OSHA Winter Workplace Safety Requirements for Richmond Businesses
Published: December 22, 2025 • 13 min read
OSHA cited a Richmond warehouse $15,000 last winter after an employee slipped on ice in the loading dock. The employer argued the ice formed overnight and they hadn't had time to treat it. OSHA didn't care.
Federal workplace safety regulations don't pause for winter. If anything, they're stricter when weather creates obvious hazards.
OSHA's General Duty Clause
OSHA doesn't have a specific "snow and ice" standard. Instead, they rely on the General Duty Clause, Section 5(a)(1) of the OSH Act:
"Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees."
Snow and ice are "recognized hazards." If someone gets hurt and OSHA investigates, you need documented proof that you took reasonable steps to mitigate the hazard.
"We didn't know it was icy" is not a defense. "We didn't have time to clear it" is not a defense.
Walking and Working Surfaces Standard (29 CFR 1910.22)
This is the standard OSHA uses to cite employers for slip-and-fall hazards, including winter conditions.
Key requirements:
1910.22(a)(1): Keep walking surfaces clean and dry
"All places of employment, passageways, storerooms, service rooms, and walking-working surfaces are kept in a clean, orderly, and sanitary condition."
Snow and ice violate this requirement. You must clear them or provide an alternate safe route.
1910.22(a)(3): Address slippery conditions promptly
"Walking-working surfaces are maintained free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow, and ice."
This is the big one. Snow and ice are explicitly listed as hazards you must eliminate. "Promptly" means within a reasonable time based on the severity of the hazard.
What "Reasonable Time" Means
OSHA doesn't define exact timeframes. They evaluate based on circumstances:
- Severity of hazard: Black ice on a loading dock where forklifts operate requires faster response than light snow on a rarely-used walkway.
- Employee exposure: 50 employees walking through an area daily vs. 3 employees weekly.
- Available resources: Did you have a snow removal contractor on call? Did you have salt stockpiled?
- Warning measures: Did you barricade the area and post signs while waiting for treatment?
A Chesterfield manufacturer was cited after an employee fell on ice at 6 AM. The ice formed overnight. OSHA's argument: The employer knew overnight freezing was possible and should have inspected and treated walking surfaces before employees arrived.
The citation stuck.
Outdoor Work Areas: Parking Lots, Loading Docks, Walkways
If your employees work outdoors or must access outdoor areas (parking, loading docks, smoking areas), you're responsible for those surfaces.
OSHA expects:
Pre-Storm Preparation
- Monitor weather forecasts
- Pre-treat surfaces with anti-icing agents when freezing precipitation is expected
- Stock de-icing materials (salt, sand, ice melt)
- Ensure snow removal equipment is functional
During Active Weather
- Clear snow at regular intervals (don't wait for it to stop)
- Apply de-icer to prevent ice formation
- Barricade untreated areas with cones and caution tape
- Provide alternate routes where possible
Post-Storm
- Inspect all walking surfaces before employees arrive
- Re-treat areas where ice has re-formed overnight
- Clear catch basins and drains to prevent refreezing of meltwater
- Document all clearing and treatment activities
Indoor Hazards: Tracking Snow Inside
Employees walk through snow outside, then track water and slush indoors. Wet floors are slip hazards.
Required controls:
- Entry mats (absorbent, non-slip backing, long enough for 3-4 steps)
- Frequent mopping of high-traffic areas
- Wet floor signs when mopping or when tracked water accumulates
- Boot scrapers or boot removal areas before entering
A Richmond office building was cited after an employee slipped on water tracked in from the parking lot. The employer argued they couldn't control weather. OSHA said they could control floor maintenance and matting.
Cold Stress and Outdoor Workers
If your employees work outdoors in winter (construction, landscaping, delivery drivers, parking lot attendants), you must protect them from cold stress.
Virginia winters are mild compared to Minnesota, but cold stress can occur in temps as warm as 40°F when combined with wind and wet conditions.
Cold Stress Hazards:
- Hypothermia: Core body temperature drops below 95°F. Symptoms: shivering, confusion, slurred speech.
- Frostbite: Tissue freezes, usually fingers, toes, ears, nose. Skin turns white or grayish-yellow.
- Trench foot: Prolonged exposure to cold, wet conditions. Feet become numb, swollen, discolored.
OSHA cold stress prevention guidelines:
- Train workers to recognize cold stress symptoms
- Provide warm break areas for workers to warm up periodically
- Schedule frequent breaks when temps drop below 32°F with wind
- Provide or require appropriate clothing (insulated, layered, waterproof)
- Monitor workers for signs of cold stress, especially new or returning workers who aren't acclimated
- Encourage warm, sweet beverages (avoid caffeine, which increases water loss)
Personal Protective Equipment (PPE) for Winter
Standard PPE requirements apply in winter, but you might need additional equipment.
Winter-Specific PPE Considerations:
- Footwear: Slip-resistant soles rated for ice. Plain leather-sole boots don't cut it.
- Gloves: Insulated, waterproof, but thin enough to maintain dexterity for tasks.
- High-visibility clothing: Daylight hours are shorter. If workers are near traffic or equipment, reflective gear is critical.
- Head protection: Insulated hard hats if working in construction. Warm hats or balaclavas for non-construction outdoor work.
Under 29 CFR 1910.132, employers must assess the workplace to determine if PPE is necessary. In winter, that assessment should include slip hazards and cold exposure.
Virginia-Specific Regulations
Virginia operates a state OSHA plan (VOSH) that's at least as effective as federal OSHA. For most standards, Virginia mirrors federal requirements.
However, Virginia has its own enforcement priorities. The Virginia Department of Labor and Industry (DOLI) focuses heavily on construction and high-hazard industries.
If you're in construction, manufacturing, or warehousing in Richmond, expect stricter scrutiny than a retail office.
Documentation That Saves You from Citations
If OSHA investigates a slip-and-fall, they'll ask for your records. Here's what you need:
1. Snow Removal Logs
Date, time, areas cleared, materials used, name of person who performed the work.
GPS-tracked service from contractors is even better. Shows exactly when and where service occurred.
2. Weather Monitoring Records
Printouts from NOAA, Weather Underground, or commercial forecasting services showing you monitored conditions.
3. Training Records
Proof that employees were trained on:
- Slip-and-fall hazards
- Proper footwear
- Cold stress recognition
- Reporting procedures for icy conditions
4. Inspection Checklists
Daily walkthrough logs showing someone inspected outdoor walking surfaces before employees arrived.
5. Incident Reports
Near-miss reports and actual slip-and-fall incidents. Shows you're tracking hazards proactively.
Sample Winter Safety Program
OSHA doesn't require a written winter safety program, but having one demonstrates you're taking the General Duty Clause seriously.
Essential Elements:
- Designated Responsibility: Who monitors weather? Who authorizes snow removal? Who inspects walking surfaces?
- Weather Monitoring Protocol: Check forecasts daily from November through March. Trigger snow removal at specific thresholds (e.g., 1 inch accumulation or any ice).
- Snow Removal Procedures: Contract with professional service or assign internal staff. Define priority areas (main entrances, emergency exits, loading docks).
- Employee Training: Annual training before winter on slip hazards, proper footwear, cold stress symptoms, reporting procedures.
- PPE Requirements: Slip-resistant footwear required for outdoor work. Insulated clothing for prolonged outdoor exposure below 40°F.
- Recordkeeping: Log all snow removal, salting, and inspection activities. Retain for 5 years.
Penalties for Violations
OSHA increased penalties significantly in recent years. As of 2025:
| Violation Type | Maximum Penalty |
|---|---|
| Serious | $16,131 per violation |
| Willful or Repeated | $161,323 per violation |
| Failure to Abate | $16,131 per day beyond abatement date |
Most winter slip-and-fall citations fall under "Serious" violations. If OSHA determines you knew about the hazard and ignored it, that's "Willful."
Workers' Compensation Implications
OSHA citations are separate from workers' comp claims. An injured employee can file for workers' comp (which is no-fault in Virginia) AND trigger an OSHA investigation.
You could end up paying:
- Workers' comp medical bills and lost wages
- Increased workers' comp insurance premiums (your experience mod goes up)
- OSHA fines
- Legal fees if the employee sues for gross negligence (rare but possible)
A Henrico manufacturing facility had an employee slip on ice, break a wrist, and miss 8 weeks of work. Total cost:
- Workers' comp claim: $18,000
- OSHA citation: $13,000
- Insurance premium increase (3 years): $22,000
- Total: $53,000
Their seasonal snow removal contract cost $4,500.
Frequently Asked Questions
Do I need to shovel employee parking lots?
Yes, if employees must park there to access the workplace. OSHA considers parking lots part of the "place of employment" if they're owned or controlled by the employer.
What about sidewalks on public streets?
If your employees must use public sidewalks to reach your building, you should clear them even if the city owns them. OSHA expects employers to control the entire path from parking to building.
Richmond City Code also requires property owners to clear sidewalks within 6 hours of snowfall ending.
Can I just close the business during snow?
Yes. If conditions are too hazardous to clear safely, closing is a legitimate control. But if you require employees to come in, you must provide safe access.
What if an employee refuses to wear slip-resistant boots?
You can discipline or terminate employees who refuse required PPE. Document the requirement, provide the boots (or require specific standards), and enforce compliance.
Do small businesses have different requirements?
No. OSHA applies to all employers regardless of size. Small employers (under 10 employees) have some recordkeeping exemptions, but safety standards are the same.
Ensure OSHA Compliance with Professional Snow Removal
Evergreen Plowing provides documented, GPS-tracked snow removal services that help Richmond businesses meet OSHA walking surface requirements. Service logs, timestamps, and application rates included.