COLD STRESS ASSESSMENT & SURVEY
A cold stress assessment measures the cold that employees face in cold rooms, freezers, chillers and outdoor work, and checks it against the legal limits. Any employer with refrigerated areas should have cold stress covered in its physical agent risk assessment.
The legal limit in the Physical Agents Regulations, 2024 is an equivalent chill temperature (ECT) of 10 °C. That means the rules can apply to a chiller, not only a freezer. ECT combines air temperature with air speed. Evaporator fans add to the cooling power of the air, so the ECT inside a cold room can be lower than the air temperature. We measure air temperature and air speed, and show where each area stands against the limit.
WHY COLD STRESS MATTERS
Cold stress sets in when the body can no longer maintain its normal core temperature. It causes discomfort, shivering, fatigue, and a loss of dexterity and coordination. Concentration drops and confusion can follow. In severe cases, it causes frostbite and hypothermia.
For the business, cold hands and poor concentration make equipment harder to handle safely, which raises the accident risk and lowers productivity. Freezers bring extra rules. Once the ECT drops below −18 °C, Table 8 of the regulations limits how long employees may stay in the cold. In a freezer held at −18 °C, air movement from the fans can take the ECT below that line.
Cold stress falls under the Physical Agents Regulations, 2024, made under the Occupational Health and Safety Act, 1993 (OHS Act). The assessment and testing duties are:
• Risk assessment (regulation 6): a competent person must assess exposure to physical agents before it starts, then at least every 24 months. The assessment covers cold, heat, lighting, indoor air quality, vibration and non-ionising radiation.
• Cold stress survey (regulations 7 and 9): by a competent person where the risk assessment calls for it, at the interval it sets and at least every 24 months.
• Controls (regulation 17): insulation and other physical agent controls must be inspected and tested by a competent person at least every 24 months.
The regulations do not require an approved inspection authority (AIA) for any of this work. Review your occupational health risk assessment under section 8(2)(d) of the OHS Act together with the results. Our free online Compliance Gap Assessment shows which assessments your workplace needs and which are overdue.
WHAT THE LAW REQUIRES FOR COLD STRESS
HOW WE CONDUCT A COLD STRESS SURVEY
Christo de Wet leads every cold stress survey. He is an occupational hygienist registered with the Southern African Institute for Occupational Hygiene (SAIOH), ROH 0953, with 15 years of experience.
Before the visit, we ask for a list of your chillers, cold rooms, freezers and blast freezers. We also need set-points, shift times and who works inside. We plan the survey for the coldest quarter of the year, as your risk assessment determines it. If you have no current physical agent risk assessment, we can do that first.
On the day, we measure air temperature and air speed in each cold area with calibrated instruments. Fans stay on as they normally would. Monitoring runs for at least 4 hours, in the coldest part of the shift. We record how long employees stay inside, how often they come out to warm up, and the protective clothing they wear.
Afterwards, we work out the time-weighted ECT for each area and compare it with the limit and the Table 8 periods. We are based in Pretoria, work in all nine provinces and are a B-BBEE Level 2 contributor.
- • The time-weighted ECT for each cold area, worked out from measured air temperature and air speed
• Each result compared with the 10 °C ECT limit
• Observed exposure times and warm-up breaks, checked against the Table 8 periods
• A review of protective clothing against the requirement for dry, whole-body clothing with adequate insulation
• Work-rest regimes and other practical controls, in order of priority
• Recommendations ready for your documented action plan
• A report written for management, SHEQ teams and auditors
What affects the quote: the time on site and travel to site. Time on site depends on the size of the site and the number of cold areas and employee groups to cover. Quotations list each service as its own line item.
WHAT YOUR COLD STRESS REPORT INCLUDES
- Does a chiller fall under the cold stress rules?
It can. Regulation 9 applies wherever the ECT is at or below 10 °C, so chillers and cold rooms can be covered, not only freezers. Fans can also push the ECT below the air temperature.
How often must cold stress be assessed?
The physical agent risk assessment is redone at least every 24 months. Review it sooner after an incident or a change in the work or plant. Where it calls for monitoring, the survey follows at the frequency it sets, and at least every 24 months. Plan a new assessment if yours was done under the Environmental Regulations for Workplaces, 1987, which were repealed on 6 September 2026.
Who may do a cold stress survey?
A competent person with knowledge, training, experience and qualifications relevant to cold stress. They must use instruments calibrated to a traceable national or international standard. The regulations do not require an approved inspection authority.
What must we do where the ECT is below −18 °C?
Limit exposure to the Table 8 periods. Down to −34 °C, that means at most 50 minutes of continuous exposure in each hour. After every exposure, employees must spend at least 10 minutes in a comfortably warm area, under supervision. Colder conditions allow much less. Where the cold cannot be eliminated at source, regulation 9 also requires dry, whole-body protective clothing with adequate insulation, among other minimum measures.
FREQUENTLY ASKED QUESTIONS
Free online tool: Compliance Gap Assessment. See what is due at your workplace
Occupational hygiene for food, beverage and cold chain
Occupational hygiene for abattoirs and meat processing
Occupational hygiene for warehousing, logistics and distribution
Cold rooms and freezers: cold stress rules for employers
What must a physical agent risk assessment cover?
What do the Physical Agents Regulations, 2024 require?
What is an AIA inspection in South Africa, and which AIA do you need?
FREE TOOL AND ARTICLES
REQUEST A QUOTE
Send us a list of your cold rooms, chillers and freezers, with their set-points and shift patterns. We will send you a quotation, with travel quoted upfront.
