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Friday, May 15, 2026

Protections from the Cold if 'Proactive Scheduling' Isn't Feasible - SHRM

The Occupational Safety and Health Administration (OSHA) recommends protecting employees from the cold by scheduling work during the warmest part of the day. But such proactive scheduling isn’t always feasible. Here’s why employers might need to consider other options and some examples of those alternatives.

When Proactive Scheduling May Not Work

Sometimes changing scheduled maintenance or repair jobs will be reasonably possible and other times it will not, said John Ho, an attorney with Cozen O’Connor in New York City.

For example, a building maintenance team may decide it can push off a new paint job for a building until the spring. In other situations, certain maintenance jobs can’t be delayed, so the employer will need to take protective measures against cold stress, he said.

Cold exposure may be unavoidable in energy work, outdoor construction and even manufacturing, said Courtney Malveaux, an attorney with Jackson Lewis in Richmond, Va. “In addition, some indoor employers require cold indoor environments for perishable food product storage and other cold processes year-round, and having at least limited employee exposure to cold may be necessary to maintain product,” he said.

Emergency response, overnight security, power line repair and road construction frequently must be performed at night when weather often is colder, Malveaux added.

Utility workers barely scratch the surface for employees who work in cold environments, said Travis Bennett, associate director,...



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