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Heat and coldAbout 5 minutesNo specific OSHA standard

Cold Stress Toolbox Talk

No specific OSHA standard covers this topic. Cold, wet and wind can pull heat from the body faster than a crew notices, and a person sliding into hypothermia may not know it is happening. This short talk covers the four cold illnesses, how to dress in layers and what to do when someone shows symptoms, using CDC/NIOSH guidance. The free PDF has a sign-in sheet.

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At a glance

  • No specific OSHA standard covers this topic. Guidance: CDC/NIOSH cold stress. Weather gear and who pays: 29 CFR 1926.95(d)(4)(ii).
  • About 5 minutes: read the script out loud, then ask the three questions.
  • Free PDF: the script, the questions, the rule and a 20-line sign-in sheet. No account, no email.

Read this to your crew

Today's talk is about the cold. Cold stress happens when the body loses heat faster than it can make it. Wind and wet clothing speed that up, so a damp, windy day can be harder on the body than a still, dry one that reads colder on the thermometer.

There are four cold illnesses to know. Hypothermia: body temperature drops too low. Early signs are shivering, fatigue, loss of coordination and confusion; later, the shivering stops, the skin turns blue, and breathing and pulse slow down. Frostbite: freezing of the skin and the tissue under it, most often the nose, ears, cheeks, chin, fingers and toes; it starts with numbness, tingling or stinging and pale or waxy skin. Trench foot: feet that stay wet and cold for a long time, even at temperatures as high as 60 degrees F. Chilblains: red, itchy, inflamed skin from repeated exposure to cold.

Dress for it. Several loose layers hold heat better than one thick coat. Waterproof, insulated boots. A hat, or a liner under the hard hat. Carry spare socks and gloves, and change them when they get wet.

Work smart in the cold. We put the coldest jobs in the warmest part of the day when we can, take breaks in a warm place, and drink warm, non-alcoholic drinks. Do not touch cold metal with bare skin.

Watch each other, because hypothermia clouds judgment and the person may not know it is happening. If a coworker starts stumbling, slurring or acting confused, get them out of the cold.

First aid. For hypothermia: tell me and call for medical help, move the person to a warm place, take off wet clothing and warm them gradually under a blanket. Warm drinks only if they are conscious, and no alcohol. If there is no pulse, start CPR if you are trained. For frostbite: get indoors, warm the area with warm, not hot, water or body heat, and do not rub it. Keep heat lamps and heating pads off numb skin; it burns easily.

Three questions for the crew

  1. What are the early signs of hypothermia?
    Listen for: Shivering, fatigue, loss of coordination, confusion.
  2. Where is the warm-up spot on this site, and when will we use it today?
    Listen for: A specific place, and breaks planned for the coldest stretch of the day.
  3. What do you do if a coworker starts acting confused or clumsy in the cold?
    Listen for: Get them out of the cold, tell the supervisor, call for medical help and warm them gradually.

Is there an OSHA cold stress standard?

No specific OSHA standard covers this topic. This talk adds no obligation; its guidance comes from the CDC's National Institute for Occupational Safety and Health.

One rule does touch winter gear. Protective equipment used to comply with the construction standards is provided at no cost to employees (29 CFR 1926.95(d)(1)), but the employer is not required to pay for ordinary clothing and items used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots and hats (29 CFR 1926.95(d)(4)(ii)). General industry has the same exception (29 CFR 1910.132(h)(4)(iii)).

The paragraphs, word for word:

“(4) The employer is not required to pay for: (i) Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots; or (ii) Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen.”

29 CFR 1926.95(d)(4)

How do you tell the four cold illnesses apart?

IllnessSignsFirst aid
HypothermiaShivering, fatigue, loss of coordination, confusion; later no shivering, blue skin, slow pulse and breathingMedical help, a warm place, wet clothes off, warm gradually; CPR if there is no pulse
FrostbiteNumbness, tingling or stinging, aching, pale or waxy skinA warm room, warm (not hot) water or body heat, no rubbing
Trench footRed skin, numbness, leg cramps, swelling, tingling pain, blistersWet boots and socks off, dry the feet, avoid walking on them
ChilblainsRedness, itching, possible blistering, inflammationNo scratching, warm slowly, keep blisters clean and covered

Source: CDC/NIOSH, Cold-related Illnesses in Workers.

Inside HazComFast

Cold-weather talks, signed in the field

Give this talk before the first freeze. In HazComFast, the crew signs it on a phone, in English or Spanish, and each signature stays on file.

  • Signed where the signal isn't

    In a basement or a dead zone, the crew can still sign the toolbox talk in Chrome on Android or on a computer. The sign-ins go out once the app is open with a signal again, and each one lands once.
  • Sheets and certificates in Spanish

    Toolbox talk PDFs and training certificates print in Spanish, and compliance reports come out in English, Spanish or both side by side.
  • Thirty hires on a Monday morning

    Import a spreadsheet, see line by line who was created and who wasn't, and print one sheet of QR badges for the morning toolbox talk. Email is optional.
  • Records that stay when a worker leaves

    When a worker leaves, their training records and competent person designation stay on file. The account can't take them along.

New sign-ups are paused · the free tools need no account

Questions about this talk

Does OSHA have a cold weather standard?

No. No specific OSHA standard covers this topic. The federal guidance comes from NIOSH, part of the CDC.

Who pays for winter work gear?

The employer is not required to pay for ordinary clothing and items used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots and hats (29 CFR 1926.95(d)(4)(ii); 29 CFR 1910.132(h)(4)(iii) in general industry).

Can trench foot happen above freezing?

Yes. CDC/NIOSH notes that it can occur at temperatures as high as 60 degrees F if the feet stay wet.

What should workers drink in the cold?

Warm liquids, and no alcohol. NIOSH lists warm liquids among the measures employers provide for cold work, and its first aid for hypothermia rules out alcohol.

What can employers do in cold weather?

NIOSH lists scheduling cold jobs for warmer months or the warmer part of the day, relief workers for long jobs, warm liquids, warm areas for breaks, shorter time outside on extremely cold days, and monitoring workers at risk of cold stress.

Does OSHA require toolbox talks?

No rule requires a talk by that name. Construction employers must instruct each employee in the recognition and avoidance of unsafe conditions (29 CFR 1926.21(b)(2)), and many standards carry their own training duty; a toolbox talk is a common way to deliver part of it.

Do we need a sign-in sheet for a toolbox talk?

No general OSHA rule requires attendance records for a toolbox talk. Some standards require written certification of training, such as fall protection (29 CFR 1926.503(b)(1)) and forklift operators (29 CFR 1910.178(l)(6)). A signed sheet shows who attended; keep the topic, the date, the presenter and the language with it. It does not show that the content was understood.

Go further

More talks on heat and cold

Sources and verification

Paragraphs verified against the eCFR on Oct 20, 2026 (title 29 current to Oct 16, 2026); guidance pages read the same day. State Plan states enforce their own standards; check the state's rule. Not legal advice.

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