September 30, 2022

Over the past few years, Oregon and Multnomah County have experienced unprecedented heat and wildfire events. In response, Oregon Occupational Safety and Health (OSHA) created temporary rules to protect employees from heat-related illnesses and wildfire smoke. On May 9, 2022, Oregon OSHA adopted permanent rule OAR 437-002-156, Heat Illness Prevention with an effective date of June 15, 2022. Then, on May 10, 2022, Oregon OSHA adopted permanent rule OAR 437-002-1081, Protection from Wildfire Smoke with an effective date of July 1, 2022.

Chief Operating Officer Serena Cruz and Interim Chief Human Resources Officer Shelly Kent sent early communications about these rules to employees and managers with a particular focus on the training requirements. In order to help keep employee safety top of mind, we are following up with this article to share this information again.

Smoke fills the sky during the September 2020 smoke event
Risk Management provides Oregon OSHA compliance support for all departments and offices. Please contact Risk Management at to request any support needed concerning these rules (i.e. written plans, monitoring, communication, training, etc.) or anything else.

A brief summary of the Heat Illness Prevention rule

Among other things, the Health Illness Prevention rule addresses health concerns including dehydration, heat exhaustion and heat stroke. The rule requires plans and actions to be developed and implemented to protect employees working indoors or outdoors when the heat index or apparent temperature reaches or exceeds 80 degrees.

Some of the main employer requirements include:

  • Provide enough water so employees can consume 32 ounces/per hour
  • Provide access to shade (covered areas, trees, etc.)
  • Ensure training is provided and completed annually (provided in Workday Learning as “Heat Stress Illness Prevention”)
  • Develop “High Heat Practices,” when temperatures meet or exceed 90 degrees
  • Develop and implement a written Heat Illness Prevention Plan with specific information regarding required rest break plans, acclimatization plans and emergency medical plans.

More information can be found here: Oregon OSHA Heat StressOregon Health Authority Extreme Heat

A brief summary of the Protection from Wildfire Smoke rule

The Protection from Wildfire Smoke rule’s main purpose is to help employers protect their employees from adverse health effects caused by exposure to wildfire smoke when the air quality index (AQI) is at 101 or higher for particulate matter (PM2.5). Wildfire smoke, even at lower AQI levels, can cause coughing, eye irritation, a runny nose and trouble breathing, especially for people with underlying conditions such as asthma. These adverse health effects could also lead to reduced lung function and even heart attacks. 

The rule does provide some exemptions for the following locations or settings:

  • Working in an enclosed building with a filtering mechanical ventilation system (HVAC)
  • An enclosed vehicle with a functional air cabin filtering system (windows closed)
  • Jobs where its predetermined that operations/work will end because of an AQI of 101 or higher
  • Working from home (teleworking)

Some of the main rule requirements include:

  • Exposure monitoring (use the Oregon DEQ website, or another as outlined in rule) at each work location once the AQI meets or exceeds 101
  • Ensure employee training is provided and completed annually (provided in Workday Learning as “Wildfire Smoke Exposure and Control Protection”) 
  • Implement a two-way communication system for sharing smoke exposure control information (requires supervisors/manager to monitor AQI and communicate and adjust safety controls as needed, along with allowing employees to report health symptoms and issues regarding access to exposure controls)
  • Implement engineering and administrative controls 
  • When to use employer-provided NIOSH-approved filtering facepiece respirators, based on the AQI levels, that are appropriate for wildfire smoke protection. Respirators approved include N95, N99, N100, R95, R99, R100, P95, P99, and P100. (Multco Marketplace)

More information can be found at Oregon OSHA Wildfire Smoke or Oregon Health Authority Fact Sheet

As a reminder, if you have any questions or concerns regarding these rules, or any other risk- or safety-related topic, contact Risk Management at