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Snow and Ice Accumulation 


By Chris A Hall, CHST

February 2015

When snow and ice come, employee safety takes on a different view.  All employees have to deal with the challenges of driving to work, walking through parking lots, and dealing with below zero temperatures.  Last year most of the country experienced extreme conditions for a portion of the winter and many employers had to adjust schedules and accommodate for the weather.

While many employee’s troubles with the cold end when they walk indoors, there are many workers without that luxury.  Construction trades, utility workers, fire/police are several fields where employees have no choice but to brave the dangerous conditions.  These challenges and risks are at their peak when these workers have to deal with cold, ice, and snow all while working on elevated surfaces.  
OSHA has provided some guidance for working in cold weather and has even created specific instructions for snow and ice removal from elevated surfaces.  Numerous worker fatalities dealing just with snow and ice removal prompted this initiative.  Although the standard rules for fall protection and addressing hazards still apply, they present a reminder of reassessing due to changing conditions (and thus enforcement via the General Duty Clause). 

As an example, roofing activities do not completely stop during the winter months and in some instances become more crucial.   Heavy snowfall on aging roofs creates additional loading which may exacerbate existing damage or leaks.  What a building owner thought could wait until spring or summer, may become an emergency repair in the winter, with dangerous exposures for employees inside and out.   But roofing isn’t the only industry where accessing work or elevated levels may be necessary.  Utility workers, fire fighters, and other construction trades will frequently be called upon to deal with emergency situations due to snow and ice accumulation. 

So what guidance does OSHA provide?  One of the first things to consider when assessing this type of work will be the load bearing capabilities of the roof or structure.  Snow and ice can add a tremendous amount of weight to a structure.  The addition of workers on top of that only compounds the problems.  With significant build-up, employers must assess the loading on the structure and confirm that the addition of employers, materials, or just the shift of snow/ice from one area to another will not cause a collapse of the structure.  OSHA offers many resources on Snow Loading from the US Forest Service, National Weather Service, and the Department of Agriculture.  Other resources are also available through trade groups and university studies. 

Next, all reasonable attempts should be made to remove snow from surfaces from the ground level, or without accessing the elevated surfaces.  There are suggestions of using aerial lift platforms, ladders, or even snow rakes with extensions to limit an employee’s exposure to a fall.  But which each of these suggestions also presents additional hazards.  Aerial lift baskets can easily be rocked back and forth causing some instability, ladders can slip on icy surfaces on the ground or where they come into contact with the structure, and snow rakes can come dangerously close to power lines.  Considerations also have to be made for where the snow will go when loosened.  Using a snow rake can create avalanche like conditions for employees on the ground, especially on sloped roofs. 

In any circumstance, it is imperative that employers work together and take the time to assess these hazards as necessary.  In almost all cases, OSHA will require the use of standard fall prevention, restraint or arrest systems in conjunction with other precautions.   Employers do not receive an exemption or a pass because conditions are treacherous; they are required to address the hazards as they exist or can reasonably be foreseen to exist. 

For more information or a detailed starting point for assessing these hazards, you can read up on OSHA.gov or follow this link https://www.osha.gov/dts/weather/winter_storm/snow_hazard_alert.html


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