As the UK seems to be entering a cold snap, we
anticipate that employers will need to know about ‘minimum temperature
requirements’. CRS has prepared this briefing note to assist employers to
understand the law in this respect, and to know what actions are needed. The
article also addresses warm weather actions and the thermal comfort range.
The law on workplace temperature
The regulatory requirements for workplace
temperatures are set by the Workplace (Health, Safety and Welfare) Regulations
1992 which replaced the requirements under the Factories Act 1961 and the
Offices, Shops and Railways Premises Act 1963. Under the regulations it states
that the temperature of indoor workplaces should be reasonable. The Approved
Code of Practice defines a reasonable temperature indoors as being normally at
least 16°C unless the work involves severe physical work in which case the
temperature should be at least 13°C. A thermometer should be provided in
workplaces. These regulations only apply to employees; they do not apply to
members of the public for example with regard to temperature complaints from
customers in a shopping centre or cinema.
Where
there are requirement for workrooms to operate at lower temperatures for
example for food hygiene purposes you should refer to the specific advice here:
chilled
food advice.
What employers should do
The Workplace (Health, Safety and Welfare)
Regulations 1992 lay down particular requirements for most aspects of the
working environment. Regulation 7 deals specifically with the temperature in
indoor workplaces and states that ‘During working hours, the temperature in
all workplaces inside buildings shall be reasonable.’ However, the
application of the regulation depends on the nature of the workplace, such as a
bakery, a cold store, an office, a warehouse.
The
approved code of practice to the HSW Regulations says ‘The temperature in
workrooms should provide reasonable comfort without the need for special
clothing. Where such a temperature is impractical because of hot or cold
processes, all reasonable steps should be taken to achieve a temperature which
is as close as possible to comfortable. 'Workroom' means a room where people
normally work for more than short periods. The temperature in workrooms should
normally be at least 16 degrees Celsius unless much of the work involves severe
physical effort in which case the temperature should be at least 13 degrees
Celsius. These temperatures may not, however, ensure reasonable comfort,
depending on other factors such as air movement and relative humidity.’
Where the temperature in a workroom would otherwise
be uncomfortably high, for example because of hot processes or the design of
the building, all reasonable steps should be taken to achieve a reasonably
comfortable temperature, for example by:
·
insulating hot plants or pipes;
·
providing air-cooling plant;
·
shading windows;
·
siting workstations away from places
subject to radiant heat.
Where a reasonably comfortable temperature cannot
be achieved throughout a workroom, local cooling should be provided. In
extremely hot weather fans and increased ventilation may be used instead of
local cooling. Where, despite the provision of local cooling, workers are
exposed to temperatures which do not give reasonable comfort, suitable
protective clothing and rest facilities should be provided. Typical examples of
suitable protective clothing would be ice vests, or air/water fed suits. The
effectiveness of these PPE systems may be limited if used for extended periods
of time with inadequate rest breaks. Where practical there should be systems of
work (for example, task rotation) to ensure that the length of time for which
individual workers are exposed to uncomfortable temperatures is limited.
PPE
Where personal protective equipment (PPE) is
required its weight and ability to prevent sweat evaporating can cause thermal
stress. In these situations employers should:
·
Permit work to occur at a slower rate
·
Rotate staff out of this environment
on a more frequent basis
·
Allow longer recovery times before
permitting re-entry
·
Consider scheduling work to cooler
times of the days (early morning, and late afternoon)
·
Periodically revisit your risk
assessment to consider if the process could be automated or alternative systems
of work/controls can be introduced
·
Re-evaluate your PPE as newer PPE may
be lighter and provide improved levels of protection and operator comfort
PPE
is intended to protect employees from a primary hazard. People can sometimes
wear too much PPE though. Look again at the reasons for the PPE. Can your
employees wear less PPE and still have the protection they require?
Alternatively, has PPE been employed as a last resort? Other controls instead
may reduce or eliminate the need for PPE.
ISO
9920 contains tables that you can use to estimate clothing insulation.
Thermal comfort range
HSE previously defined thermal comfort in the
workplace, as: 'An acceptable zone of thermal comfort for most people in the
UK lies roughly between 13°C (56°F) and 30°C (86°F), with acceptable
temperatures for more strenuous work activities concentrated towards the bottom
end of the range, and more sedentary activities towards the higher end.'
In our experience, a ‘thermal comfort policy’ has
proven a good idea. Specifying a range of ‘normally acceptable
temperatures’ helps an employer to agree with their workforce what is
acceptable. When temperatures fall below or above this range, the policy
can outline what management will do to improve the situation. This is
particularly helpful for short periods of cold and hot weather as experienced
in the UK, rather than for a process which is routinely associated with
temperatures outside this range.
Metabolic heat
The main source of heat gain in the body is the body's
own internal heater - metabolic heat. It is generated within the body by the
biochemical processes that keep us alive and by the energy we use in physical
activity. Measuring metabolic rate is very
difficult, requires expensive equipment, a high level of competency and may not
be very accurate in an industrial setting. BS EN 28996 and BS EN ISO 8996
provide a detailed description of how to estimate and/or measure metabolic rate
for those interested.
Useful resources
Heat stress in the workplace – what you need to know as an employer http://www.hse.gov.uk/pubns/geis1.pdf
Health risks from working in the sun http://www.hse.gov.uk/pubns/indg147.pdf
A short guide to the PPE Regulations http://www.hse.gov.uk/pubns/indg174.pdf
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