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  • OrCAN

Support OSHA’s Heat and Smoke Rules in Oregon

Updated: Mar 3, 2022

Climate hazards such as extreme heat and wildfire events are becoming increasingly common as Oregon’s climate changes and Oregon’s farmers, ranchers and farmworkers are on the frontlines of the climate crisis, bearing the brunt of these impacts.


In addition to threatening our natural and working lands, wildfire smoke and excessive heat pose serious health risks to farmers, ranchers, and farm workers. To help mitigate these effects, Oregon Occupational Safety and Health Administration (OSHA) recently published its final draft of proposed rules to protect workers from climate-fueled wildfire smoke and excessive heat, as directed under Governor Brown’s executive order 20-04, or the Oregon Climate Action Plan (OCAP). The proposed rules are based off of temporary rules in place last summer.

“Strong heat and smoke standards have the potential to provide meaningful protections for Oregon’s agricultural workers and prevent avoidable injury, illness, and death.” OCAP Health Policy Table

Health impacts from wildfire smoke: Coughing, wheezing, chest tightness; difficulty breathing; asthma attacks; increased risk of respiratory and cardiovascular illnesses; pregnancy complications; increased hospital visits; and premature death.

Health impacts from excessive heat: Heat strain; dehydration; fatigue; increased risk for accident and injury; mental distress and confusion; kidney failure; cardiovascular strain; heat stroke and premature death.

OrCAN supports Oregon OSHA’s rules for heat and smoke protections because the farming systems we promote intertwine climate resilience and holistic agricultural principles with high quality jobs paying living wages, safe working conditions, and access to healthy, affordable and culturally appropriate food for all. It is critical that OSHA adopt strong rules without delay, before the next heat and wildfire season puts more Oregon worker lives at risk from extreme climate impacts.

Center image courtesy of AFOP.

What’s in the Rules?

Heat Overview: Trigger applies when the heat index is 80 degrees and higher. High heat provisions triggered at 90 degrees.

  • Trigger applies whether working outdoors or indoors.

  • Protections include access to shade and water, a work/rest schedule, emergency medical & action plan, and more.

  • Read more about the heat rule here.

Smoke Overview: Trigger starts at Air Quality Index (AQI) 101. Applies whether indoors or outdoors. Must implement the following controls:

  • At AQI 101 -voluntary respiratory protection - NIOSH-approved respirators (N-95 or greater) provided by the employer.

  • At AQI 201 -mandatory respirator use -provided by employer.

  • At AQI 501 - mandatory respirator use plus a full respiratory protection plan in place, including annual training and fit testing before exposure occurs.

  • Read more about the wildfire smoke rule here.

How to Express your Support

OrCAN's Guide for Submitting Comments. Send written comments or leave a voicemail for Oregon OSHA by 5:00 pm on March 18th:

  • Call: 1-833-604-0884 (toll free) or 503-947-7396. Voicemail messages may be left 24 hours a day, and must be under two minutes in length.

Thank you to the Heat/Smoke Stakeholder Coalition and OCAP Health Policy Table for all their hard work on this rule over the last year. For more information on the rules and how to make them stronger, please see the coalition's testimony guide.

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