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HomeMy WebLinkAbout700-30POLICY & PROCEDURE Subject: Wildfire Smoke Response Plan Index: SAFETY Number: 700-30 Effective Date: 10/02/2024 Supersedes: n/a Page: 1 of 8 Staff Contact: HRRM Approved By: 1.0 PURPOSE: This policy establishes a Wildfire Smoke Response Plan. The plan will protect employees working in outdoor environments from exposure to wildfire smoke by implementing measures in compliance with Washington State regulations (WAC 296-820). 2.0 ORGANIZATIONS AFFECTED: All departments/divisions that have employees who work in outdoor environments. 3.0 REFERENCES: City of Renton Policy 700-05, Accident Prevention Program City of Renton Policy 700-22, Respiratory Protection Washington Administrative Code (WAC) 296-820, Wildfire Smoke 700-30 Appendix: Wildfire Smoke Response Plan Template 4.0 POLICY : The City of Renton is dedicated to protecting the health and welfare of its employees, including during outbreaks of wildfire smoke. The Wildfire Smoke Response Plan will reduce employee exposure to health hazards from wildfire smoke by detailing how harmful air quality conditions will be identified, how wildfire smoke hazards will be communicated with employees, what information will be included in required training, which exposure symptoms require immediate medical attention, and what protective measures will be implemented to minimize exposure. 700-30 Wildfire Smoke Response Plan p. 2 5.0 DEFINITIONS: 5.1 Air Quality Index (AQI): An unitless index used by the U.S. Environmental Protection Agency (EPA) to communicate air quality for several pollutants, including PM2.5. For the purposes of this policy and the Wildfire Smoke Response Plan, AQI means “NowCast AQI for PM2.5.” 5.2 High-efficiency particulate air (HEPA) filter: A filter capable of trapping and retaining at least 99.97 percent of all monodispersed particles of 0.3 micrometers mean aerodynamic diameter or larger. 5.3 PM2.5: Solid particles and liquid droplets suspended in air, known as particulate matter, with an aerodynamic diameter of 2.5 micrometers or smaller. Measured in micrograms per cubic meter (µg/m3). 5.4 Wildfire Smoke: PM2.5 which includes emissions from planned and unplanned fires in wildlands, wildland urban interface, agricultural operations, or adjacent developed areas. Wildfire smoke contains a complex mixture of gases and particulates. Fine particulates such as PM2.5 are the primary pollutant of public and occupational health concern in wildfire smoke. 6.0 PROCEDURES: 6.1 Wildfire Smoke Response Plan Departments (or divisions, sections, or programs) with employees who work outdoors will develop and implement a Wildfire Smoke Response Plan by completing the template provided in the Appendix. The fillable template is located on the Risk Management SharePoint page under “Wildfire Smoke.” This completed plan must be submitted annually to Risk Management by May 15. 6.2 Identification of Harmful Wildfire Smoke Exposures The main pollutant in smoke is the small particles in the air called fine particulate matter, also called PM2.5. PM2.5 measurements are reported in two ways: Micrograms per cubic meter (mg/m3), or NowCast AQI for PM2.5. 700-30 Wildfire Smoke Response Plan p. 3 The wildfire smoke regulations require employers look at hourly PM2.5 averages, which is reported as “Current PM2.5”. NowCast Air Quality Index (AQI) for PM2.5 can also be used, which is a unitless index which uses PM2.5 data averaged over the past 3 to 12 hours. To assess employee exposure to the current PM2.5, the City of Renton will use these methods: AirNow.gov1 AirNow is a partnership of the U.S. Environmental Protection Agency, National Oceanic and Atmospheric Administration (NOAA), National Park Service, NASA, Centers for Disease Control, and tribal, state, and local air quality agencies. City of Renton SharePoint Home Page2 (internal/network access only): display of the AirNow.gov AQI Dial showing the current AQI. Air Quality3 WA mobile app (links to the mobile apps are in the Online tools" section). 1 https://www.airnow.gov/?city=Renton&state=WA&country=USA 2 https://cityofrentonwa.sharepoint.com 3 https://ecology.wa.gov/Air-Climate/Air-quality 700-30 Wildfire Smoke Response Plan p. 4 6.3 Summary of the Wildfire Smoke Role Requirements The following table summarizes the key requirements of WAC 296-820. Current PM2.5 (g/m3) Air Quality Index (AQI) Required Protections 0.0 - 20.4 0 - 71 Prepare a written wildfire smoke response plan. Provide wildfire smoke training to employees. Watch the PM2.5 conditions and forecasts. Prepare a two-way communication system. Make provisions for prompt medical treatment and permit that treatment without retaliation. 20.5 - 35.4 72 - 100 All of the above and: Notify employees of PM2.5 conditions. Ensure only trained employees work outdoors. Consider implementing exposure controls. Consider providing voluntary use respirators. 35.5 - 250.4 101 - 350 All of the above and: Implement exposure controls. Make N95 respirators available for voluntary use. 250.5 - 500.3 351 - 848 All of the above and: Ensure workers experiencing adverse symptoms requiring medical attention are moved to a location that ensures sufficient clean air. Directly distribute N95 respirators to employees for voluntary use. 500.4 - 554.9 849 - 956 All of the above and: Implement a complete required use respiratory protection program per Policy 700-22, Respiratory Protection, including fit-testing, medical evaluations, requiring affected employees to be clean-shaven, and requiring the use of particulate respirators. *Enrollment not required if employee exposed at this level for 15 minutes or less in a 24-hour period. Risk Management recommends that all non- emergency outdoor operations be suspended. 555 or more 957 or more All of the above and: Require respirators with an assigned protection factor APF) of 25 or more. N95 Respirators are not sufficient at this level of smoke. Refer to Policy 700-22, Respiratory Protection. 700-30 Wildfire Smoke Response Plan p. 5 6.4 Wildfire Smoke Hazard Communication to Employees Employees must be informed of the following: When at least two consecutive current PM2.5 readings are 20.5 g/m3 AQI 72) or more. When the current PM2.5 reaches 35.5, 250.5, 500.4, and/or 555 g/m3 AQI 101, 849, and/or 957) or more. What available protective measures are available to employees to reduce their wildfire smoke exposures at each level. Specific information on methods of communication, available protective measures, and how employees will report worsening air quality will be provided in the completed Appendix A: Wildfire Smoke Response Plan Template. 6.5 Employee and Supervisor Training Employees who work outdoors and supervisors who supervise employees who work outdoors are required to receive wildfire smoke training before working in a PM2.5 concentration of 20.5 g/m3 (AQI 72) or more and annually thereafter. Training topics must include: The health effects and symptoms of wildfire smoke exposure; The importance of informing the employer when the employee is experiencing symptoms of wildfire smoke exposure; The right to obtain medical attention without fear of reprisal; The requirements of WAC 296-820-805 through 296-820-860; The employer’s methods of determining the current PM2.5 under WAC 296-820-815; How employees can obtain the current PM2.5, and the employer’s methods to communicate the current PM2.5; The employer’s response plan for wildfire smoke, including methods to protect employees from wildfire smoke, and the exposure symptom response procedures; 700-30 Wildfire Smoke Response Plan p. 6 The importance, benefits, and limitations of using a properly fitted respirator when exposed to wildfire smoke; The risks and limitations of using an unfitted respirator, and the risks of wearing a respirator without a medical evaluation; and How to properly put on, use, and maintain the respirators provided by the employer. Additionally, supervisors will receive training on the following: Procedures the supervisor must follow to implement the applicable provisions of WAC 296-820-805 through 296-820-860; Chapter 296- 820 WAC Wildfire Smoke; Procedures the supervisor must follow if an employee exhibits symptoms of wildfire smoke exposure; and Procedures for moving or transporting employees to an emergency medical service provider, or other appropriate level of care, if necessary. 6.6 Health Effects and Adverse Symptoms of Wildfire Smoke Wildfire smoke contains particulate matter that can reach the deepest parts of the lungs and be absorbed into the body. Health effects include cardiovascular and respiratory diseases, cancer, and nervous system harm. Symptoms of wildfire smoke-related illness can include: Coughing, difficulty breathing, wheezing, shortness of breath, asthma attack, runny nose, sore throat, sinus pain or pressure. Chest pain or discomfort, fast or irregular heartbeat, feeling weak, light-headed, faint, dizzy, pain or discomfort in the jaw, neck or back. Sudden numbness or weakness in the face, arm, or leg – especially on one side of the body; sudden confusion; trouble speaking or difficulty understanding speech; sudden trouble seeing in one or both eyes; sudden trouble walking, dizziness, loss of balance, or lack of coordination; sudden severe headache with no known cause. Headache, scratchy or irritated eyes, fatigue, or tiredness. 700-30 Wildfire Smoke Response Plan p. 7 6.7 Responding to Wildfire Smoke Exposure Symptoms Employees must report symptoms of wildfire smoke exposure so that they can be monitored to determine if medical attention is necessary. Employees may seek medical attention or follow medical advice that they have been given for symptoms potentially related to wildfire smoke exposure. Employees will not be retaliated against for seeking medical attention or following medical advice they have been given. Where the current PM2.5 is 250.5 µg/m3 (AQI 351) or more, employees experiencing adverse symptoms requiring medical attention must be moved to a location that ensures sufficient clean air. Specific information how employees will report symptoms of wildfire smoke exposure, including symptoms that require immediate medical attention, and the identifications of locations that ensure sufficient clean air will be provided in the completed Appendix: Wildfire Smoke Response Plan Template. 700-30 Wildfire Smoke Response Plan p. 8 APPENDIX 1ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN CITY OF RENTON Wildfire Smoke Response Plan ACCIDENT PREVENTION PROGRAM 2ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN This page is intentionally left blank. 3ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN Instructions Each City department, division, section, or program with employees who work outdoors are responsible for completing this document prior to May 15 each year. This document is designed to be completed by entering text in the appropriate location. Each field to be completed is gray in color and bounded by similar color border. Place the cursor inside the text box and answer or provide the requested information. Once completed, print the document for use in your department. Send a pdf copy to Risk Management. As part of the annual training, review the initial/updated wildfire smoke response plan with staff. Document attendance, ensuring all staff that work outdoors have received the annual training. If there are questions, concerns, or suggestions, contact Risk Management for assistance. DEPARTMENT/DIVISION/SECTION/WORK GROUP: Click or tap here to enter text. DATE COMPLETED/UPDATED: Click or tap to enter a date. COMPLETED BY: Click or tap here to enter text. 4ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN Introduction Purpose The purpose of the Wildfire Smoke Response Plan is to help prevent smoke-related illnesses and injuries. City departments with employees who work outdoors are required to complete this template to create a customized plan to meet the requirements in Chapter 296-820 Washington Administrative Code (WAC), Wildfire Smoke, enforced by the Washington State Department of Labor and Industries (L&I), Department of Occupational Safety and Health (DOSH). Supervisors are required to complete this plan and review it with employees initially, annually, and when updates are needed. Evaluate and consider the specific conditions i.e., Air Quality Index and level of physical activity) during your outdoor work activities to successfully tailor this plan and procedures. Attachment A can be used to document the review of this plan with employees. Scope This plan applies to all City employees who work in outdoor environments where it is reasonably anticipated that employees may be exposed to wildfire smoke with some exceptions: The Wildfire Smoke rule does not apply when employees are: 1. Inside enclosed buildings or structures in which the employer ensures that windows, doors, bays, and other exterior openings are kept closed, except when it is necessary to briefly open doors to enter and exit; or 2. Inside enclosed vehicles in which the air is filtered by a properly maintained cabin air filter and the employer ensures that windows, doors, and other openings are kept closed except when it is necessary to briefly open doors to enter or exit. Employees doing the following jobs are considered to meet the description of working in outdoor environments where it is anticipated that they may be exposed to wildfire smoke: list job titles/types and/or tasks] 5ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN Summary of Required Protections The following table summarizes the required protections in WAC 296-820. Column 1 provides ranges of current or forecasted hourly particulate matter concentrations with an aerodynamic diameter of 2.5 microns (PM2.5) measured in micrograms per cubic meter µg/m3). The current Air Quality Index (AQI, shown in column 2) is directly related to the PM2.5 ranges and can also be used to estimate PM2.5 concentrations. Both levels are provided so departments and divisions can utilize the various recognized information sources. Table 1: Wildfire Smoke Worker Protections Current PM2.5 (g/m3) Air Quality Index (AQI) Required Protections 0.0 - 20.4 0 - 71 Prepare a written wildfire smoke response plan. Provide wildfire smoke training to employees. Watch the PM2.5 conditions and forecasts. Prepare a two-way communication system. Make provisions for prompt medical treatment and permit that treatment without retaliation. 20.5 - 35.4 72 - 100 All of the above and: Notify employees of PM2.5 conditions. Ensure only trained employees work outdoors. Consider implementing exposure controls. Consider providing voluntary use respirators. 35.5 - 250.4 101 - 350 All of the above and: Implement exposure controls. Make N95 respirators available for voluntary use. 250.5 - 500.3 351 - 848 All of the above and: Ensure workers experiencing adverse symptoms requiring medical attention are moved to a location that ensures sufficient clean air. Directly distribute N95 respirators to employees for voluntary use. 500.4 - 554.9 849 - 956 All of the above and: Implement a complete required use respiratory protection program, including fit-testing, medical evaluations, requiring employees to be clean-shaven, and requiring the use of particulate respirators. Enrollment not required if employee exposed at this level for 15 minutes or less in a 24-hour period. Risk Management recommends that all non-emergency outdoor operations be suspended. 555 or more 957 or more All of the above and: Require respirators with an assigned protection factor (APF) of 25 or more. N95 Respirators are not sufficient at this level of smoke. 6ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN Roles & Responsibilities City Departments (or Divisions or Sections) To ensure employee safety and to comply with the Washington state rule, departments are required to: Ensure employees who work outdoors and their supervisors complete the Wildfire Smoke Safety training initially and annually. Develop and implement a Wildfire Smoke Response Plan by completing this template. Review this plan with employees initially and annually. Inform employees that they are protected from retaliation for reporting signs or symptoms of wildfire smoke exposure, or for seeking medical care for wildfire smoke-related illnesses or symptoms resulting from outdoor work. Employees Complete Wildfire Smoke Safety training initially and annually. Follow City and department requirements for preventing wildfire smoke-related illnesses or symptoms. Report wildfire smoke-related health symptoms to your supervisor. Recognize and monitor themselves for wildfire smoke health effects and know their personal risk factors for wildfire smoke, which may include asthma, COPD, diabetes, heart disease, pregnancy, and respiratory infections among others. Worker health and safety requirements Employees and supervisors share responsibility for safety at the worksite. This includes watching out for yourself and others and communicating worsening air quality and potential wildfire smoke-related health symptoms. 1. Hazard Communication Departments are required to have a reliable 2-way communication method to relay current air quality conditions and protective measures available to reduce wildfire smoke exposures. Employees must have a mechanism for and be given the opportunity to report smoke-related health symptoms, availability issues of protective measures, such as respirators, and changing conditions. Describe your department/division communication system.] 7ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN Notification to personnel and increasing protective measures are required when at least two consecutive PM2.5 readings or forecasted readings cross a threshold listed in Table 1. Controls can be reduced when two consecutive readings fall below a threshold. Describe how your department/division will obtain accurate AQI information. (Check all that apply). AirNow.gov City of Renton SharePoint page (internal/network access only) Other (List Source)] 2. Exposure Symptom Response Departments must allow personnel who display or report any symptoms (listed in the following section “Responding to Wildfire Smoke-related Illness”) that may potentially be related to wildfire smoke exposure to seek medical attention or follow medical advice they have been given. Departments must not retaliate against an affected individual for seeking such medical attention or following medical advice. Departments must monitor employees displaying symptoms of wildfire smoke exposure to determine whether medical attention is necessary and must have procedures in place for obtaining medical attention for affected employees. Describe your system for monitoring workers for exposure-related symptoms and responding to exposures.] Departments must take steps to reduce or eliminate continued exposure to wildfire smoke as appropriate to an individual’s symptoms, intensity of exposure, and exposure controls in place, including respiratory protection. Describe the steps your department or division will take to reduce or eliminate exposure based on an individual’s symptoms, intensity of exposure, and exposure controls in place.] Where the current AQI is at or above 351 at the location where outdoor work is occurring, departments must ensure employees who are experiencing symptoms that require immediate medical attention are moved to a location with sufficient clean air such as: A location where the current AQI is less than 351; or An enclosed building, structure, or vehicle with HEPA filtration sufficient for the volume of the space. 8ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN Describe the steps your department or division will take to reduce or eliminate exposure based on an individual’s symptoms when the AQI is at or above 351.] Departments must have effective provisions made in advance for prompt medical attention of employees who display symptoms of wildfire smoke exposure. Departments can reference the current First Aid Plans if they already provide suitable provisions. Describe the steps your department or division will take to ensure that employees who display symptoms of wildfire smoke exposure will receive prompt medical attention.] 3. Exposure Controls Controls help prevent personnel from being exposed to wildfire smoke. i. AQI at or above 72 When the current AQI is at 72 or higher at the location where work is occurring, departments are responsible for communicating wildfire smoke hazards, providing wildfire smoke safety training, and providing respiratory protection for voluntary use to personnel upon request. Exposure controls that are required when the AQI is at 101 or higher are optional to implement when the AQI is between 72 and 100. Describe how you are providing required training and respiratory protection for voluntary use. List any additional optional exposure controls.] ii. AQI at or above 101 When the current AQI is at 101 or higher where work is occurring, departments are required to implement effective exposure controls whenever feasible. Such controls include, but are not limited to: Providing work and/or rest areas in enclosed buildings, structures, or vehicles where the air is effectively filtered. Providing portable HEPA filters in enclosed areas. Relocating work indoors, or to an outdoor location with a lower AQI. Changing work schedules so outdoor work can occur when the AQI is lower. Avoiding or reducing work that creates additional exposures to dust, fumes, or smoke. Reducing the amount of work that involves physical exertion. 9ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN Providing additional rest periods. Monitoring personnel for exposure symptoms. Making N95 respirators available for voluntary use. Describe which controls will be utilized and how the selected control measures will be implemented and communicated to employees.] 4. Respiratory Protection Departments may need to provide respirators and either encourage or require employees to wear them (based on the level of wildfire smoke pollution) if work must continue outdoors during a wildfire smoke event. Respirators are used in addition to other exposure controls; they do not replace other exposure controls. When the current AQI is between 72 and 100 where work is occurring, departments are responsible for providing N95 filtering-facepiece respirators at no cost to employees upon request. When the current AQI is between 101 and 350 where work is occurring, departments are required to provide N95 filtering-facepiece respirators to exposed employees. Departments are required to encourage employees to use a respirator; however, employees are not required to use them. Departments must provide respirators by either of the following methods: Directly distribute to each exposed employee; or Maintain a sufficient supply for all exposed employees at each work location where exposure occurs. Respirator supply availability and locations must be made known and be readily accessible to all exposed employees in a manner that does not restrict or hinder employee access to obtain and replace respirators when needed. When the current AQI is between 351 and 848 where work is occurring, departments must distribute N95 filtering-facepiece respirators directly to each exposed employee. Departments are required to encourage employees to use a respirator; however, employees are not required to use them. When the current AQI is between 849 and 956 (beyond the AQI) where work is occurring, personnel must be enrolled in the Respiratory Protection Program. The department is required to provide to employees working outdoors (and employees are required to wear) one of the following respirators: 10ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN N95 filtering facepiece respirator; Half-facepiece air-purifying respirator equipped with P100 filters; or Other respirators equipped with P100 filters, with an assigned protection factor of 10 or greater. The requirement for enrollment in the respiratory protection program does not apply to employees exposed to PM2.5 above the AQI of 849 for a total of 15 minutes or less during a 24-hour period. NOTE: Employees under the age of 18 cannot work in a job where respiratory protection is required. When outdoor work is required at levels above the AQI of 957 and over 555 µg/m3, respirators with an assigned protection factor of 25 are required. Describe the procedure for providing and distributing respiratory protection for the increasing levels of wildfire pollution.] 5. Training Employees working in the jobs listed above are required to receive wildfire smoke safety training initially and annually thereafter. Supervisors of those employees must also receive training. Required training information is included in Policy 700-30, Wildfire Smoke. Describe the plan for providing or arranging training for your department or division.] Responding to Wildfire Smoke-related Symptoms or Illness Employees are encouraged to let a supervisor (or someone nearby) know if they or a coworker are experiencing symptoms of wildfire smoke-related illness and take immediate action to ensure things don’t get worse. Supervisors should ensure the protection of personal health information to the extent possible. Symptoms of wildfire smoke-related illness can include: Coughing, difficulty breathing, wheezing, shortness of breath, asthma attack, runny nose, sore throat, sinus pain or pressure. 11ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN Chest pain or discomfort, fast or irregular heartbeat, feeling weak, light-headed, faint, dizzy, pain or discomfort in the jaw, neck or back. Sudden numbness or weakness in the face, arm, or leg – especially on one side of the body; sudden confusion; trouble speaking or difficulty understanding speech; sudden trouble seeing in one or both eyes; sudden trouble walking, dizziness, loss of balance, or lack of coordination; sudden severe headache with no known cause. Headache, scratchy or irritated eyes, fatigue, or tiredness. Describe your specific emergency response procedures below: 1. Let the individual(s) rest and move to area of better air quality. [List other practices adopted to respond to wildfire smoke-related health emergencies.] 2. [For personnel working alone, specify the supervisor or designee staying in contact with the individual to monitor their recovery and assess the need to contact emergency medical services.] 3. If the individual does not respond quickly, call emergency medical services. Describe the method to access emergency medical services. Include a map and clear directions to give if emergency services are called.] 4. [If the individual is in a remote or non-developed area with unidentified roads, create procedures for moving or transporting them to a place where they can be reached by emergency medical services. For example, you may need to have the supervisor or another person meet emergency services at the closest point to guide them to the ill employee’s location.] If the individual receives medical attention, a written authorization from the provider that the worker can return to work, or if there any work restriction or limitations, is required. The supervisor, the person injured, or another department representative must submit an injury report within 24 hours via Origami Risk. Any inpatient hospitalization requires immediate notification to HRRM. Note: Refer to the City of Renton Policy 700-22, Respiratory Protection for additional information and guidance 12ACCIDENTPREVENTIONPROGRAM ACCIDENT PREVENTION PROGRAM WILDFIRE SMOKE RESPONSE PLAN ATTACHMENT A: Sample Documentation Form Unit or Site-Specific Wildfire Smoke Safety Plan Review Workplace Name: Name Training Date Signature Click here to enter name. Click here to enter date. Click here to enter name. Click here to enter date. Click here to enter name. Click here to enter date. Click here to enter name. Click here to enter date. Click here to enter name. Click here to enter date. Click here to enter name. Click here to enter date. Click here to enter name. Click here to enter date. Click here to enter name. Click here to enter date. Click here to enter name. Click here to enter date. Click here to enter name. Click here to enter date. Click here to enter name. Click here to enter date. By signing this log, you confirm that you have been provided with site specific wildfire smoke safety information, that the content of the information is understood, and that you have had an opportunity to ask questions.