On March 21, 2019, the Occupational Safety and Health Standards’ Board (OSHSB) granted petition 573 in part to propose new regulations to protect outdoor workers from breathing the toxic air from wildfire smoke. On May 8, 2019, an advisory meeting was held to gather input on the development of this emergency rule-making proposal.
The proposed legislation contains multiple requirements. The main ones call for employers to measure air quality before and throughout each shift, and they establish a system to communicate hazards to all workers.
The full text of the proposal details a complex procedure for monitoring and controlling the air quality, which includes moving workers around, increasing rest times to lower heart rates, and providing work areas that have filtered air.
On the surface, the proposal sounds reasonable and even necessary. Wildfire smoke contains vapors, gases, and solid and liquid particles that include carbon dioxide, carbon monoxide, nitrogen oxide, and fine particulate matter.
Small particles of less than 10 micrometers in diameter pose the greatest risk to human health since they penetrate deeply into the lungs and enter the bloodstream. Studies have indicated that breathing wildfire smoke is heavily associated with respiratory morbidity and the development of asthma and COPD.
Protecting outdoor workers from wildfire smoke is clearly necessary. However, the way the legislation has been written is causing concern among hospitals.
Hospitals want the proposal reworded
According to the response filed by the California Hospital Association, the proposed law, as currently written, would impede a hospital’s ability to care for patients in emergency situations. The regulation exempts “emergency response personnel performing lifesaving emergency rescue and evacuation”; however, the legislation suggests that health-care workers that evacuate patients in an emergency qualify as “outdoor workers.
As long as health-care workers evacuating patients are regarded as “outdoor workers,” they would be subject to the regulations, which would make it all but impossible for them to do their job. The CHA argues this premise is flawed and should be corrected to reflect the perspective that hospital workers in an evacuation scenario qualify as “emergency response personnel.”
The CHA also explained in its statement that hospitals have respiratory protection plans in place already and are required to have N95 respirators available. Anyone required to work outside will be offered appropriate protection.
Protection is also supplied to people inside a hospital to a degree, in the form of air filtration systems. Wind can blow wildfire smoke for miles, so a quality air filtration system and a filter with a high MERV rating are the best indoor protection for people who don’t have a respirator.
An air filtration system can only help to a limited degree, however. Heavy smoke can overwhelm the effectiveness of even the best system.
Hospital patients don’t have access to respirators, so if smoke becomes too intense, they will be compelled to evacuate the building.
Contaminated air is a big deal
The push for extra protection for outdoor workers is understandable, considering the dangers of contaminated air. Wildfire smoke increases the risk of mortality from lung cancer, ischemic heart disease, and cardiovascular disease.
Firefighters are at high risk for all these diseases. Some of the toxic ingredients in wildfire smoke include:
- Aldehydes (volatile organic compounds). These compounds irritate the eyes, nose, and throat. They cause lung inflammation, cough, shortness of breath, and chest pain. Formaldehyde is an example of an aldehyde.
- Sulfur Dioxide. Sulfur dioxide is an irritant to the eyes, skin, and upper respiratory tract, and can cause bronchoconstriction. When combined with water vapor, sulfur dioxide forms sulfuric acid.
- Carbon monoxide. When carbon monoxide is inhaled, it displaces oxygen by attaching to red blood cells. The blood cells have less capacity to carry oxygen, which can lead to hypoxia. The work firefighters perform creates an increase in respiratory rates, which raises the amount of carbon monoxide they inhale.
A four-year study done by the U.S. Forest Service’s National Technology and Development Program measured carbon monoxide levels along with levels of particulate matter. Researchers found carbon monoxide to be an indicator that other irritants and toxins are present. In the study, as carbon monoxide levels rose, so did the levels of other toxins.
- Acrolein. Breathing in acrolein increases the possibility of respiratory infections and irritates the nose, lung, and throat. It can cause chronic respiratory irritation, and prolonged exposure can damage the proper functioning of the lungs.
- Benzene. Benzene isn’t deadly, but it causes headaches, dizziness, nausea, confusion, and irritates the respiratory tract. Prolonged exposure limits the body’s ability to repair DNA.
- Crystalline silica. Although classified as a carcinogen by OSHA, inhalation of crystalline silica can cause silicosis — a noncancerous lung disease.
We can minimize the risk of smoke inhalation, but elimination is impossible
As long as wildfires occur, we can’t eliminate the inhalation of smoke for outdoor workers and firefighters. People may move to regions that are less affected by smoke, but firefighters and outdoor workers have to face it.
One would hope California legislators will take the input from the CHA under advisement, and alter the wording to allow hospital workers to be classified as emergency personnel during an evacuation. The bill is currently in the Senate, and it shouldn’t be long before it gets voted on.