Cal/OSHA Releases Wildfire Smoke Respiratory Protection

Interim Guidance

Bryan Little, Farm Employers Labor Service

September 30, 2020

On September 29, Cal/OSHA released Temporary Guidance Strategies for Optimizing the Supply of N95 Respirators for Wildfire in response to pleas from representatives of employer stakeholders about the unavailability of N95 respirators mandated to be provided to outdoor employees by the Cal/OSHA Wildfire Smoke regulation (GISO 5141.1).  The guidance permits limited use of disposable N95 respirators that are expired (beyond manufacturers’ specified shelf life), use of other types of NIOSH-certified re-useable respirators including quarter-mask, elastomeric half- and full-mask respirators (note: the agency indicates use of non-disposable respirators for GISO 5141.1 compliance purposes requires medical evaluation as required for respirators under the general respirator protection standard (GISO 5144) but not fit-testing), power air-purifying respirators and other types with appropriate filters; limited re-use of used N95 respirators (for more than one shift) by the same employee so long as the respirator is in satisfactory condition, and use of certain KN95 (Chinese-certified) respirators under certain very narrow conditions:

• The employer attempted unsuccessfully to obtain NIOSH-certified respirators;
• The AQI for PM2.5 is 175 or lower (the Wildfire Smoke regulation (GISO 5141.1 requires provision of N95 respirators when the AQI for PM2.5 exceeds 150);
• The respirator is secured to the user’s head by (infrequently found) head straps, not the more common ear-loops; and,
• The respirator provides minimum 95% filtration efficiency as found by NIOSH testing.

The agency also provided a List of Vendors who Report Available Supplies of N95 Disposable Respirators who indicate to the agency they can supply at least 100,000 NIOSH-certified N95 respirators.  The guidance also indicates that respirators may be available through local Medical Health Operational Area Coordination (MHOAC) programs.  The vendors on the OSHA-supplied list indicate availability of N95s as of this writing; prices vary from $4.50 to $9/respirator.  One vendor provides re-useable respirators meeting the N95 standard for $80/respirator.

N95 respirators have also been provided from the California Office of Emergency Services stockpiles to local County Agricultural Commissioners (CACs) through the offices of the California Department of Food and Agriculture (CDFA), though some of those respirators were recently recalled because they were not NIOSH-certified.

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