Wildfire Smoke Regulations and the COVID Epidemic


One Cal/OSHA COVID-19 regulation (3205) requires employers to maximize outside air ventilation to prevent the spread of the virus. Another Cal/OSHA mandate (5141.1) requires minimum exposure to outside air. Which rule should a facilities manager follow? How can you protect employees from the potentially harmful effects of smoke from wildfire, continue to combat COVID, and still maintain production?

Businesses already impacted by the COVID epidemic get dealt a double blow when the Air Quality Index (AQI) numbers begin climbing. It’s tough enough to keep a building well-ventilated under normal conditions. Combine the COVID virus with wildfire smoke, and the situation can become extremely difficult to navigate.

Wildfire Smoke and COVID-19 Regulations: The Exception

First, Cal/OSHA COVID regulations do make an exception for wildfire smoke. Read further in title 8, section 3205, and you’ll find the following:

…except when the United States Environmental Protection Agency (EPA) Air Quality Index is greater than 100 for any pollutant or if opening windows or maximizing outdoor air by other means would cause a hazard to employees…

Thankfully, the law does provide a way out of the dilemma, but management is still left with a pivotal decision: Do we curtail activities, or is there a way to stay in operation while still protecting our employees?

To exacerbate the issue, the Air Quality Index (AQI) numbers may not always be reflective of your current location. The monitoring point collecting data from ground and satellite observations may be located many miles from your facility. Terrain and wind patterns can also create a significant difference between the AQI number provided and the air quality at your workplace.

Solutions to Minimize Wildifre Smoke Impact & COVID-19 Risk

Wildfire smoke and COVID. Graphic.

Solutions to the Wildfire Smoke and the COVID-19 Dilemma

When wildfire smoke becomes a verified problem at your facility, there are a number of measures you can take to lessen the impact on employees and still keep them on the job. All should be included in your wildfire smoke preparation plan.

  • Shut or minimize your air intakes: When AQI is approaching 151 due to PM2.5, and respiratory health is threatened at your facility, reducing exposure to that air becomes a priority. Don’t allow your ventilation system to keep pumping the hazard you’re trying to mitigate into your building. This action may seem obvious, but enacting it can take longer than necessary when your wildfire smoke plan isn’t readily available or doesn’t get consulted. First responders to medical emergencies know the importance of stopping the bleeding. Your facilities maintenance personnel should likewise get pre-season training on how to stop the smoke. 
  • Educate your employees: Griping is contagious. One disgruntled employee can get the entire crew in a funk — especially when they aren’t sure what management is doing to protect their health. Complaints are often due to poor communication. That’s why education is crucial. Inform workers about the protocols you’ve established and when they will be enacted. Communication that is both candid and interactive can help minimize complaints. A little education can go a long way towards helping your employees feel their safety is a top concern.
  • Be ready to mobilize portable air filtration: When primary ventilation from the outside is no longer possible, you can employ portable air filtration units to assist in maintaining the flow of filtered air. Be sure to use HEPA filters. See the EPA webpage on MERV ratings and HEPA filters for further information. Be sure to properly place the number of air filtration units necessary to provide supplemental air filtration. That number will vary according to the square footage you need to protect. Close access to and airflow from spaces that aren’t needed.
  • Conduct health screening: Employees who are especially sensitive to air quality disturbances can suffer adverse symptoms before wildfire smoke becomes an issue for their less-sensitive co-workers. COVID-19 made employee health screening a standard procedure. You may be able to utilize that data to identify people likely to need special accommodations. Likewise, the information in your wildfire smoke preparation plan can help with screening.
  • Increase cleaning efforts for both COVID and wildfire smoke. Your cleaning protocols for COVID protection should be emphasized when wildfire smoke adds to the environmental threat. There are, however, differences between those two workplace enemies. Cleaning for COVID and cleaning for wildfire smoke have much in common, but not everything is the same. You’ll need to add special cleaning methods to protect your employees. See Wildfire Planning for Business: Prepare, Respond, Recover for a graphic that illustrates both the inside and outside cleaning measures FACS recommends.
  • Allow as many employees as possible to work from home. Home air filtering can be much easier to provide than workplace air filtering. Many of your employees are probably already using a filtration system to maintain the quality of indoor air. At home, they can manage their own health and comfort during wildfire smoke episodes. Some may even opt to travel to an area where air quality is healthier and work from there.
  • Stay updated on the information you need to make the best decisions: Maintain a clear pathway between your company and the latest changes in both the situational and regulatory conditions. Your plan will indicate who is responsible to monitor which data and how they should do it. Certain websites, email lists, telephone or text alert systems, and industry membership sites can all be indispensable. Don’t wait for an urgent need to prompt those connections, though. Monitor them now.

The wildfire smoke tips mentioned above make an excellent starting place for keeping your operations intact during the times when wildfire smoke exacerbates the COVID-19 threat. If you’re at all unsure about how to develop and maintain your wildfire smoke preparation plan, our FACS industrial health experts can provide the necessary coaching and assistance.

What Not to Do About the Wildfire Smoke and COVID-19 Dilemma

Every complete set of instructions includes both “what to do” and “what not to do”. We’ve already indicated some of the “not to do” warnings in the previous list, but we’ll spell them out here to help clarify the best practices to defend your facilities against wildfire smoke:

  • Don’t use air sanitizers — even those that claim to be effective in counteracting the effects of smoke in the air. Rely on your HEPA air filtration system to accomplish the task. Odor masking is not recommended. It could trigger asthmatic reactions in sensitive individuals similar to or worse than the potential physical reactions to wildfire smoke.  
  • Don’t ignore air quality issues until your employees begin to complain. We can’t overemphasize the importance of education and communication. Employees who are informed about the nature of threats to their wellbeing and how you are prepared to address those threats can return to work knowing your company is concerned about their health and ready to respond should the situation warrant. Make sure your managers are equipped to provide updates rather than join the gripe session.
  • Don’t rely totally on AQI readings; they can be incorrect. There are times when common sense is better than forecasting. If the AQI indicates hazardous conditions, but the air outside doesn’t agree, you may choose to keep the outside air flow intact. Be ready to react quickly should the air quality at your location begin to reverse, but the AQI isn’t always an accurate measure of your current environmental experience.
  • Don’t fail to prepare in advance. Not only is it necessary to create a wildfire smoke response and recovery plan, it is crucial that you are very familiar with the document and prepared to act on it when conditions warrant. Go beyond making sure your maintenance team has the necessary equipment, supplies, and knowledge to carry out the plan: Let your employees know it exists and what will happen when it is enacted.

How FACS Can Help Protect Your Company from Wildfire Smoke and COVID-19 Threats

FACS can assist with the development and updating of wildfire response and recovery plans, particulate air monitoring, help with fit testing of employees, the development of respiratory protection programs, assist in communication with all stakeholders, and the conducting of wildfire smoke assessments at your facility.

You can draw on the information we have collected over decades of industrial health experience by calling FACS at (888) 711-9998 or by reaching out via the Contact page on our website.