By David Picton, SVP Safety and Sustainability, EcoOnline
As winter approaches across the Northern Hemisphere, it’s a crucial prompt for organisations to review how chemical substances are stored and handled. A ‘perfect storm’ of circumstances and conditions could radically alter the risk profiles associated with chemical management.
Every season brings its own demands when it comes to chemical management. Sites may need to adjust storage and handling controls as temperatures rise in the summer, while many chemicals behave differently again in the cold. In winter, these seasonal pressures coincide with Christmas holiday shutdowns and January restarts. The transitions between stopping and restarting operations can create the conditions in which temporary workarounds become normal practice.
Equipment may sit idle while maintenance teams undertake unfamiliar or non-routine tasks. When production resumes in the new year, teams are often under pressure to return quickly to schedule.
There are also workforce changes to contend with. Seasonal and agency workers are often employed during busy holiday periods, and more experienced workers take leave or support maintenance projects. In their first weeks on site, workers face significantly higher risk of injury and may be unfamiliar with local procedures and hazards. In fact, the HSE says workers are as likely to have an accident in their first 6 months at work as during the whole rest of their working life.
Risk therefore builds as people, equipment and procedures change at once.
The first weeks on site
The HSE figure reflects vulnerabilities during shutdowns and periods of reduced staffing.
Seasonal, agency and fixed-term workers need time to understand how a site operates. Experience in a similar role or facility can help but it does not automatically prepare someone for a site’s unique ways of working.
Shutdowns also involve tasks outside normal routines, from cleaning equipment to supporting maintenance work. Before starting, workers need to understand which substances are present, what protective equipment is required, when a permit is needed and what to do if conditions change. Crucially, they must also feel able to stop work and raise a concern.
Effective supervision is especially important. Experienced colleagues who hold much of this practical knowledge may be on leave or occupied with maintenance during the holiday period. EHS teams should therefore establish in advance who will brief, train and supervise temporary workers, rather than leaving responsibility unclear.
Clear instructions and supervision help workers identify hazards before work begins, respond when conditions change and avoid relying on assumptions drawn from previous sites. Preparation is therefore a dynamic and core safety control, not simply a box to be ticked in the induction process.
Cold weather compounds holiday risks
The greatest winter risk is not simply the cold itself – bringing wet, icy or windy conditions – but the possibility that procedures no longer reflect the circumstances in which work is taking place.
For instance, some liquids become more viscous or crystallise, slowing their movement through pipes or making them harder to dispense. Dry winter air can raise static risk and cold hands reduce grip and dexterity, making precise handling more difficult. These all add pressure to tasks which already carry a degree of risk.
Instructions written in summer or autumn may assume warmer storage temperatures, predictable equipment performance and easier handling. When conditions no longer match those assumptions, a familiar task may take longer, require different controls or need to be stopped altogether.
Sites must therefore treat the onset of winter as a trigger to revisit planned work rather than relying on assessments completed earlier in the year. EHS teams need to consider the expected temperature, the materials involved, the equipment being used and the demands of each task. Where colder conditions affect storage, movement or handling, instructions and controls must be updated accordingly.
Naturally, the work doesn’t end when the paperwork is updated. Those changes must then be communicated before work begins. Otherwise, workers are left to bridge the gap between the written procedure and the conditions in front of them, creating precisely the circumstances in which unsafe adaptations can take hold.
Avoiding ‘safety drift’
The most dangerous adaptations are often those that appear to work. When circumstances change, workers may introduce workarounds to keep operations moving. If nothing goes wrong, these can quickly be seen as harmless adaptations.
This is how safety drift takes hold: a workaround succeeds once, so it is repeated with less scrutiny and passed between shifts without a clear record of why it was introduced. Over time, a temporary response becomes accepted practice, even though it differs from the documented procedure and may no longer be safe.
Seasonal and agency workers can inherit these habits especially quickly. When they see experienced colleagues completing a task in a certain way, they may reasonably assume that this is the approved method.
Evidence of drift usually appears before an incident occurs. Near misses, worker observations and recurring changes to permits or task plans can reveal where procedures no longer fit the reality of the job. One change may be a justified response to an unusual condition; repeated changes across tasks or shifts indicate that risk is accumulating and the formal process needs review.
The right question, then, is not simply whether someone departed from a procedure, but why completing the work required that departure. Addressing gaps early allows sites to correct the conditions behind the workaround before it becomes embedded.
Before any shutdown begins, leaders should agree how deviations will be reported, reviewed and resolved, including who has authority to pause work. During the restart, short shift debriefs can help teams capture workarounds, near misses and unexpected equipment behaviour before these are absorbed into routine practice.
Winter shutdowns expose the limits of static safety systems in chemical handling. Procedures may appear robust on paper but changing temperatures, staffing and working patterns can be quickly undermined. The real measure of resilience is how quickly a site recognises and closes the gap between planned work and what is happening in real time. That adaptability is what prevents small seasonal pressures from developing into serious incidents.
