Larse Farms, Inc.
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  • Larse Farms SOP

    Wildfire Smoke Worker Protection
    • Document: SOP no_ 02-07 recordID 327
    • Safety All Persons
    • Standard Operating Procedure [SOP]
    • Risk Assessment   |   All Farm
    • WORKER SAFETY
      Approved By Heather Fichter, Revision no_ 1    2019.09.04

      Who or What:

      The California Occupational Safety and Health Standards Board of the Department of Industrial Relations (Cal/OSHA) issued an emergency regulation requiring protection for workers exposed to smoke from wildfires. The regulation took effect on July 30, 2019.

      Employers must protect workers from exposure to wildfire smoke under these conditions:

      1. An Air Quality Index (AQI) greater than 150 (Hazardous for Sensitive Groups) resulting from the presence of particulate matter of 2.5 microns or smaller (the regulation is not triggered by the presence of other pollutants that may result in an AQI of 150 or greater (ozone, for example); and,

      2. The employer should "reasonably anticipate" that employees may be exposed to wildfire smoke. Exemptions:

      3. Employees in workplaces in enclosed buildings or vehicles with filtered air supplies are exempted.

      4. Employees who are exposed for a total of one hour or less during a shift are exempted.


      Where:
      All workers when wildfire smoke is present

      Hazard:
      Wildfire smoke poses a serious health hazard to all workers as it contains chemical hazards. This can be a major or minor risk depending on the severity of the smoke in the air.

      Contaminant:
      Wildfire smoke
      Prevention Procedure:

      Employee Communication and Training

      1. Communicate information in a manner readily understandable by all affected employees.

      2. Encourage employees to communicate to you about possible wildfire smoke hazards without fear of reprisal.

      3. Inform employees about the current PM 2.5 AQI and protective measures available to them to reduce wildfire smoke exposures.

      4. Encourage employees to inform you about worsening air quality and any adverse symptoms experienced due to wildfire smoke exposure, including asthma, breathing difficulty and chest pain.

      5. Provide effective training and instruction using the regulation's Appendix B (regulatory text linked above in English and Spanish includes Appendix B); this can take the form of workplace training similar to other types of safety trainings you provide employees.

      Control of Wildfire Smoke Exposure:

      1. Use NIOSH-approved respirators such as N-95 respirators

      2. Provide respirators for voluntary use and encourage employees to use them.

      3. Respirator use requirements such as fit-testing and medical evaluation are not required for respirators provided for voluntary use under GISO 5141.1, Protection from Wildfire Smoke.

      4. Train employees using Appendix B and make it available to them in their preferred language. Information in Appendix B and in instructions provided with respirators themselves like fit-testing, medical evaluation, and shaving of facial hair do not apply under this regulation.

      5. N95 respirators are generally readily available, but supplies might be short during a wildfire, so be prepared.


      Protocol, Policy or Correction Procedure:


      Control of Wildfire Smoke Exposure:

      o    Check air quality at the location where employees will be working, both before and periodically during each shift, particularly if you have reason to believe the air quality may be such that it would trigger the regulation.

      Air quality sites:

      US EPA AirNow       (airnow.gov)

      US Forest Service Wildland Air Quality Response Program    (wildlandfiresmoke.net)

      California Air Resources Board  (ww2.arb.ca.gov/air-pollution-control-districts)

      o    Use engineering controls (where feasible): providing enclosed buildings, structures, or vehicles with filtered air; 

      o    Use administrative controls (if practicable) where engineering controls are infeasible or cannot reduce PM 2.5 exposure to an AQI 150 or less: relocating work to a location where AQI is 150 or less for PM 2.5, change work schedules to allow work when air quality is not hazardous, reduce work intensity, or provide additional rest periods;

      o    Use respiratory protection equipment (respirators) where engineering controls are infeasible and administrative controls are not practicable to reduce exposures to below AQI 150 for PM 2.5.

      o    When AQI exceeds 500 from PM 2.5 during a wildfire smoke event, you must comply with respirator use regulations as specified in GISO 5141, Control of Harmful Exposure to Employees. Generally, GISO 5141 imposes requirements for feasible engineering controls, practicable administrative controls where engineering controls are infeasible or insufficiently effective, requires use of respirators when engineering controls and administrative controls prove inadequate, requires medical evaluation and fit-testing, imposes respirator selection criteria and requires implementation of a respirator program.  AQI exceeding 500 for PM 2.5 has been seen for relatively short periods of time in past wildfires; given the probably short duration of such conditions and the time-consuming administrative burdens of GISO 5141, you might want to elect to cease operations until the AQI for PM 2.5 drops below 500 at which time you may resume operations under GISO 5141.1 


      Supporting Docs:
      Protection from Wildfire Smoke (Spanish)

      viewed 2020-09-30 02:10:07 by 173.245.54.239

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