Western North America is suffering from huge wildfires this year. I’ve written pieces discussing ways to protect workplaces from fire (HERE) and to protect workers during wildfires (HERE). Today’s note discusses worker safety during cleanup after wildfires. I synthesize guidance from the US Occupational Safety and Health Administration (OSHA), Centers for Disease Control and Prevention (CDC), US Environmental Protection Agency (EPA), California EPA (CalEPA), and the California Department of Public Health (CDPH).
What hazards may be present after a wildfire?
The most obvious distinction for organizations is whether or not a worksite has been burned at least in part by a wildfire.
• What if fire didn’t reach the workplace, but smoke did?
Even if the workplace itself has not been hit by fire, the organization should consider continuing hazards after an offsite wildfire from:
Ash and other material fallout
An area that was inundated with smoke during an offsite fire will probably be contaminated with ash, soot, and perhaps larger particle fallout. Health agencies remind us that exposure to ash or soot may produce itchy eyes, coughing, shortness of breath, or difficulty breathing, wheezing, chest tightness or pain, palpitations, headaches and nausea, unusual fatigue or lightheadedness. Organizations should therefore hasten to clean up these materials, at least in accessible areas (as a practical matter, roofs may receive lower priorities in expectations that rain will eventually rinse them (but remember stormwater rules!)). Personnel performing cleanups will require appropriate training and protections, and these efforts need to remove these materials rather than just blowing them back into the air. For example, CDPH recommends the flowing tips for safely cleaning up ash in workplaces and homes:
- Never use a leaf blower, as it will spread the ash and blow it back into the air
- Wear a close-fitting respirator rated N-95 or P-100 to block inhalation of ash particles (bandanas, surgical and cloth masks do not effectively block fine particles)
- Wear protective gloves, long-sleeved shirts, long pants, socks and shoes to avoid skin contact with ash
- Remove shoes before entering structures, or use "sticky mats" in entryways to remove dust and ash from shoes
- If someone gets ash on their skin, wash it off as soon as possible
- Keep children and pets out of contaminated areas
Assuming materials are collected (inside a vacuum, for example), they must be contained and disposed safely. If they’re washed into storm drains, then the organization must consider water quality protection requirements.
Continuing air quality issues, in ambient and workplace air
During a nearby fire, the biggest immediate concerns are air quality impacts from smoke. After a fire, some of these issues may persist as burnt-over areas continue to smolder, and as confined spaces that received smoke retain it until they re-equilibrate with cleaner ambient air. Depending on the severity and persistence of these issues – site-wide or in particular areas – your organization may need to continue measures such as:
- respiratory protections for individuals
- air purification and filtration
- special operating requirements for equipment
- air monitoring for contaminants of concern (particulates, ozone, carbon monoxide, carbon dioxide, industrial materials burned and entrained by fires in built-up areas)
- limitations on usability of spaces, including off-limits, usable-with-protections, sanctuary clean areas
- restrictions on activities
These measures may need to be tailored with supplemental protections for at-risk individuals, including those who work at more hazardous tasks and those who may have health issues.
Movement through areas that burned
Once a work area is open, the occupants must keep in mind the hazards associated with traveling through areas that may still be contaminated by recent or ongoing fires, and of (re)introducing contamination to the workplace. Issues include:
- protect driver and passenger breathing
- keep windows and vents closed during movement to protect air quality inside the vehicle
- consider whether to provide respiratory protection
- if a vehicle has a separate storage area (back of truck, for example), evaluate whether it forms a confined space that may accumulate unsafe levels of contaminants
- check arriving vehicles for ash and other particulates, and consider when and how they need cleaning
• What if a workplace was hit by a wildfire?
If a workplace was directly affected, cleanup and reconstruction work will be necessary to restore the site to working condition. These activities present health and safety hazards that require necessary precautions in addition to the basic cleanup issues described above. OSHA identifies the following hazards, many of which are special examples of fairly standard workplace hazards that OSHA regulates:
- electrical hazards
- carbon monoxide poisoning
- lifting injuries
- heavy equipment
- extreme heat
- unstable structures
- hazardous materials response
- confined spaces
- worker fatigue (recovering from activities during fires, and extended/unusual work shifts after fire)
- respiratory protection
- rodents, snakes and insects
- downed electrical wires
- working outdoors
- slips, trips, and falls
In addition, cleanup and restoration efforts require planning, training and equipment, and implementation of activities that may or may not have been present onsite before the incident. Employers have to decide how to budget, staff, schedule and implement; some mix of ongoing employees (who may be unable to work at their usual tasks, if their work areas are damaged or inaccessible) and/or contractors will be needed.
Nearly all areas are potentially susceptible to wildfires, and many areas are subject to much higher likelihood and extent of risks (here in the San Francisco Bay Area we’ve had fire-related health shutdowns and post-fire cleanups for three years in a row). Organizations should prepare for wildfires, and for cleanup after a fire occurs.
Are any of the organization’s facilities subject to wildfires?
If so, has the organization assessed these locations for site-specific wildfire hazards and fire safety measures?
If so, has the organization incorporated hazard reduction and fire safety measures into relevant structures and activities?
If so, does the organization include assessment of wildfire hazards and fire safety measures in the design and construction of new facilities, and selection criteria for selecting facilities to be rented or leased?
Have any of the organization’s facilities been exposed to smoke and/or other interference from a nearby wildfire?
Have any of the organization’s facilities been directly exposed to s wildfire?
Where can I go for more information?
• CDC• OSHA Wildfires safety information page
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years.
Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).
Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).
You may contact Mr. Elliott directly at: email@example.com