The new wildfire smoke rule from L&I is already in full effect, and farm managers are scrambling to comply. After multiple meetings with Washington L&I/DOSH and consultation with Washington Farm Bureau, we've summarized the most important parts of the rule: communication, training, responding to sick workers, exposure controls, and respiratory protection. We'll cover what you as an employer must do, and how Harvust farm safety software can make that easy and ensure compliance.
Communication
You must:
- Monitor employees' exposure to PM2.5/poor air quality before and periodically throughout the shifts.
- Alert employees when air quality conditions are unhealthy (AQI 151 or higher).
- Inform employees of available protective measures against wildfire smoke.
How Harvust Helps
Harvust now comes with a set of built-in features that will provide you with nearly 100% automated compliance with this rule. While you and your employees are focused on your work, Harvust will constantly monitor the PM2.5/AQI at every one of your farm locations. If dangerous levels are present, Harvust will send automated text message alerts (audio-translated, Spanish/English) to all of your employees. These alerts will also contain information on protective measures available to your employees. In addition, Harvust will alert your managers that they need to verbally follow up with the handful of employees who aren't connected to Harvust through a phone. Finally, Harvust creates records of all of these alerts automatically, so you have documentation to give to an L&I inspector.
You must:
- Encourage employees to inform their employer of worsening air quality or if they start feeling sick from the smoke.
How Harvust Helps
Good workplace communication is a two-way street. Using Harvust, you can facilitate two-way conversations with your employees that come with built-in translations. For example, every alert will encourage your employees to report worsening air quality to their supervisors. Or they can just reply to the alert message straight from their phone, and your managers will receive their reports immediately.
You must:
- Include wildfire smoke in the written accident prevention program.
Your Accident Prevention Program (APP) can be the difference between a small fine violation and a large one. Adding the new wildfire smoke hazard to it is critical. Here is a link to an APP addendum template provided by L&I.
Training
You must:
- Provide all workers effective information and training regarding wildfire smoke before work that exposes the worker to smoke, and at least annually thereafter.
How Harvust Helps
Harvust makes it extremely easy to send or schedule a wildfire smoke training to be sent directly to your employees’ smartphones. Harvust trainings include English and Spanish translations in both written and audio formats and automatic records. Harvust has a Washington compliant “WA Wildfire Smoke Safety” training ready for you to use. While the emergency rule does not explicitly require record-keeping, L&I has said that records of training will likely be asked for during an inspection. The more evidence on your side, the better!
You must:
- Train supervisors on emergency procedures
Your managers are required to have additional training. It needs to cover what they should do if they notice an employee exhibiting signs of wildfire smoke exposure and procedures for transporting the sick employee to medical care. Going forward, we recommend training annually at the same time you train on heat illness.
Responding to sick workers
You must:
- Keep an eye on employees who show wildfire smoke exposure symptoms, and make sure you have a plan in place if they need immediate medical care.
- You must allow employees who show signs of injury or illness due to wildfire smoke exposure to seek medical treatment, and you can not retaliate against affected employees for seeking such treatment.
L&I has told us that this can’t just be words. You need to make sure that managers and crew bosses are not punishing workers who get sick, such as assigning them to a “slow” crew, etc.
Exposure controls
You must:
- Have ways you can reduce the amount of smoke an employee is exposed to.
This may mean trying to move work to a location where the air is cleaner, modifying work schedules, reducing work intensity, or providing more rest breaks. You are encouraged to take these actions at AQI 69, but you are not required to until AQI 151 or higher.
Respiratory protection
You must:
- Provide adequate respirators to workers at AQI 151 or higher.
The new rule encourages you to provide them at AQI 69, but you are not required to provide them until the AQI is 151 or higher. Even at that level, workers are not required to wear them. Respirator/mask use is 100% voluntary. Remember that only N95 (or KN95 for 2021) masks provide protection against wildfire smoke. The Washington Farm Bureau has masks available for free. If a worker’s respirator is dirty or damaged make sure they can get a fresh one from you or a supervisor.
How Harvust Helps
As part of the training, you must teach employees how to wear a respirator properly, test whether it leaks, and when to get a new one. Our “WA Wildfire Smoke Safety” training covers all of these topics.
Conclusion
Without Harvust, you’d have to spend a lot of time refreshing websites checking for air quality, putting up posters or other signs that employees may or may not read, and trying to communicate through the phone-tree of your managers. Complying with this new rule is hard, but with Harvust the worst of these pains go away. Training and communicating with your employees, and keeping records of everything, is just a click away.
Contact us today to get your farm up and running with simple, fast, and easy Washington wildfire smoke compliance!
