Wildfire smoke is known to regularly blanket broad regions of Nevada. The presence of smoke from wildfires directly impacts both indoor and outdoor air quality in regions where smoke is present. Wildfire smoke is composed of small particles suspended in the air that present a health hazard for workers exposed to it. These particles can irritate the lungs and have a range of potentially serious health effects from permanently reduced lung function to heart failure. Air quality is monitored using the Environmental Protection Agency (EPA) Air Quality Index (AQI) which identifies the level of air pollution.
In general, outdoor air quality is highly variable depending on location, altitude, and weather conditions. Employers are expected to monitor working conditions at any location where their employees are performing work, to identify hazards that are causing or are likely to cause harm to their employees, and to implement effective methods to control those hazards. While Nevada OSHA has not set an outdoor air quality standard, if the agency determines that workers are exposed to an uncontrolled hazard based on the outdoor air quality at their workplace, the agency could consider an enforcement action under the Nevada General Duty Clause, NRS 618.375(1).
Businesses can take proactive steps to mitigate the effects of wildfire smoke and meet their general duty to protect their employees. Please note that this guidance does not contain new enforceable standards. At this time, neither Nevada OSHA nor the federal OSHA program have promulgated enforceable standards that define outdoor air quality requirements, exposure limits, or work stoppage requirements. When air quality is impacted by wildfire smoke, employers should consider the following:
- Monitor the EPA Air Quality map at least once daily if working in an area exposed to wildfire smoke. The map is located at this website: https://gispub.epa.gov/airnow/.
- Provide training regarding the hazards of wildfire smoke and encourage employees to report worsening air quality issues and any potential personal health effects resulting from poor air quality.
- Determine when respiratory protection is needed and what type is appropriate based on the Respiratory Protection Standard in 29 CFR 1926.103 and 29 CFR 1910.134. 3
- Consider maintaining a sufficient supply of N95 respirators for voluntary use by employees. Employers that allow employees to voluntarily wear N95 respirators must comply with the voluntary-use provisions of 29 CFR 1910.134.
- Follow the activity level guidance in the EPA’s Air Quality Guide for Particle Pollution for the applicable Air Quality Index as shown in Appendix A of the health guidance linked below.
- Consider increasing the frequency of breaks in an indoor environment with appropriate ventilation and air filtering.
- Establish clear procedures for when work stoppage will occur as a result of current air quality levels.
- Establish and implement a plan to respond to employees reporting symptoms of exposure to wildfire smoke.