When the Air Isn’t Safe: Protecting Workers from Poor Air Quality

Most employers would not send employees into a visibly hazardous environment without first considering how to protect them.

Poor air quality, however, can be easy to overlook.

The source may be hundreds of miles away, the sky may only look slightly hazy, and the workday may already be underway before anyone checks the conditions.  

Poor outdoor air quality can affect employees working outside, driving between locations, working near open loading bays, or working inside buildings where smoke and other pollutants can enter.  

What Is AQI? 

The Air Quality Index, or AQI, is the Environmental Protection Agency’s system for reporting outdoor air quality and its potential health effects.

It tracks ground-level ozone, particle pollution, carbon monoxide, sulfur dioxide, and nitrogen dioxide.  

The higher the number, the greater the health concern: 

• 0–50: Good 
• 51–100: Moderate 
• 101–150: Unhealthy for sensitive groups 
• 151–200: Unhealthy 
• 201–300: Very unhealthy 
• 301 and above: Hazardous 

Employers can monitor current and forecasted conditions online via the EPA’s AirNow website and Fire and Smoke Map.

It may also easily accessible through your own phone’s weather app.  

Health Tool

The AQI is a public health tool, not an OSHA permissible exposure limit.

Federal OSHA also does not have a wildfire smoke-specific standard or a universal AQI level at which work must stop.  

Federal OSHA also does not have a wildfire smoke-specific standard or a universal AQI level at which work must stop.  

That does not mean employers can ignore poor air quality.

OSHA may rely on the General Duty Clause, which requires employers to provide a workplace free from recognized hazards that are causing or likely to cause death or serious physical harm.

Standards addressing specific air contaminants and respiratory protection may also apply depending on the workplace and the exposure.  

These Wildfires Are Wild 

Wildfire smoke is not just a West Coast problem. This summer, smoke from Canadian wildfires traveled across the Great Lakes and into the East Coast, triggering air-quality warnings in several major cities.

For employers in the Northeast, it was another reminder that a wildfire does not have to be nearby to affect employees and workplace conditions.  

Of particular concern is particulate matter small enough to travel deep into the lungs as a result of exposure to air polluted by wildfire smoke.

Exposure can aggravate asthma and other health problems.

Exposure can aggravate asthma and other health problems and may result in coughing, wheezing, eye or throat irritation, headaches, chest discomfort, or difficulty breathing.  

Wildfires are also not the only cause of poor air quality.

Vehicle exhaust, industrial emissions, construction dust, prescribed burns, ground-level ozone, and weather conditions that trap pollutants can all affect the AQI.

Employers should be prepared to monitor air quality even when there is no nearby fire.  

Telling Employees to Wear an N95 Is Not Enough 

Handing employees N95 respirators may seem like a quick solution, but requiring employees to wear them can trigger OSHA’s Respiratory Protection Standard, 29 CFR 1910.134.  

Depending on the hazard and respirator selected, a compliant program may require: 

• A written, worksite-specific respiratory protection program 
• A qualified program administrator 
• An evaluation of the hazard and selection of the proper respirator 
• Medical evaluations 
• Initial and annual fit testing 
• Employee training 
• Procedures for proper use, storage, inspection, and replacement 

An N95 also has limitations. It filters particles but does not protect against gases or vapors or supply oxygen.  

Different rules apply when employees voluntarily use disposable filtering-facepiece respirators. In that situation, the employer must determine that the use will not create a hazard and provide employees with the information in Appendix D to 29 CFR 1910.134.

The full respiratory protection program requirements generally do not apply to voluntary N95 use. If employees must wear an N95 to continue working, describing it as optional will not make it so.  

What Employers Can Do Now 

Employers do not need to wait until the sky turns orange to plan. Practical steps include:  

• Assigning someone to monitor the AQI and someone responsible for making the final call on whether it is safe to work under exposure 
• Identify exposed employees 
• Set internal action levels 
• Reduce exposure where possible  
• Prepare for employee concerns  
• Decide whether N95 use will be voluntary or required and complete the applicable OSHA requirements before respirators are needed
• Put the plan in writing 

The appropriate response will depend on the AQI, the pollutant involved, and the type and duration of the work.

A brief outdoor task is not the same exposure as an eight-hour roofing shift simply because both occur under the same sky.

Poor air quality may arrive with little warning, but an employer’s response when the air outside becomes unsafe should not be improvised.  

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For more information, contact CBIA’s Delmarina López (860.244.1982).