Is your business ready for winter?

As winter approaches it is time to revisit the issues which this season may generate for your company and employees and decide if your procedures are robust enough.

Two women walking on a snowcovered sidewalk.



One of the fundamentals during the winter months is protecting your workers from the effects of excessive cold in the premises which form their place of work. Perhaps the most easily controlled environment is an office. Generally, such workplaces have an effective heating system which will deal with this issue. However, has it been serviced and maintained well enough to make the possibility of breakdown remote? If the system is fuelled by gas it should receive an annual service and inspection by a competent agent; a Gas Safe Registered contractor.

A well designed system should have little problem exceeding the basic requirements relating to temperature in workplaces. The minimum temperatures required under the Workplace (Health, Safety & Welfare) Regulations 1992 are 16oC or, where significant manual work is undertaken, 13oC. However, these should be viewed as extreme minimums rather than “targets”. An ideal temperature is very in much open to personal interpretation but a comfortable environment is likely exceed temperatures in the lower 20oC. Sedentary work over a prolonged period at the minimum temperature is likely to generate considerable discomfort and where temperatures are low there will be an increased risk to workers in industrial environments as loss of dexterity and concentration increase. Where necessary, local heating should be provided to counteract temperature drop.

Some environments cannot be practically heated to a comfortable level. Food freezers are an obvious example. However, other areas may offer a comfortable environment for most of the year but become unpleasant as the end of the year approaches. Large storage areas or production areas with high roofs and poor insulation are not uncommon. Local heating can be beneficial but the tendency of warm air to rise can give problems when attempting to resolve this issue.

In older, less well constructed workplaces the problem may be made considerably worse by draughts arising from poorly fitted windows or doors or other ineffective seals within the structure. Where it is possible to rectify this, obvious benefits arise in terms of working conditions and heating costs. However, it is not always possible to make the desirable level of improvement.

If this is the case, other measures should be undertaken. These may include the provision of warmer work-wear for staff in such environments. In cases such as that of stores operatives, they need not be in the main body of the stores all the time. Ensuring they have a well-heated office to operate from can be an effective solution to seasonal low temperatures.

Premises and Services

Other premises considerations include services. Is there a history of water services to buildings freezing up? If so there is the danger of burst pipes and subsequent flooding with possible consequent loss to stock or production. Also, if there is a long term interruption to drinking water and toilet services the premises may become unfit for continued occupancy. Better lagging of pipes or possibly trace heating may be part of a solution.

It should be borne in mind that the Construction (Design & Management) Regulations also carry legal requirements relating to workers both indoors and out of doors on construction sites.

Prevention is always better than cure and can be implemented under controlled conditions. An unexpected failure of part of the structure, particularly roofs in areas where prone to winter gales can generate an “emergency” which could be prevented by a little forethought. If there is a history of roof problems a pre-winter examination may allow timely repairs where problems are detected. The alternative involves urgent repairs to preserve the structure of the premises and stock / equipment within it. This may involve putting workers at risk attempting repair work during adverse conditions. Work carried out in obviously dangerous conditions would be deemed a failure to operate a safe system of work.

Managing Freezing Temperatures, Frost and Snow

Having considered the premises it is reasonable to extend this process to the surrounding area. Winter will bring unpredictable weather and may result in rain followed by freezing temperatures, frost or snow. This creates hazardous conditions in the areas used by those arriving at work. There is a limit to what may practically be done to safeguard all areas against such hazards but there are obvious priorities. While you may not guarantee all arrivals a snow-free parking space there will be areas on which all foot traffic will travel from the car park and around the premises. These are areas which should receive priority for gritting.

Gritting or similar activities will require planning and should be carried out when frost, ice or snow is predicted and when temperatures are at, or below freezing. The responsible person needs to decide to take measures or discount the need for gritting based on weather information. If possible, contingency measures should be considered to cover unexpected change in conditions. Staff, equipment and materials stock must also be decided. Large bags of de-icing salt are readily available from Seton along with a range of Salt Spreaders that are specifically designed for gritting are available. Basic equipment such as robust brushes and shovels will also be needed. Finally, specific staff must be designated to perform the work and adequate instruction given to such persons.

Familiarity with the premises should ensure that hazardous areas such as depressions in surfaces where water will accumulate are well known. Such areas should be repaired to prevent the formation of sheets of ice.

External Lighting

Another matter to examine is external lighting. As the days shorten staff will eventually be entering and leaving in total darkness unless adequate lighting is provided. This should light walkways and also provide a basic level of lighting in parking area. From a welfare point of view it is worth considering that some members of staff may feel very uneasy leaving a well-lit building and walking through very poorly lit areas, particularly if they have been working later than normal.

Road Safety

Another obvious matter of concern in winter arises where travelling is a substantial part of work activity as it is for sales staff, client facing workers and many others. Certainly, PUWER (Provision and Use of Work Equipment Regulations 1998) does not apply to private cars and guidance states that Road Traffic Legislation takes precedence, except where vehicles are used off-road but there are other issues to consider including, in the absence of firm legal requirement, a moral obligation not to endanger workers. Also, Corporate Manslaughter legislation may be applied where a fatality arises when work-related driving activities represent a breach of the requirement to operate a safe system of work.

Winter is a time to look again at the hours and geographic locations within which high mileage drivers operate. At a more basic level, inappropriate pressure must not be applied to staff to complete journeys, including commuting to work in the face of dangerous conditions. It will prove impossible to offer comprehensive guidance on varying circumstances but it must be made clear that employees have discretion to decide whether to go ahead with a journey. On the other hand, their decision must be reasonable and may be subject to managerial scrutiny if it seems questionable.

Such staff may be encouraged to take a flask of soup and blanket on journeys and ensure their mobile phone is charged. Sticking to main roads rather than back roads is also sensible, even if the journey will be longer. For company vehicles employers usually offer a breakdown / recovery service and may also wish to consider what further equipment they provide (e.g. a kit with red triangle, torch, high visibility vest, etc).

Dealing with the consequences of winter weather presents employers with many concerns over risk and forethought is the sensible course of action to ensure the safety of your staff.

Disclaimer: The information provided through Legislation Watch is for general guidance only and is not legal advice. Legislation Watch is not a substitute for Health and Safety consultancy. You should seek independent advice about any legal matter.

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