10 minutes without protection;
- below -55°C, conditions are very dangerous for unprotected exposure of even less than 2 minutes.
Consequently, below 15°C, workers must be equipped with protective clothing suited to the temperature and duration of exposure. However, this protective equipment does not completely eliminate the risks associated with cold. Therefore, risk analysis must take account of the protection afforded by protective equipment.
In the case of artificially cooled premises, measuring the inside temperature can be used to determine the extent of exposure to cold. In the case of outdoor work, the employer must also take wind speed into account to determine how workers really feel.
Employers must also assess the presence of frost on floors to determine the risk of slips and falls on the same level due to the cold.
Finally, to complete the assessment of cold-related risks, the employer must also take into account individual risk factors (age, gender, experience, physical condition, state of health, pregnancy, chronic illness, etc.) as well as other risks inherent to the work performed (repetitive movements, awkward postures, high work rates, wearing of gloves or bulky clothing, lack of heated rest rooms, etc.).
Preventive measures
To prevent cold-related risks, employers must implement preventive measures and take action on :
- the design and layout of premises and workstations (heated work and break rooms, non-slip floors, cold room signage, safe layout of cold rooms with alarm systems and ventilation, etc.);
- work organization (limiting the duration of cold work, taking weather conditions into account, avoiding static work, etc.);
- the use of adapted work equipment (forklift trucks, handling aids, etc.);
- use of personal protective equipment (clothing suited to the temperature, duration of exposure and task to be performed);
- worker training (informing workers of the risks associated with cold, training workers in the use of PPE and protective clothing, etc.).
The use of protective clothing against the cold is essential, and particular attention must be paid to choosing the PPE best suited to the situation.
Clothing and equipment must guarantee protection for all parts of the body, including the extremities of the fingers and toes, for the entire duration of wear, and workers must never feel pain or be exposed to conditions hazardous to their health (PPE design and manufacturing rules - Appendix II of article R4312-6 C. trav.).
In addition, all PPE, particularly cold protection clothing, must bear a CE mark attesting to their conformity(Article R4313-3 C.trav.).
In particular, this compliance ensures that the incident heat flux transmission coefficient is as low as required by working conditions and that the degree of flexibility is appropriate to the movements and postures of the worker (PPE design and manufacturing rules - Annex II to article R4312-6).
🔍 Focus: The instructions for personal protective equipment intended for use in cold environments must include the maximum duration of exposure to cold.
Note that in the national guide to preventing and managing the health and social impacts of cold snaps 2023-2024, sheet no. 9 "Workplace" reminds employers of the applicable regulations and specifies the actions to be taken. This sheet mainly concerns work in open or closed premises (e.g. warehouses), outdoor work (construction, transport industry, etc.) and sectors in which employees use vehicles as part of their professional activity in icy or snowy conditions.
Company agreement on the prevention of occupational risk factors
Companies with at least 50 employees who expose at least 25% of their workforce to cold work must draw up an agreement to prevent this risk(Article L4162-1 C.Trav.). This provision concerns all the risk factors defined in Article L. 4161-1 , including cold work. Companies with an accident rate in excess of 0.25 are also required to set up such an agreement.
This agreement is concluded for a maximum period of three years(Article L4162-3 C.Trav.) and must deal in particular with the reduction of exposure and/or poly-exposure and/or the improvement of working conditions(Article D4162-3 C.Trav.).