Keeping Your Staff Warm During Outside Winter Working

person wearing warm clothing outside and blowing into hands due to cold

If your outside workers are complaining that more should be done to keep them warm and dry in the winter months. What are your legal obligations and what’s the best way to fulfil them?

The law

Employers have a wide-ranging duty of care towards workers under s.2 of the Health and Safety at Work etc. Act 1974. For example, it includes the provision of a healthy work environment, equipment as needed and safe systems of work. All of these factors are relevant when considering winter working conditions and the control measures to put in place.


More specifically, the Personal Protective Equipment (PPE) at Work Regulations 1992 describe your duty to provide PPE to protect employees from risks to their health or safety. The definition of PPE in these regulations makes it clear that this includes “clothing affording protection against the weather”.

What you must do

The priority is to do what you can to make the work comfortable, by means other than protective clothing. This is because PPE should be considered a last resort.

  1. These measures should include providing:
  • shelter (if it’s reasonably practicable)
  • provision to have hot drinks
  • first-aid facilities
  • a warm and dry place to rest and change out of wet clothes; and
  • somewhere to dry the outdoor clothing.

Note. A temperature of 20°C is sufficient for most items to dry within ten hours.

  1. In bad weather there will be times that you’ll need to stop work completely due to the risks. Decide the criteria in advance so that supervisors and staff know what’s expected. (See risk assessment and training below)

Warm clothes

If working in winter weather creates risks which are not controlled by the employee wearing normal winter clothing, you’ll need to top it up with specific items as necessary.

  • Encourage outdoor workers to wear layers of their everyday clothing and take spares to change in to if they get wet.
  • If you require staff to wear hard hats, purchase thermal liners. Check that they are compatible and give the level of insulation you need. Don’t allow staff to wear hoodies instead as there are safety concerns surrounding the field of vision.  This may require a specific dress code depending on the job.
  • If normal clothing is not sufficient, provide body warmers, woolly hats, warm/water resistant gloves and rain wear.

Wet and dark conditions

In winter employees may begin and end their working day in the dark. Therefore high-visibility clothing is an absolute must for outside workers.

  • When purchasing high-visibility waistcoats and jackets for the winter season, order larger sizes to fit over layers of winter clothing.
  • When issuing this PPE, remind staff in what circumstances it must be worn. For example, they are required to wear high-visibility clothing when working around vehicles

Risk Assessment & Appropriate Training

Ensuring that a suitable and sufficient risk assessment is undertaken for all activities where working outdoor in winter weather is essential prior to undertaking the work.  The provision of appropriate clothing (where appropriate) would be part of a measure of controls put in place to reduce risks.

Appropriate training must also be provided to all employees who need to work with equipment and provided with information on the risks of working in extreme and cold weather conditions.  They need to understand the importance of using all control measure provided and what to do if they start to develop symptoms of cold stress.

Risks of Working Outside

The main risks from the cold are the affects that it can have on the human body. Regardless of the surrounding air temperature, the body needs to maintain a constant core temperature of about 37oC. If it’s too cold it can result in reduced productivity and an increase in accident rates. At temperatures below 35oC, hypothermia occurs and this can lead to a variety of problems including loss of muscle function, frostbite and even death. This means that special care needs to be taken for those that have to work in cold temperatures.

How Can We Help?

To assist with your arrangements related to providing staff with information on winter working download a copy of our working in winter conditions staff briefing.  This document can be amended as required to meet your specific needs.  If you require any help or assistance with any aspect of health and safety do get in touch.  We provide a free no obligation 15 minutes consultation, so give us a call on 07875 535558.

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