Cold rooms and freezers: cold stress rules for employers

1 hour ago

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Short answer: where the equivalent chill temperature (ECT) is at or below 10 °C, regulation 9 of the Physical Agents Regulations, 2024 requires controls and dry, insulated whole-body protective clothing, and below −18 °C Table 8 also limits how long employees may stay in the cold. A chiller or cold room at 10 °C ECT or colder is therefore covered, not only a freezer. Cold stress monitoring must run for at least 4 hours, in the coldest period of the shift.

Cold stress falls under regulation 9 and Tables 1 and 8 of the Physical Agents Regulations, 2024 (Government Notice 5952, Government Gazette 52226, 6 March 2025), which took effect on publication. They replace the Environmental Regulations for Workplaces, 1987, which regulation 21 repealed 18 months after promulgation, on 6 September 2026. The February 2026 amendment did not change the cold stress provisions.

The limit, and what ECT means

Occupational exposure limit: an ECT of 10 °C, as a time-weighted average over 4 hours (Table 1). There is no action level for cold stress.
Equivalent chill temperature: an expression of wind chill that reflects the cooling power of wind on exposed flesh, taking into account both the dry-bulb temperature and the wind speed.
Cold stress: a condition that occurs when the body can no longer maintain its normal core temperature.

This limit works downwards: the duties in regulation 9 apply where exposure is at or below 10 °C ECT. Air movement matters, not only the set-point. Evaporator fans add to the cooling power of the air, so the ECT inside a cold room can be lower than the air temperature.

How long employees may stay in the cold

Regulation 9(2)(f) requires you to limit exposure so that it does not exceed the periods in Table 8:

ECT below 10 °C, down to −18 °C: no time limit, although the other measures still apply.
Lower than −18 °C, but not lower than −34 °C: maximum continuous exposure of 50 minutes in each hour. After every exposure, at least 10 minutes must be spent, under supervision, in a comfortably warm environment.
Lower than −34 °C, but not lower than −57 °C: two periods of 30 minutes each, at least 4 hours apart, with total low-temperature exposure of 1 hour per day.
Lower than −57 °C: a maximum of 5 minutes in any 8-hour period.

In a freezer held at −18 °C, air movement from the fans can take the ECT below −18 °C, which brings in the 50-minute rule and supervised warm-up breaks.

The minimum measures in regulation 9

Regulation 9(1) requires cold stress to be eliminated at source where reasonably practicable. Where it is not, and exposure is at or below the limit, you must as a minimum:

implement alternative working methods, and install plant and machinery designed to reduce the risk of cold stress, where applicable;
implement maintenance programmes for plant and machinery, the workplace and workplace systems;
review the design and layout of workplaces, workstations and rest facilities;
review the risk assessment, monitoring programme, medical screening, medical surveillance and control measures;
limit the duration and magnitude of exposure to the periods in Table 8;
provide dry, whole-body protective clothing and equipment with adequate insulation.

Medical screening is required where the risk assessment shows a need (regulation 8). For vulnerable employees, those at higher risk of injury, disease or complications from exposure, you must obtain an occupational medicine practitioner's opinion on whether screening is necessary.

Monitoring cold rooms and freezers

Regulation 9(3) requires the cold stress monitoring programme to:

take into account both the dry-bulb temperature and the air velocity when determining the time-weighted average ECT;
be taken over a period of at least 4 hours;
be conducted during the coldest period of an employee's shift;
be conducted during the coldest quarter of the year, as determined by the risk assessment.

Under regulation 7, a competent person must do the monitoring, with instruments calibrated to a national or international traceable standard, at the frequency the risk assessment sets or at least every 24 months. No approved inspection authority is required. The risk assessment itself must be repeated at intervals not exceeding 24 months, and reviewed sooner when, for example, work methods or plant change, or after an incident.

A quick self-check

List every chiller, cold room, freezer and blast freezer, with its set-point and whether fans run while people work inside.
Check that your physical agent risk assessment covers cold stress and is less than 24 months old.
Where the ECT may be below −18 °C, check exposure times against Table 8: at most 50 minutes at a time down to −34 °C, with supervised warm-up breaks of at least 10 minutes, and much less below that.
Inspect the protective clothing: it must be whole-body, insulated and dry.
Confirm that a comfortably warm area is close to the freezers for warm-up breaks.
Ask your occupational medicine practitioner whether any vulnerable employees need medical screening before cold work.

How Qualitas can help

Our cold stress surveys measure the cold stress parameters in cold rooms, freezers and other cold areas, evaluate clothing insulation and exposure duration, and compare exposure with the limit and the Table 8 periods. The report, written for management, SHEQ teams and auditors, recommends practical controls, including work-rest regimes.

For the wider framework, see our overview of the Physical Agents Regulations, 2024; for hot processes and summer work, see our article on heat stress surveys.

Not sure what your site needs? Start with our free Compliance Gap Analysis, request a quote, or call or WhatsApp 082 649 6599.

This article summarises the Physical Agents Regulations, 2024 (Government Notice 5952, Government Gazette 52226, 6 March 2025), as amended by Government Notice 7149 (Government Gazette 54177, 20 February 2026), for general guidance. It is not legal advice; refer to the regulations for the full requirements.

Christo de Wet is a SAIOH-registered occupational hygienist with 15 years' experience and the founder of Qualitas Occupational Consulting.