Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine how to control the health hazards of wildfires.
Active wildfires and recovery and cleanup work following a fire pose unique hazards for workers. The health effects of wildfire smoke can range from stinging eyes and a scratchy throat to asthma attacks, chest pain, and a fast heartbeat. Three states—California, Oregon, and Washington—have occupational safety and health standards for wildfire smoke exposures.
Ash, dust, soot; electrical equipment and power lines; and unstable structures pose risks to recovery and cleanup workers. Following a series of wildfires in Los Angeles and Ventura counties, California’s Department of Industrial Relations and its Division of Occupational Safety and Health (Cal/OSHA) gathered or updated guidance and resources for employers involved in recovery and cleanup work.
California’s wildfire smoke standard
California’s “Protection from Wildfire Smoke” standard requires employers to protect workers from the unhealthy air caused by wildfire smoke. The standard’s requirements include informing employees of the air quality index (AQI) for particulate matter (PM2.5) and available protective measures, providing instruction and training on wildfire smoke’s health effects and steps for protection, and handing out respiratory protection for voluntary use.
Employers in the state must monitor the AQI for PM2.5 before and throughout a work shift and modify work, if necessary, or provide approved respirators for voluntary use. The AQI, developed by the U.S. Environmental Protection Agency (EPA), indicates overall air quality based on pollutants regulated under the Clean Air Act.
Employers of outdoor workers must take the following steps to protect employees when the AQI for PM2.5 is 151 or greater:
- Inform employees of the AQI for PM2.5 and protective measures available to them.
- Provide employee instruction and training on information contained in the state’s standard, including the health effects of wildfire smoke, the right to obtain medical treatment without reprisal, how to obtain the current AQI for PM2.5, requirements of the standard, and how to protect themselves from the effects of wildfire smoke.
- Implement feasible modifications to the workplace to reduce exposure. One option is to provide enclosed structures or vehicles where the air is filtered.
- Implement practical changes to work procedures or schedules to reduce wildfire smoke exposure, such as relocating a worksite or reducing the time employees work outdoors or are exposed to unfiltered outdoor air.
- Provide proper respiratory protection equipment, such as disposable respirators, for voluntary use.
Respirators labeled N95, N99, N100, R95, P95, P99, or P100 can filter out fine particles but must be labeled as approved by the U.S. National Institute for Occupational Safety and Health (NIOSH).
When the AQI for PM2.5 exceeds 500 due to wildfire smoke, respirator use is required. Employers must ensure employees use respirators and that their respiratory protection program complies with the state’s standard, including requirements for medical evaluation, fit testing, and training.
Oregon’s wildfire smoke standard
In 2022, the Oregon Occupational Safety and Health Division (Oregon OSHA) established permanent workplace safety and health standards for heat and wildfire smoke exposures. The heat and wildfire smoke rules were built on temporary emergency regulations adopted in summer 2021.
Oregon’s wildfire smoke standard applies when the ambient air concentration for PM2.5 is at or above 35.5 micrograms per cubic meter (μg/m3) (an AQI of 101).
Oregon employers must perform exposure assessments and provide employee information and training that cover symptoms of wildfire smoke exposure and the acute and chronic health effects of wildfire smoke, implement engineering and administrative controls to reduce exposures, and provide filtering facepiece respirators (FFRs) at no cost to employees.
Respirator use is required whenever employee exposure to PM2.5 is at or above 500.4 μg/m3 (AQI of 501).
Mandatory respirator use must comply with the state’s requirements for a respiratory protection program.
Washington state’s wildfire smoke standard
Washington state adopted temporary outdoor heat exposure and wildfire smoke rules in 2022, and a permanent wildfire smoke standard took effect January 15, 2024.
Under the state standard, covered employers must prepare a written wildfire smoke response plan, monitor PM2.5 conditions and forecasts, establish a communications system for informing employees of changing wildfire smoke conditions, and ensure employees who display or report symptoms of wildfire smoke exposure receive prompt medical attention.
Employers in Washington must train workers on wildfire smoke hazards and controls before exposing them to PM2.5 concentrations of 20.5 µg/m3 or higher. Training must be repeated at least annually. An appendix to the rule contains a training program template and a sample wildfire smoke response plan.
Employers must implement exposure control measures when PM2.5 measures 35.5 to 250.4 µg/m3 and make N95 respirators available for voluntary use. At PM2.5 levels ranging from 500.4 to 554.9 µg/m3, employers must provide respirators as part of a respiratory protection program with medical evaluations and fit testing. At levels measuring 555 µg/m3 or greater, employers must require the use of respirators equipped with P100 filters.
Draft hazard review but no federal standard
While there’s no federal standard for occupational exposures to wildfire smoke, NIOSH released the draft hazard review “Wildland Fire Smoke Exposure Among Farmworkers and Other Outdoor Workers” in September 2024.
Natural fuel buildup, extreme weather events, and urban expansion into wildlands have led to more intense wildland fires, according to NIOSH. Wildfire smoke has recently become an increasingly widespread and potentially serious threat to public health.
NIOSH’s review lays out the current knowledge of wildfire smoke impacts, which comes from studies of populations living near wildland fires. It also identifies a need for more research into the occupational risks of wildfire smoke and effective control measures.
NIOSH suggested a tiered approach to hazard assessment and recommended using the EPA’s AQI for PM2.5 to evaluate health risks.
The institute also suggested that effective control measures might include the following:
- Engineering controls like providing filtered air to reduce workers’ wildfire smoke exposure. Filtered air can be provided in enclosed spaces, such as temporary or permanent structures, and vehicles.
- Education, training, and administrative controls aimed at managing exposures. Administrative controls could include worker relocation, reducing shift length, rotating workers, work-rest cycles, and reducing work intensity.
- Respirators—NIOSH-approved personal protective equipment (PPE), such as N95 respirators selected and used in a compliant respiratory protection program—could also protect farmworkers and others who work outdoors.
Fire recovery, cleanup hazards, controls
Fire recovery and cleanup safety hazards include demolition, electricity, excavations, fire and fire byproducts, flammable gases, hauling vehicles, sharp or flying objects, tree work, and unstable structures. Occupational health hazards include asbestos, ash, dust, and soot; carbon monoxide poisoning; hazardous liquids and other hazardous substances; and heat illness.
Following the recent Los Angeles and Ventura County wildfires, the DIR and Cal/OSHA made new and updated resources available for employers engaged in recovery and cleanup work following wildfires.
First, Cal/OSHA updated its worker and employer guidelines for fire cleanup.
The state agency also directed employers to its guidance on respiratory protection during fire cleanup, as ash, dust, and soot can be disturbed during cleanup and could be inhaled. Employers also must provide and ensure employees use properly fitted, NIOSH-approved respirators.
After a power outage, electrocution hazards can occur as power lines are reenergized and electrical equipment is turned back on. Cleanup employers should only allow qualified electrical workers to work on or near downed power lines and restore electrical power. Employers also should only allow qualified line-clearance tree trimmers to perform tree-trimming operations near energized power lines. Other cleanup workers shouldn’t be allowed to perform any work near energized high-voltage lines. Overhead electrical power lines should be considered energized until a utility company verifies the lines aren’t energized and the lines are visibly grounded at the worksite.
Cleanup employers should never assume fire-damaged structures or buildings are stable. Buildings may be structurally damaged or weakened and can collapse without warning, so employers should take precautions, such as assuming all stairs, elevated floors, and roofs are unsafe until inspected and not allowing any work to be performed in or around any fire-damaged structure until it has been examined and certified that it’s safe for work by a registered engineer or another qualified person.
The state’s standards most applicable during recovery and cleanup are its regulations for general safety precautions, electric shock, and injury and illness prevention programs. Cal/OSHA explained that while “household domestic service” (child care, cleaning, and cooking performed for a family) isn’t covered by the state’s safety and health standards, any fire cleanup work performed by domestic workers is covered by the agency and its regulations. Household domestic workers are covered by Cal/OSHA and its standards when performing fire cleanup work and home reconstruction.
Next, the DIR posted updated guidance for workers and employers on how to proceed rapidly and safely to address the risks associated with fire debris removal and cleanup.
Hazardous conditions persist, even after fires are extinguished, according to the DIR. The state’s employers involved in recovery and cleanup operations in fire-damaged areas must assess workers’ risks, address unsafe conditions, and ensure all workers are trained properly.
The DIR emphasized its commitment to protecting workers on the front lines of disaster recovery, ensuring their safety and health as they help restore what’s been lost.
Workers and employers also have access to a wildfire cleanup training tool that’s available in both English and Spanish. Other safety and health issues in recovery and cleanup work covered by the DIR and Cal/OSHA resources include the following:
- Physical hazards. Information is available regarding the risks of structural collapse or contact with live utilities.
- Hazard communication. Informing and training workers on chemical hazards from burned buildings, such as fire retardants, lead or asbestos, and other hazardous materials.
- Cleanup, debris removal, and restoration. Cal/OSHA provides guidance for employers and workers regarding proper training and equipment for safely handling debris during the cleanup of contaminated areas. Cleanup of fire-damaged sites and debris removal must be done in accordance with the state’s Hazardous Waste Operations and Emergency Response (HAZWOPER) regulations.
California also reminded employers of antiretaliation provisions of the state’s labor statutes and regulations. Workers have a right to leave or refuse to report for work in a disaster area if they believe it’s unsafe to remain, and it’s illegal to take action against an employee for refusing to work in unsafe or unhealthy conditions.
You may want to familiarize yourself with the standards and guidance issued by California, Oregon, and Washington if you’re facing the hazards of wildfire smoke or fire recovery and cleanup.