Wildfire smoke presents occupational hazards that employers and workers in affected regions must recognize. Smoke from wildfires contains chemicals, gases, and fine particles that can cause acute and long-term health concerns. Wildfire smoke can be a hazard for workers even when they are not close to the fire. The most significant hazard comes from breathing fine particles in the air, which can reduce lung function, worsen asthma and other heart and lung conditions, and cause coughing, wheezing, and difficulty breathing. Hazards can continue even after wildfire crews extinguish them.
Depending on your state's regulations, proper personal protective equipment (PPE) and training could be mandatory for indoor and outdoor workers in wildfire regions. Depending on where you are located, this article lists mandatory requirements and some best management practices employers can incorporate into their safety management system to protect their workers from the hazards of wildfire smoke. An easy way to incorporate wildfire hazards into your safety management system is using a Job Safety Analysis (JSA) and Activity Hazard Analysis (AHA).
Outdoor Workers
The U.S. Department of Environmental Protection (U.S. EPA) regulates outdoor air quality through the Clean Air Act. Under the Clean Air Act, the EPA can mandate employers adhere to the National Ambient Air Quality Standards (NAAQS) and Air Quality Index (AQI). The smallest and usually the most harmful wildfire smoke hazard is particulate matter PM2.5 (solid particles and liquid droplets suspended in air). The small particulates (PM2.5) can present a significant health hazard for workers exposed to the smoke, even when they are not working near a wildfire. It can affect the lungs, worsening conditions like asthma, chronic obstructive pulmonary disease (COPD), bronchitis, and pneumonia. Wildfire smoke can also affect the heart and increase the risk of a heart attack.
Federal Occupational Safety and Health Administration (OSHA) does not regulate outdoor air quality; however, states such as California have more stringent outdoor air quality standards. The California Department of Industrial Relations Division of Occupational Safety and Health (DOSH), or Cal/OSHA , published their own Protection from Wildfire Smoke standard. The standard applies to workplaces where the U.S. EPA AQI for PM2.5 particulate is 151 or greater ("unhealthy") and where the employer should reasonably anticipate that employees may be exposed to wildfire smoke.
The Cal/OSHA Protection from Wildfire Smoke standard mandates the following actions from employers in wildfire regions:
- Identify harmful exposures: Determine employee exposure to PM2.5 at the start of each shift and periodically thereafter, as needed. Incorporating this step into your Job Safety Analysis (JSA) or Activity Hazard Analysis (AHA) is an extra reminder for your outdoor workers to check the air quality.
- Communicate with employees: Implement a system for communicating wildfire smoke hazards in a language and manner readily understandable by all employees, such as a JSA or AHA. This includes encouraging employees to inform their employer of worsening air quality and adverse symptoms that might be related to wildfire smoke.
- Train and instruct employees: Provide effective training on the information stated in the standard.
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Control harmful exposures to employees: List the engineering or administrative controls on a Job Safety Analysis (JSA), Job Hazard Assessment (JHA) or Activity Hazard Analysis (AHA):
- Engineering Controls: Where feasible, provide engineering controls such as an enclosed location with filtered air so that employee exposure to PM2.5 is less than a current AQI of 151, or to the extent feasible.
- Administrative Controls: If engineering controls are not feasible or adequate, use practicable administrative controls such as relocating to another location where the current AQI for PM2.5 is lower, change work schedules, reduce work intensity, or provide more rest periods.
- Respirators: Provide enough National Institute for Occupational Safety and Health (NIOSH) approved respirators if workers’ exposure to PM2.5 cannot be reduced to a current AQI of 150 or lower. When chosen and worn correctly, respirators can reduce exposure to wildfire smoke. One common type of respirator suitable for protection against wildfire smoke is an N95 filtering facepiece mask. Items such as bandanas, scarves, or t-shirts worn over the nose and mouth will not provide sufficient protection against wildfire smoke.
If your state does not have a wildfire smoke standard, U.S. EPA and the Centers for Disease Control (CDC) recommend the following best management practices for employers where wildfire smoke hazards exist:
- Relocate work to less smoky areas.
- Reschedule work until air quality improves.
- Reduce the level or duration of physical exertion.
- Where feasible, provide enclosed structures for employees to work in, where the air is filtered.
- Where feasible, provide enclosed vehicles. During times of poor air quality, operate the air conditioning in “recirculate” mode and keep vents and windows closed.
Indoor Workers
Windborne wildfire smoke can be a hazard for workers in offices and other commercial buildings as well. Wildfire smoke can enter an office building through open windows, doors, and malfunctioning heating, ventilating, and air conditioning (HVAC) units. These recommendations are not mandatory, but employers should consider applying the following best management practices to reduce wildfire smoke in office and commercial settings:
- Ensure the HVAC system is working correctly and that air filters are clean and properly seated.
- Work with an HVAC technician to determine the highest filtration rating your HVAC system will support and use the highest rating possible when smoke is present. Filters with high filtration ratings require more frequent change-outs, but these steps can improve indoor air quality.
- Consult with a qualified HVAC technician or ventilation engineer before reducing building air intake to ensure air pressure remains slightly positive. If the air pressure becomes negative compared to the outdoors, pollution will infiltrate the building through the exhaust system and other openings.
- Portable high-efficiency HEPA air cleaners can improve air quality in small, defined spaces by removing fine particulates. Do not use ozone generators, personal air purifiers or electrostatic precipitators, and ionizers that produce ozone.
Each employer is responsible for the safety and health of its workers and for providing a safe and healthful workplace. Employers are required to protect workers from the anticipated hazards associated with wildfires. As you prepare your next Job Safety Analysis (JSA) or Activity Hazard Analysis (AHA) hazards of wildfire smoke may be an essential part of your hazard assessment. A JSA worksheet will help workers identify wildfire smoke hazards and determine what controls and safety procedures can be implemented. For JSA software to aid in creating JSA worksheets and activity hazard analysis forms, visit www.JSABuilder.com.
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