Information provided to Oregon Occupational Health Division for Rulemaking to Protect Workers from Wildfire Smoke

In March of 2020, Oregon Governor, Brown issued an executive order to develop a proposal for standards to protect Oregonian workers from excessive heat and wildfire smoke. Oregon recognized the the smoke fom wildfires is a health hazard, and that worker exposures, including to workers who may be more vulnerable to smoke exposures, such as those with asthma, lung disease, or heart disease may be more impacted.

Oregon OSHA has been holding advisor and stakeholder meetings to discuss rulemaking efforts, and in May 26, 2021 has released a Draft Wildfire Smoke Rule.

Various researchers in my department at UW have been in contact with Oregon OSHA, who’ve requested information on heat and wildfire risk and mitigation strategies. This morning, on behalf of the Pacific Northwest Agricultural Safety and Health Center and the Northwest Center for Occupational Health and Safety, we provied a letter sharing information from our groups.

With regard to wildfire smoke PM2.5 information, we sent them our recent papers on historical exposures to agriculture workers in Washington state, and estimates of general population health impacts from the September 2020 wildfire in Washington. We also commented on California’s use of EBAM portable PM2.5 monitoring equipment during the wildfire season to provide better spatial assessment of smoke concentrations, as well as recent work at the UW in using lower-cost sensor technologies in rural areas.

We also provided information on differences in general population PM measurements and standards vs occupational ones, in terms of particle size, averaging times, and risk communication.

We also mentioned differences in activity levels of some workers, which may place them at greater risk than sedentary workers, which I wrote about in a previous post.

Regarding protective measures, we provide information along the hierarchy of controls, noting that PPE such as N95 respirators while practical, may not be fully effective without fit-testing, or feasible for workers in some occupations (e.g., due to heat). Adminstrative controls need to include broad considerations for worker health, including consideration of potential lost wages, from stopping work, thinking about shifting/swaping work activities or environments to reduce dose (i.e., reduce either concentration, time, and/or inhalation rate). Engineering controls may consider evaluation of clear/cool air spaces and novel technologies that may provided ventilated, conditioned, and/or shaded conditions for work.