Working in Cold Stores: Entrapment and Cold Stress

Why is cold store safety handled separately?

In businesses storing meat, dairy products, frozen food and fruit and vegetables, the cold room is the quietest but riskiest part of the warehouse. Insulated walls do not let sound out, doors are heavy and airtight when closed, and the temperature inside is at a level the human body cannot withstand for long. Cold store safety should therefore be addressed under four headings in addition to the general warehouse rules: being shut inside, cold stress, icy floors and vehicle traffic.

There is no separate regulation specific to cold rooms in the legislation; the obligations arise from general provisions. Art. 4 and 10 of Law No. 6331 on Occupational Health and Safety require the employer to address these risks in the risk assessment. Annex 1 of the Regulation on Health and Safety Measures in Workplace Buildings and Annexes contains two important rules:

Item 20: If the nature of the work makes it necessary to work continuously in a very cold environment, measures are taken to protect workers from the cold.
Item 35: Doors on escape routes must always be able to be opened from inside without assistance. Mechanical doors have an emergency stop device that is easily recognisable and accessible; doors that do not open automatically when the power fails must be able to be opened manually.

In food production and storage facilities in Bursa and the surrounding provinces, cold rooms are mostly adjacent to the loading dock. This means that forklift, pallet truck and pedestrian traffic concentrates at the doorway.

How can entrapment in a cold room be prevented?

The typical scenario is this: at the end of the shift, while one worker is counting stock on the back racks, another worker switching off the lights locks the door from outside, thinking nobody is inside. If there is no inside release mechanism or it has iced up, shouting cannot be heard outside. Measures against the risk of being trapped in a cold room should be set up as complementary layers:

Inside release mechanism: Even if the door is locked from outside, it must be possible to open it from inside with a push bar or mushroom-head release. The mechanism is on the inside face of the door and marked with a luminous sign so that it can be found in the dark.
Alarm button inside: There is an illuminated button next to the door, at a height that can be reached from the floor. The button gives an audible and visual alert outside; if possible, the alarm is also forwarded to the security guard or the shift supervisor's phone.
Lighting: The switch for the lighting inside should not be only outside, or there should be emergency lighting inside.
Door heating and seal maintenance: Ice forming on the door frame makes opening from inside difficult. Regularly check that the frame heater works and the seal is intact.
Entry and exit tracking: Place a name board or card system next to the door showing who is inside; the person locking the door first looks at the board, then checks by calling inside and with the lights.
Notification when entering alone: It is made a rule that a worker entering alone informs someone outside and keeps in contact at set intervals.
Powered doors: There is an emergency stop button and the option to open manually in a power cut.
Regular testing: The inside release mechanism and the alarm are physically tested every month and the result is recorded.

The presence of a cold room door release makes the cold room part of the emergency plan. The entrapment scenario, who will hear the alarm, which key will open the door and how the first aider will respond should be written in the plan. For preparing the plan, see our emergency plan guide.

Cold stress and working time in the cold

In a cold environment, the body first reduces blood flow to the hands and feet. Numb fingers and reduced grip strength increase the risk of accidents when carrying boxes or using knives. If exposure continues, symptoms indicating that body temperature is starting to drop appear, such as shivering, slowed speech and movements and difficulty making decisions. Whitening and loss of feeling in the nose, ears and fingertips may be signs of frostbite.

For working time in the cold, the Workplace Buildings and Annexes Regulation requires protective measures to be taken but does not set a numerical time limit. Determine the time in the risk assessment according to these factors:

Room temperature: A 0 / +4 °C cold room and a freezer store below −18 °C cannot be managed with the same plan; warm-up breaks should be more frequent in a freezer store.
Air movement: Working in front of evaporator fans means more heat loss at the same temperature.
Workload: Heavy carrying generates body heat but causes sweating; wet underclothing speeds up heat loss.
Personal condition: The workplace physician assesses the fitness of workers with cardiovascular disease, circulatory disorders or excessive sensitivity to cold at pre-employment and periodic examinations.

The practical arrangement is as follows: set the frequency of warm-up breaks in writing, provide a warm rest area near the store and hot drinks, keep a spare inner layer for changing wet clothing and divide long jobs in the freezer store into short periods.

Icy floors, forklifts and racking

Humid air entering each time the door is opened forms ice at the door threshold and under the evaporator. An icy floor means both slipping for pedestrians and longer braking distances for forklifts. The following measures are a priority:

The door threshold and the area under the evaporator are checked every shift and the ice is broken up and removed; if salt or chemicals are to be used, the risk of contact with the product is assessed.
Using a strip curtain or high-speed door at the doorway reduces moisture ingress and icing; if the strip curtain blocks the forklift driver's view, it is kept transparent and clean.
Glasses and cab windows can fog up when leaving through the door; drivers need to slow down at the doorway and pedestrian crossings need to be marked.
Racks have load limit labels to prevent collapse; frozen pallets can slide.

Our article on the forklift and pedestrian traffic plan in warehouses provides guidance on traffic arrangements inside the warehouse, and our article on safety of food machinery on machinery risks in food plants. The plant room of the refrigeration system should be treated as a separate area that only authorised persons enter, with detection and ventilation against gas leaks.

Freezer store PPE and choice of clothing

Protective clothing against cold is personal protective equipment selected according to the risk assessment under the Regulation on the Use of PPE, CE marked and provided to the worker free of charge. In the product documents, look for cold protection standards such as EN 342 for protective clothing against cold and EN 511 for gloves.

Area	Typical temperature	Recommended equipment
Cold room	0 / +4 °C	Thermal inner layer, insulated jacket, insulated shoes with non-slip soles, insulated work gloves
Freezer store	−18 °C and below	Layered thermal overalls or jacket and trousers, hood and face protection, insulated non-slip boots, gloves protecting against cold
Loading dock	Outdoor air, damp	Windproof outer layer, non-slip shoes, high-visibility vest

A common mistake in choosing freezer store PPE is issuing gloves that are thick but make gripping difficult. When the worker cannot hold the box, they take the gloves off and touch the cold metal racks with bare hands. Choose gloves by trying them for the actual work and keep spares. We explain the whole PPE selection process in our article on selecting PPE.

Cold store checklist

You can use the following list on the monthly site walk:

The inside release mechanism works and is visible with a luminous sign.
The alarm button has been tested; the alert outside can be heard and seen.
The door frame heater works, the seal is intact, the door does not freeze shut.
The entry and exit board or card system is in use.
There is no ice at the door threshold or under the evaporator.
Lighting inside is adequate and emergency lighting works.
The warm-up break routine is in writing and is being applied.
Workers' clothing and gloves are in good condition and spares are ready.
Rack load labels are in place and there is no damage to the racks.
The emergency plan includes the entrapment scenario and it has been drilled.

To adapt this list to your workplace, add cold rooms as a separate section in the risk assessment and link the checks to the OHS calendar, you can use our OHS specialist and risk assessment services. For other risks specific to the food sector, see our food sector page.

Frequently Asked Questions

What should a worker trapped in a cold room do?

First, they should use the inside release mechanism and the alarm button. If the door does not open, they should repeat the alarm, keep moving to generate heat, protect their hands by keeping them under their armpits and move away from the front of the evaporator fan. These steps should be taught to workers when they start the job.

Is there a legal limit on working time in the cold?

OHS legislation does not set a numerical time for work in cold rooms; it requires protective measures to be taken in very cold environments. The frequency of warm-up breaks is determined in the risk assessment according to room temperature, air movement and workload.

Does a cold room door have to open from inside?

There is no article specific to cold rooms in the legislation; however, when the rules that doors on escape routes must be able to be opened from inside without assistance and that risks must be prevented are read together, an inside release mechanism and an alarm are the most basic measures against the risk of being shut inside.

What PPE is needed in a freezer store?

Layered thermal clothing, a hood and face protection, insulated non-slip boots and gloves protecting against cold are needed. The equipment is selected according to the risk assessment, is CE marked and is provided to the worker free of charge.