In recent years, wildfires have become a major concern, especially in hot, dry states across the nation. They may be sparked by power lines, careless cigarette use, campfires, lightning, or other means. Once ignited, a combination of dry conditions, high winds, and challenging terrain means these fires may get out of control very quickly and burn hundreds of thousands of acres of land. And where there is fire, there is smoke which fills the air with chemicals, gases, and soot that can present a health risk to outdoor workers.
PM2.5, tiny particles less than 2.5 micrometers in size, pose the most significant hazard from wildfire smoke. This particulate matter can easily enter the lungs or bloodstream. This exposure is linked to serious health issues such as heart failure, reduced lung function, bronchitis, and worsening asthma.
Additional wildfire hazards or exposures include:
- Excessive heat from the sun or fire;
- Carbon monoxide and other gases;
- Overhead electrical lines and energized equipment;
- Toxic or hazardous substances like lead or mold;
- Falling trees, branches, or floating embers;
- Building or other structural hazards;
- Slips, trips, and falls; and
- Moving vehicles and equipment.
Scope
Though there currently isn’t a specific national standard for wildfire smoke exposure, employers must still protect workers under the General Duty Clause (29 USC 654) by providing a workplace free of recognized hazards. Protective measures include clear operational procedures, air quality monitoring, ensuring the availability of emergency response and personal protective equipment, and providing appropriate training.
California, Oregon, and Washington have implemented wildfire smoke regulations based on the Air Quality Index (AQI). These regulations provide employers with guidelines to protect workers from the harmful effects of wildfire smoke according to air quality levels.
The AQI is a uniform color-coded index developed by the Environmental Protection Agency (EPA) for reporting and forecasting daily air quality nationwide. The AQI reports common ambient air pollutants regulated under the Clean Air Act. It informs the public about local air quality levels, who may be affected, and steps to take to reduce exposure.
The AQI uses a normalized scale from 0 to 500, with higher AQI values indicating poorer air quality and a higher health concern. EPA explains that AQI values at and below 100 are generally considered satisfactory, while values above 100 are considered unhealthy.
Key definitions
- Air Quality Index (AQI): The measurement system used by the Environmental Protection Agency (EPA) to provide information on air quality in real time.
- General Duty Clause: Requirement within the Occupational Safety and Health Act of 1970 requiring employers to furnish a workplace free from recognized hazards that are causing or are likely to cause serious physical harm or death to employees.
- Harmful exposure: An exposure to dusts, fumes, mists, vapors, or gases either in excess of any permissible limit or that inhalation will result in, or has a probability of resulting in, injury, illness, disease, impairment, or loss of function.
- Particulate matter (PM2.5): Particles of soot or other pollutants in wildfire smoke. These particles have an aerodynamic diameter of 2.5 micrometers or less.
- Wildfire smoke: The emissions from fires in wildlands or in adjacent developed areas.
Summary of requirements
- Develop a wildfire smoke plan that addresses procedures for responding to wildfire emergencies.
- Determine if outdoor employees are exposed to harmful amounts of particulate matter from wildfire smoke using EPA’s Air Quality Index (or other measuring tool).
- Check the AQI before each shift and periodically monitor as conditions warrant.
- Control harmful exposures using:
- Engineering controls - Reduce exposures with ventilation, filtered air, or other means.
- Administrative controls - Adjust work schedules, reduce work intensity, add rest periods, or relocate work as needed to reduce exposures.
- Personal protective equipment – Enforce the use of respiratory protection and other protective equipment as conditions dictate.
- Create a communication system to relay wildfire smoke hazards and include a way for employees to inform the employer of wildfire smoke hazards at the worksite without fear of retaliation. The system should notify employees of:
- The current AQI for particulate matter, and
- The protective measures available to reduce their exposures to unhealthy air.
- Encourage employees to report: o Worsening air quality, and o Any adverse symptoms resulting from exposure to wildfire smoke (e.g., asthma attacks, breathing difficulty, etc.)
- Train workers on emergency procedures and requirements for wildfire smoke response. Practice drills are highly recommended for emergency evacuation, shelter-in-place, and critical operation shutdowns.
