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Working in cold conditions affects many workers, particularly in construction and the food industry. It poses a real danger to health and safety, thus requiring the implementation of preventive actions. Find the essentials of cold work regulations in this article.
Working in Cold Conditions: What Are We Talking About?
Working in cold conditions is characterized by workers' exposure to low, or even very low, temperatures. The Labor Code does not specify a temperature limit to define cold work, but it is generally accepted thatbelow 10°C (Celsius), workers are exposed to a cold environment. Furthermore, below 5°C, workers may accrue points in their professional prevention account.
🔍 Focus : There is a significant difference between recorded temperatures and human perception. Indeed, wind speed can greatly influence how workers perceive the temperature by several degrees. Therefore, when working outdoors, it is important to be attentive to temperature fluctuations. Furthermore, the perception of cold can be particularly significant during static or sedentary work.
Nearly 100,000 workers are exposed to cold environments as part of their work. This exposure can be due to artificial cold or outdoor work.
Indeed, many sectors of activity, particularly in the food industry, use cold or air-conditioned rooms or refrigerated warehouses to preserve food.
Furthermore, the sectors of construction, transport, or agriculture often require outdoor work for workers. The issue of working in cold conditions then arises mainly during the winter period.
🔍 Focus : There are professions at high altitudes, in cold water, or in regions with extreme temperatures that particularly expose workers to cold. Many professions are affected (divers, construction workers in mountainous areas, ski instructors, etc.).
What are the risks of working in cold conditions?
Depending on the temperature, working in cold conditions can have direct consequences on workers' health and safety.
ℹ Please note : When exposed to cold, the body regulates temperature through bodily mechanisms (cutaneous vasoconstriction, shivering, etc.). However, when this situation is prolonged, these mechanisms may no longer be sufficient, leading to a drop in body temperature and creating health hazards.
Exposure to mild cold, between 5°C and 15°C, can cause a real discomfort and significantly degrade working conditions. Below 5°C, cold can also cause pain and vascular acrosyndromes (numb extremities, insensitive fingers and toes, etc.).
Furthermore, below -25°C, there is a significant risk of hypothermia and frostbite for workers. Hypothermia is a serious condition which can lead to workers' death in the worst-case scenario. It is characterized by shivering, lack of energy or fatigue, and can disorient or cause workers to lose consciousness.
Moreover, work exposing individuals to cold increases the risk of developing musculoskeletal disorders (MSDs) and increases the risk of workplace accidents due to fatigue, arduousness, lack of dexterity (caused by cold sensitivity and wearing clothes and gloves), and potentially icy and slippery ground.
⚠️ Warning : For all these reasons, it is prohibited to assign young workers to activities exposing them to extreme temperatures likely to harm their health (Article D4153-36 C.trav.).
Occupational Prevention Account
Exposure to extreme temperatures is considered a hardship factor and grants rights to earn points on the Occupational Prevention Account when certain thresholds are exceeded (Article L4163-1 C.Trav.).
🔍 Focus : Exposure to cold is considered an occupational risk factor due to an aggressive physical environment (Article D4161-1 C.trav.).
Thus, employees who are exposed to temperatures below or equal to 5 degrees Celsius for a duration of 900 hours per year, earn points on their professional prevention account (Article D4163-2 of the Labor Code.).
The instruction of June 20, 2016, specifies that temperatures related to the activity itself are taken into account; external temperatures are not considered.
Employers must digitally declare workers exposed above the thresholds to the retirement and occupational health insurance funds.
What actions should be implemented to prevent risks associated with working in the cold?
To prevent risks associated with working in the cold, employers must adhere to the general principles of risk prevention, including (Article L4121-2 of the Labor Code.):
- avoid exposing workers to cold;
- assess risks due to cold ;
- implement collective protection measures;
- use appropriate work equipment;
- act on work organization.
Furthermore, the employer must take all necessary measures to ensure the protection of workers against cold and inclement weather (Article R4223-15 C.trav.). Prior to this, they must seek the opinion of the occupational physician and the Social and Economic Committee (CSE).
Moreover, for outdoor workstations, the employer must, wherever possible, take measures to protect workers against atmospheric conditions and against the risks of slipping or falling (Article R4225-1 C.trav.).
ℹ Please note : For workers not specifically exposed to cold, the Labor Code specifies that enclosed workplaces must be heated during the cold season to maintain a suitable temperature (Article R4223-13 C.trav.).
Risk Assessment
To assess risks, the employer must first identify situations where workers are exposed to cold as well as the duration and frequency of these exposures.
As discussed, cold can be natural when working outdoors or artificial when working in artificially cooled premises.
Therefore, whenever a worker must perform a task in one of these two work situations, they must be considered exposed to cold-related risks.
Once situations are identified, the employer must analyze the risks to which workers are exposed based on temperatures and exposure duration. Here are some examples of risks caused by exposure to cold temperatures without protection :
- temperatures between 5°C and 15°C cause discomfort and minor strain. They promote workplace accidents, the onset of shivers, numbness, colds, and MSDs;
- temperatures between 5°C and -10°C pose a direct risk to workers' health. Without protection, the risks of hypothermia and frostbite are low for an exposure of less than one hour;
- temperatures between -25 and -40 °C pose a risk of hypothermia and frostbite for an exposure between 10 to 30 minuteswithout protection;
- temperatures between -40 and -55 °Cpose a serious risk of hypothermia and severe frostbite for exposure exceeding 10 minutes without protection;
- below -55°C, conditions are very dangerous for unprotected exposure, even for less than 2 minutes.
Consequently, below 15°C, workers must be equipped with protective clothing appropriate for the temperature and duration of exposure. Nevertheless, this protective equipment does not completely eliminate cold-related risks. Therefore, the risk assessment must consider the protection offered by the protective equipment.
For artificially cooled premises, measuring the indoor temperature helps determine the extent of cold exposure. For outdoor work, the employer must also consider wind speed to determine the actual perceived temperature for workers.
Furthermore, the employer must also assess the potential presence of ice on floors to determine the risk of slips and falls due to cold.
(repetitive movements, strenuous postures, high work rates, wearing bulky gloves or clothing, lack of heated rest rooms, etc.).
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To prevent cold-related risks, the employer must implement preventive actions and address:
the design and layout of premises and workstations
- (heated work and rest areas, non-slip flooring, cold room signage, secure layout of cold rooms with alarm systems and ventilation, etc.); work organization
- (limiting the duration of work in the cold, considering weather conditions, avoiding static work, etc.); the use of appropriate work equipment
- (forklifts, material handling aids, etc.); the use of personal protective equipment
- (clothing appropriate for the temperature, duration of exposure, and task to be performed); worker training
- (informing workers about cold-related risks, training workers on the use of PPE and protective clothing, etc.). The use of cold-weather protective clothing is paramount, and particular attention must be paid to choosing the PPE best suited to the situation.
Therefore, clothing and equipment must
provide protection for all parts of the body throughout the entire period of wear , including fingertips and toes, and workers must under no circumstances experience pain or be exposed to health-hazardous conditions (PPE design and manufacturing rules-Appendix II of Article R4312-6 of the French Labour Code).
Furthermore, all PPE, particularly cold-protective clothing, must bear a CE marking attesting to their conformity (Article R4313-3 of the French Labour Code.).
This conformity notably ensures an incident thermal flux transmission coefficient as low as required by the working conditions and an appropriate degree of flexibility for the movements to be performed and the worker's postures (PPE design and manufacturing rules - Appendix II to Article R4312-6)
🔍 Focus : The instruction manual for personal protective equipment intended for cold environments must include the maximum cold exposure duration.
It should be noted that in the National guide for the prevention and management of health and social impacts related to cold waves 2023-2024, sheet n°9 "Work Environment" reminds employers of the applicable regulations and specifies the actions to be taken. This sheet primarily targets work in open or enclosed premises (e.g., warehouse), outdoor work (construction, transport industry, etc.), and sectors where personnel use vehicles as part of their professional activity in icy or snowy conditions.
Company agreement for the prevention of professional risk factors
Companies with at least 50 employees that expose at least 25% of their workforce to cold work must establish an agreement for the prevention of this risk (Article L4162-1 of the Labor Code). This provision concerns all risk factors defined in Article L. 4161-1 including cold work. Companies with an accident frequency rate greater than 0.25 are also subject to the implementation of this agreement.
This agreement is concluded for a maximum period of three years (Article L4162-3 of the Labor Code) and must specifically address the reduction of exposure and/or multiple exposures and/or the improvement of working conditions (Article D4162-3 of the Labor Code).