Protection from Wildfire Smoke

Scope

The scope of this procedure encompasses all employees, contractors, and visitors who may be required to perform outdoor work or operate in non-filtered environments when the local Air Quality Index (AQI) for PM2.5 reaches or exceeds the threshold of 101.

This plan does not apply to the following scenarios:

• Enclosed Buildings: Indoor workspaces where the air is filtered by a mechanical ventilation system and the employer ensures that windows and doors are kept closed.
• Enclosed Vehicles: Vehicles in which the air is filtered and windows are kept closed.
• Short-Term Exposure: Employees exposed to an AQI of 151 or greater for a total of one hour or less during a shift.
• Wildfire Firefighters: Personnel actively engaged in wildland firefighting, who are governed by separate respiratory protection standards.

Exposure Assessment

As the air begins to get smoky, each manager or their designee is responsible for checking AirNow.gov, at the start of each shift and as needed thereafter, to determine the AQI. On AirNow.gov type the city of your worksite into the webpage.  Lane’s main campus is located between Eugene, Springfield, and Goshen. The highest AQI of these three cities will be used for the purposes of this procedure. All employees may also use AirNow.gov to check the AQI for themselves.

If AirNow.gov is unavailable, and another digital source like LRAPA or Purple Air is also unavailable, the 5-3-1 visibility method may be used to estimate air quality.

Exposure Assessment: The 5-3-1 Visibility Method

In the event that AirNow.gov, the Oregon DEQ Air Quality Index, or local monitoring data is unavailable or inaccessible at a specific worksite, managers may use the 5-3-1 Visibility Method to estimate the Air Quality Index (AQI). Oregon OSHA adopted this method into its permanent wildfire smoke rules (OAR 437-002-1081) as a "backup" measurement.

This method relies on the ability to clearly see known landmarks at specific distances to determine the level of health risk and the required protective actions.

1. Preparation (Pre-Smoke Season)

Each department with outdoor employees should identify "permanent" landmarks (e.g., specific buildings, hills, or towers) at distances of 1, 3, and 5 miles from the primary worksite.

2. How to Conduct the Assessment

The assessment must be conducted during daylight hours and only when the relative humidity is below 65% (to ensure fog or mist is not mistaken for smoke).

1. Face away from the sun.
2. Determine which of the pre-identified landmarks are clearly visible.
3. Compare the visibility to the table below to determine the AQI category and required action.

3. Visibility Triggers and Actions

4. Documentation

If the 5-3-1 method is used because digital monitoring is unavailable, the manager must document the date, time, the specific landmarks observed, and the resulting AQI estimate in the department's safety logs. As soon as internet/cellular service is restored, the assessment must be verified against official AirNow data.

Training

This course in the LCC learning management system, Vector, must be completed by all employees who may be exposed to ambient air concentrations at or above AQI 101.  Employees should complete this training annually in May.

Method of Protecting Employees from Wildfire Smoke

1. Prioritize work that can be done indoors.
2. If outside work must be done and:
   1. The AQI is at or above 101 and below 250, employees are encouraged to voluntarily wear an N95 mask. For voluntary use (AQI 101–250), the employee must be provided with, read, and sign OSHA Appendix D (found in the LCC Respiratory Protection Program). If an employee chooses to use a reusable elastomeric (cartridge-style) mask voluntarily, a medical evaluation is mandatory before use.
   2. The AQI is at or above 251 and below 500, wearing an N95 mask while working outside is mandatory. In alignment with the LCC Respiratory Protection Program, employees required to wear N95 filtering facepieces solely for protection against wildfire smoke (AQI 251–500) are exempt from medical evaluations and fit testing. However, if an employee reports or exhibits health symptoms related to respirator use (e.g., chest pain or difficulty breathing), a medical evaluation must be provided regardless of the AQI level.
3. When the AQI reaches 501, standard wildfire exemptions end. Working outside is not allowed unless the employee has completed the full 'Pathway to Certification' (Medical Evaluation, Training, and Fit Testing) as required by the LCC Respiratory Protection Program.

Please obtain N95 masks from your manager or their designee.  Employees should be given several N95 masks at a time. Masks are disposable and should only be used for one day. Employees must perform a positive and negative pressure user seal check every time the respirator is put on to ensure a proper seal. N95 masks must be stored in a clean, dry area. If a mask is being reused during a single shift, it should be stored in a clean plastic bag labeled with the employee's name.

What to Do When an Employee Reports or Exhibits Health Symptoms

1. Early Symptoms: Employees must immediately report to their manager if they experience any of the following symptoms of smoke exposure: persistent coughing, wheezing, shortness of breath, chest tightness, increased fatigue, or burning eyes/throat. Managers must allow any employee experiencing these symptoms to move to a filtered air environment or seek medical evaluation.

2. Emergency Care: If an employee exhibits or reports symptoms necessitating immediate medical attention (e.g., asthma attack, severe difficulty breathing, or chest pain):

• Main Campus: Call Public Safety at (541) 463-5555 (Public Safety will coordinate with EMS).
• All other locations: Call 911.

3. Non-Emergency Medical Clearance: Per the LCC Respiratory Protection Program, any employee who reports health symptoms related to wearing a respirator (N95) must be provided a medical evaluation by a Licensed Health Care Professional (PLHCP) at no cost to the employee and during paid time.

Two-Way Communication System

The College will maintain a two-way communication system to notify employees of air quality changes and to allow employees to report worsening conditions or health symptoms.

• Primary Methods:
  • Facilities and Public Safety: Two-way radio.
  • All other employees: Email and [Phone/Text/In-person check-in]. Note: Managers must ensure outdoor workers are notified immediately via a method they can access in the field.
• Employee Reporting: Employees are encouraged to use these communication channels to report:
  • Worsening air quality or visible smoke plumes.
  • Smoke-related health symptoms.
  • Issues with respirator fit or availability.

Action Triggers for Managers 

Managers or designees will issue alerts via the communication system at the following thresholds:

• AQI 101: Notify employees that N95s are available for voluntary use.
• AQI 251: Notify employees that N95 use is now mandatory for all outdoor work.
• AQI 501: Notify employees that all outdoor work must cease (unless the employee is fully certified under the RPP with a medical exam and fit test). Move all staff to filtered indoor environments.

Respirator Limitations and Safety Requirements

1. Greater Hazard Exception (Arc Flash) 

N95 respirators MUST NOT be worn during electrical work where fire-resistant (FR) clothing is required for arc flash protection. In these instances, the risk of the respirator melting or igniting poses a greater hazard than the smoke. Employees performing this work must be prioritized for indoor/filtered air assignments.

2. Facial Hair and Seal Obstructions

Per the LCC Respiratory Protection Program, tight-fitting respirators (including N95s) must not be worn by employees with facial hair (beards, stubble, or long sideburns) that comes between the sealing surface of the facepiece and the face. Jewelry or headgear that interferes with the seal is also prohibited.

3. User Seal Checks

Employees must perform a Positive and Negative Pressure User Seal Check every time they put on an N95 to ensure it is protecting them effectively.

Documentation

Managers must verify that all applicable employees complete the annual wildfire smoke training in Vector.

Annual Review

The Respirator Program Administrator will review the training records annually to evaluate the effectiveness of the wildfire smoke protection program and update this procedure as necessary.