Safety Sense January 2026
Preparing for Winter Weather Hazards
Winter weather presents significant safety challenges for employers, particularly those with outdoor operations, driving responsibilities, or facilities exposed to cold conditions. Snow, ice, freezing temperatures, and reduced visibility increase the risk of injuries, illnesses, and operational disruptions.
Employer Responsibilities Under OSHA
While OSHA does not have a specific winter weather standard, employers remain responsible under the General Duty Clause to protect employees from recognized hazards associated with cold weather. Employers must take reasonable steps to reduce known hazards including cold stress conditions (hypothermia, frostbite, and frostnip), slips, trips, and falls due to snow and ice, motor vehicle accidents caused by icy roads and poor visibility, carbon monoxide exposure from improperly vented heaters or equipment, and strains and overexertion from snow removal activities.
We recommend employers develop a winter weather plan including procedures for severe weather which may include delayed openings and/or remote work options. Employers should conduct a hazard assessment, train employees on winter driving, implement controls to minimize exposure, and provide appropriate personal protective equipment (PPE) for employees working in cold conditions.
Employers in every workplace should promptly remove snow and ice, apply salt or ice melt and maintain adequate lighting at entrances and exits where winter weather might create a hazard.
Additional considerations:
Ensure Vehicle and Equipment Safety – Inspect vehicles and equipment. Train employees on winter driving safety. Allow additional travel time.
Winter weather hazards are predictable and preventable. Employers who plan ahead and implement appropriate controls can reduce injuries, OSHA citations, and operational downtime.
DOL Letters Of Interpretation
The Department of Labor (“DOL”) issued seven letters of interpretation in 2025 providing explanations of agency requirements and their application.
On January 3, 2025, the DOL clarified that 29 CFR 1910.146(d)(3)(iii) requires all “confined spaces” or “permit-required confined spaces” be isolated prior to entry, except when the piping does not terminate in the space. This requires that water be drained from pipes prior to entry for repair, regardless of whether a hazard assessment shows no risk of rupture.
The second letter of interpretation, issued February 5, 2025, states that OSHA will no longer enforce COVID-19 recordkeeping and reporting requirements under 29 CFR § 1910.502(q)(2)(ii) and (q)(3)(ii)-(iv), or 29 CFR 1910.502(r). Employers will not be cited for any violations of these code sections. However, the requirements for recordkeeping and reporting under 29 CFR § 1904 will remain enforced by OSHA.
On April 1, 2025, the DOL issued another letter clarifying that the language of 29 CFR 1910.178(l)(2) requires a trainee may only operate a powered industrial truck under the direct supervision of a person with the knowledge, training, and experience to train operators and evaluate their competence. To properly evaluate competence, the evaluation by such qualified person must be performed physically at the location where the training takes place and may not occur virtually.
On April 29, 2025, the DOL issued a letter of interpretation stating an alternative form generated by company software can be used as a substitute for OSHA Forms 300, 300A, and 301, which are used to record all recordable occupational injuries and illnesses as required by 29 CFR 1904.29(a). The alternative form must meet the requirements of an equivalent form as specified by 29 CFR 1904.29 and 29 CFR 1904.32.
On May 8, 2025, the DOL defined “engineering controls” as used in Benzene and Butadiene standards, which require employers to institute engineering controls and practices to reduce or maintain employee exposure. Pursuant to these standards, bellow valves, leak-proof, double-seal valves, and conventional non-bellow, non-leak proof, non-double seal valves, are considered engineering controls. According to the DOL, OSHA expects employers to follow manufacturer instructions for equipment, environmental regulations for fugitive emissions, and industry standards in determining when to replace such valves.
On June 11, 2025, the DOL clarified that 29 CFR §1910.95(g)(1) requires employers to offer audiometric testing to all employees exposed to noise greater than 85 decibels for 8-hours on average, regardless of an employee’s natural hearing thresholds. Therefore, an employee is not exempt from audiometric testing because of a cochlear implant and may not conduct said testing with the implant turned on.
On June 17, 2025, the DOL issued a letter of interpretation specifying that 1910.25(c)(1)-(c)(3) requires tread depth of stairs built after 2017 be 9.5 inches, measured horizontally between the vertical planes, not including any beveled or rounded tread surfaces which slope more than twenty degrees.