3.4 The winter jobsite: ice underfoot, snow overhead

1 Snow and ice are a standards issue

There is no OSHA cold standard, but there is a standard about ice. 29 CFR 1910.22(a)(3) requires that walking-working surfaces be maintained free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow, and ice. 1910.22(a)(1) requires places of employment, passageways and walking-working surfaces to be kept in a clean, orderly and sanitary condition, and 1910.22(d) requires regular inspection and maintenance, with hazardous conditions corrected before employee use or properly guarded.

In construction the equivalent duty runs through 1926.25 housekeeping and the General Duty Clause. Either way, an untreated icy walkway is not bad luck; it is a condition somebody is responsible for.

OSHA's winter weather guidance gives the controls: clear walking surfaces of snow and ice quickly after storms, spread deicer as soon as possible, and where walking on snow or ice is unavoidable, wear insulated and water-resistant boots with good rubber treads, keep rubber over-shoes with good treads available during the winter months, and take short steps and walk at a slower pace so you can react quickly to a change in traction.

2 Where the falls actually happen

The fatal and serious cases in OSHA's public accident records have a pattern that should reshape where a site puts its effort. On January 7, 2019, a worker directing traffic slipped on ice, broke her leg, developed a blood clot in the hospital and died two days later (Summary Nr 112637.015). On February 1, 2019, a construction worker filling a water truck slipped on an icy surface and was hospitalized with a fractured arm (Summary Nr 113392.015). And the parking lot case that opens this chapter.

None of those people were doing anything exotic. They were walking, standing and filling a tank. The high-risk winter locations on most sites are the ones nobody assigns to a crew:

Black ice deserves its own line. It forms where water runs off, drips or thaws and refreezes overnight, and it collects in shade and low spots. Those are the same places the crew crosses in the dark at 6:30 a.m., which is why deicer spread at 9 a.m. is deicer spread too late. The five-minute version of all this for a tailgate meeting is the winter slips on ice toolbox talk.

3 Snow on the roof

Snow removal from roofs is the winter task that kills people, and OSHA's winter weather guidance treats it as its own hazard set. The hazards it lists are falls from heights, structural collapse under the weight of the snow, hidden hazards beneath the snow such as skylights, electrical hazards from overhead power lines or equipment, and layers of ice forming on the surfaces being worked on.

The controls it gives, in order:

1. 1
   Evaluate the hazards and plan the work safely before starting.
2. 2
   Have a competent person inspect the surface to confirm it is structurally safe to work on.
3. 3
   Use methods that avoid putting workers on the roof at all wherever possible — snow rakes, drag lines and aerial lifts from below.
4. 4
   Where workers must go up, provide the right equipment: ladders, aerial lifts, fall arrest systems and non-slip safety boots.
5. 5
   Train workers in the proper use of that equipment before the storm, not during it.

Falling ice and snow from structures, cranes and scaffolds is the mirror hazard: everyone below is in a struck-by zone that did not exist in September. Barricading below and knocking accumulations down deliberately, from a safe position, beats waiting for a thaw to do it at random.

4 Wind, dark and the shortened day

Winter changes three site conditions at once, and they compound.

Wind is the biggest driver of the wind chill number from Chapter 3.1 — and it also swings loads, destabilizes lifts and sheeting, and makes any elevated work harder. The wind that puts the crew in a frostbite band is often the same wind that should be stopping the crane work.

Dark arrives in the middle of the shift. Ice that could be seen at noon cannot be seen at 4:45 p.m., and the walk back to the truck happens in the dark on the surface nobody salted since morning. Lighting the paths people actually walk is a cold control as much as a housekeeping one.

Time pressure comes with both: fewer daylight hours to do the same work, which is exactly the pressure that shortens warm-up breaks and skips the second pass with the deicer. A cold weather plan that does not account for schedule pressure is a plan that will be abandoned in February.

5 Equipment and vehicles in winter

Two cold-weather equipment issues are worth naming because they cause injuries that get filed under something else.

Bare skin on cold metal. OSHA's Cold Stress Guide tells workers to avoid touching cold metal or wet surfaces with bare skin. Contact freezing happens during small tasks — a two-second grab of a chain, a hand on a trailer frame — when gloves are off for dexterity.

Cold makes everything take longer and hurt more. Stiff hoses, frozen fittings, hardened rigging, ground too hard to drive stakes into. Crews force things in winter that they would not force in July, and the extra force is where the strains, cuts and struck-by injuries come from. The published control is the same one as for cold stress: reduce physical demands, rotate people, and give the job the extra time it now needs.

The wind chill from a moving vehicle deserves a mention too. A worker riding an open lift or standing on a moving truck bed is generating their own wind, and the frostbite bands respond to that just as they do to weather.

6 The winter walk-around

A five-minute inspection before the crew arrives catches most of this chapter. It is the cold-weather equivalent of the daily inspection any other hazard gets.

• Parking lot, gate walkway, trailer steps: cleared and salted before first arrival?
• Deicer on site, in a known place, with somebody assigned to spread it?
• Any place where water drips, runs off or thaws and will refreeze tonight?
• Ladders, stair treads, scaffold planks and truck beds: ice or packed snow on the walking surface?
• Accumulated snow or ice on structures, scaffolds, crane booms or overhead work — and who is below?
• Lighting on the routes people walk at the end of the shift?
• Boots and treads on the crew, and the spare socks and gloves on the truck?

Write the answers on the pre-task plan with the day's wind chill. That single sheet is the cold-weather record that exists when someone asks what the site knew and did.