As wildfire activity increases across Arizona, California, Colorado and New Mexico, employers should take proactive steps to protect employees from the health hazards associated with heavy smoke conditions. While California has a specific Wildfire Smoke Emergency Standard, employers in Arizona, Colorado, and New Mexico are also required under federal OSHA’s General Duty Clause to provide a workplace free from recognized hazards, including hazardous air quality caused by wildfire smoke. 

Wildfire smoke contains fine particulate matter (PM2.5), gases, and other contaminants that can irritate the eyes and respiratory system, worsen asthma and heart conditions, reduce lung function, and create serious health risks for outdoor workers and those in facilities with inadequate air filtration. 

California’s wildfire smoke regulation serves as a useful framework for employers throughout the region. The standard applies when the Air Quality Index (AQI) for PM2.5 reaches 151 or higher and employees may be exposed to wildfire smoke. At that point, employers must monitor air quality, communicate hazards to employees, provide training, and implement protective measures to reduce exposure. 

Although Arizona, Colorado, and New Mexico do not currently have state-specific wildfire smoke standards, OSHA recommends similar protective measures whenever smoke conditions create a recognized health hazard. Employers with outdoor operations including agricultural worksites, transportation operations, or other employees working in smoke-affected environments should review their emergency response plans before conditions deteriorate. 

Regardless of where your operations are located, here are a few best practices to keep in mind: 

• Monitor Air Quality Conditions Daily. Designate a responsible individual to monitor local air quality reports before and throughout the workday. Reliable resources include EPA’s AirNow website and local weather or emergency management alerts. Establish clear internal thresholds that trigger protective measures or operational changes. 

• Modify Work Schedules and Job Tasks. When slegmoke levels become unhealthy, consider rescheduling physically demanding tasks, reducing exertion levels, relocating work to less affected areas, or moving employees indoors where air filtration is available. Administrative controls should be considered before relying solely on respiratory protection. 

• Provide Respiratory Protection. Make NIOSH-approved respirators, such as N95 masks, available when smoke conditions become hazardous. Train employees in the proper use, limitations, and storage of respirators. Even when not legally required, providing respiratory protection can significantly reduce employee exposure to harmful particulate matter.

• Train Employees and Supervisors. Training should cover the health effects of wildfire smoke, symptoms of smoke-related illness, reporting procedures, available protective measures, and how employees can access current air quality information. Supervisors should be prepared to identify symptoms and respond quickly when conditions change. 

• Establish Clear Employee Communications. Provide regular updates regarding current smoke conditions, protective measures being implemented, and any operational changes. Communications should be provided in a language and manner readily understood by employees. Employees should also be encouraged to report concerns without fear of retaliation. 

• Prepare Before an Emergency Occurs. Employers should review wildfire smoke response plans before peak fire season, identify employees most likely to be exposed, ensure adequate supplies of PPE are available, and coordinate emergency procedures with heat illness prevention and evacuation plans. Preparing in advance allows a quick response as conditions develop. 

Wildfire smoke events often occur with little warning and can change rapidly throughout the day. Monitoring conditions, training employees, communicating effectively, and implementing protective measures before smoke levels become hazardous will better position your operations to protect workers and reduce potential liability.