Working in Cold Weather on Construction Sites: UK Guide

There is no legal minimum or maximum temperature for outdoor work. HSE's guidance says there is no law for a maximum working temperature. Its figures of at least 16°C, or 13°C where much of the work involves rigorous physical effort, come from the Approved Code of Practice for the Workplace (Health, Safety and Welfare) Regulations 1992 and apply to indoor workplaces. Most of those Regulations do not apply to a construction site where only construction work is going on (Workplace Regulations 1992, regulation 3(1)(b)).

On site, the duties that matter in winter are mainly in CDM 2015:

• Indoor temperature. So far as is reasonably practicable, the temperature of an indoor construction site during working hours must be reasonable for what the space is used for (CDM 2015, regulation 34(1)).
• Weather protection outdoors. Where it is needed for health or safety, an outdoor site must, so far as is reasonably practicable, be arranged to give protection from adverse weather. The arrangement takes account of the work and of any protective clothing or equipment provided (regulation 34(2)).
• Lighting. The site, its approaches and its traffic routes need suitable and sufficient lighting. Secondary lighting is required wherever a failure of the main lighting would put someone at risk (regulation 35).
• Safe access and traffic routes. There must, so far as is reasonably practicable, be suitable and sufficient safe access and egress (regulation 17). Traffic routes must be regularly checked and properly maintained (regulation 27(4)).
• Rest areas. Rest rooms or rest areas must be maintained at an appropriate temperature (Schedule 2, paragraph 5(2)(e)).

Other law applies too. Employers and self-employed contractors must assess the risks of their work, including cold (Management of Health and Safety at Work Regulations 1999, regulation 3). Work at height may only go ahead when the weather does not jeopardise health or safety (Work at Height Regulations 2005, regulation 4(3)).

Who is responsible? Every contractor must meet the Part 4 requirements for matters within its control (CDM 2015, regulation 16(2)). It must also make sure, so far as is reasonably practicable, that its workers have the Schedule 2 welfare facilities (regulation 15(11)). Where there is more than one contractor, the principal contractor must make sure Schedule 2 facilities are provided throughout the construction phase (regulation 13(4)(c)). A domestic client who controls how the work is done picks up the Part 4 duties for matters in their control (regulation 16(3)).

The clocks went back on 25 October 2026 (GOV.UK), and from now on many sites start and finish in the dark. Plan the tasks that need good light, such as work at height, lifting, excavation and cutting, for the middle of the day.

The site, its approaches and its traffic routes must have suitable and sufficient lighting, natural light so far as is reasonably practicable. Artificial lights must not change how safety signs and signals look. Where a failure of the main lights would put someone at risk, secondary lighting is required (CDM 2015, regulation 35).

In practice:

• light access routes, stairs, scaffold access points, ladders, edges, openings, excavations and the route to welfare;
• check the lights work before it gets dark, not after;
• give stairs and internal areas battery-backed or other secondary lighting;
• use head torches as a back-up, not as the main light for a task;
• place lights so they do not dazzle or leave deep shadows at edges and steps;
• keep lighting cables off walkways (see preventing slips, trips and falls);
• keep petrol generators outside, away from doors and openings (see the carbon monoxide section below).

Work at height must be carried out only when the weather does not jeopardise the health or safety of the people doing it (Work at Height Regulations 2005, regulation 4(3)). Winter storms make this a daily decision.

• Check the forecast for gusts, not just average wind speed.
• Find the maximum wind speed for each MEWP and mobile tower on its data plate or in the manual. It varies from machine to machine, so don't guess.
• Wind is often stronger at height than at ground level. Plasterboard, sheets and boards can catch the wind like a sail.
• Sheeting and netting add wind load to a scaffold, and the scaffold design must allow for it. Ask your scaffold contractor.
• Get the scaffold inspected after high winds. HSE's scaffolding guidance lists high winds as an example of circumstances that call for an inspection, alongside the routine inspection at least every seven days. The law requires an inspection whenever exceptional circumstances liable to jeopardise safety have occurred (Work at Height Regulations 2005, regulation 12(3)(b)).
• Tie down or remove loose materials, sheeting, waste chutes, fencing panels and signs before a storm.
• For lifting operations, stop when the wind limits in the lift plan or the equipment instructions are reached.
• Cold hands grip less well. Plan more breaks for static work at height.

See working at height and scaffolding safety.

The PPE at Work Regulations 1992 define personal protective equipment as including “clothing affording protection against the weather” (regulation 2). Where the risk is not adequately controlled in other ways, employers must provide suitable PPE to their workers (regulation 4(1)), and relevant self-employed people must provide it for themselves (regulation 4(2)). Since 6 April 2022 the employer's duty also covers limb (b) workers, and HSE confirms the PPE must be provided free of charge. The PPE duties do not apply to ordinary working clothes and uniforms that give no specific protection (regulation 3(2)(a)).

PPE is suitable only if it fits the risk, the conditions and the wearer, and does not increase the overall risk (regulation 4(3)). For winter that means:

• Layers: a base layer that moves sweat away from the skin, a warm middle layer and a windproof, waterproof outer layer. Hi-vis should still be on top and visible.
• Head: use a helmet liner or cold-weather accessory, and check the helmet maker lists it for that model. A hat that stops the helmet fitting properly undermines it.
• Hands: insulated gloves keep hands warm but can cost feel and grip. Choose gloves that balance warmth with dexterity for the task (NHBC Foundation). HSE lists BS EN 511 as the standard for gloves that protect against cold.
• Feet: insulated, waterproof safety boots with good grip on ice.
• Spares: keep dry gloves and socks on site. Wet kit loses much of its warmth.
• Eyes: use anti-mist eye protection when moving between warm cabins and cold air.

See PPE for construction.

Before driving to site, the Highway Code says you must be able to see. That means clearing snow and ice from all windows and making sure your lights and number plates are clean (Highway Code, rule 229).

On site, a construction site must be organised so that, so far as is reasonably practicable, pedestrians and vehicles can move without risks to health or safety (CDM 2015, regulation 27(1)). Steps must be taken to prevent unintended vehicle movement and to stop vehicles falling into excavations (regulation 28). Work equipment must be maintained in good repair (Provision and Use of Work Equipment Regulations 1998, regulation 5).

Winter checks:

• clear windows, mirrors, cameras and lights of ice and dirt before moving any vehicle or plant;
• check batteries and starting. Cold reduces battery efficiency (NHBC Foundation);
• never run engines, generators or petrol tools to warm up in an enclosed area (see below);
• grit haul roads and keep pedestrians separate from vehicles, especially in the dark;
• make sure banksmen and signallers are lit and visible;
• watch the ground. Frozen ground can feel firm and then go soft as it thaws, which affects plant stability and excavation edges;
• where an excavation is supported or battered, a competent person must inspect it at the start of each shift and after any event likely to have affected its strength or stability, before work goes on in it (CDM 2015, regulation 22(4)). A hard frost, a thaw or heavy rain can be such an event. See excavation safety.

Cold and wet make hand-arm vibration symptoms worse. HSE describes vibration white finger as the fingertips going white, then red and painful on recovery, in the cold and wet.

The law reflects this. A vibration risk assessment must consider specific working conditions such as low temperatures (Control of Vibration at Work Regulations 2005, regulation 5(3)(g)). The control measures must include considering the provision of clothing to protect employees from cold and damp (regulation 6(3)(i)).

HSE's leaflet for workers (INDG296) advises:

• store tools so their handles are not very cold when next used;
• keep warm and dry, for example with warm waterproof clothing;
• give up or cut down on smoking, because smoking reduces blood flow;
• report tingling, numbness or white fingers early.

See noise and vibration on construction sites.

The Site Book generates RAMS, construction phase plans and site inductions with pre-filled site-specific hazards and control measures for you to review and adjust. For winter work, add:

• the stop criteria for wind, ice and low temperatures, including the concrete or mortar limits from your specification;
• the heating, drying and hot-drink arrangements in the welfare section of the CPP;
• the type of heater, where it goes and how it is ventilated;
• the lighting plan for access routes and work areas;
• first aid for cold injuries and the emergency arrangements for remote or lone work;
• a short briefing at induction on cold stress, ice and carbon monoxide.

A generated document does not decide whether a control is suitable for your site. You and your competent person do. To brief the team, you can use our toolbox talk template. See also how to write a risk assessment and what is a CPP.