Cal/OSHA held an advisory meeting this week to discuss potential revisions to California’s Protection from Wildfire Smoke Standard. The meeting provided stakeholders an opportunity to comment on potential regulatory language being developed to implement AB 2243.

During the meeting, worker advocacy organizations urged Cal/OSHA to consider requirements beyond the draft language under discussion, including lowering the PM2.5 AQI threshold from 151 to 101 beyond the proposed respiratory protection for agricultural employees at an AQI of 300 instead of the current threshold of 500. These organizations also suggested expanding the scope of the standard beyond wildfire smoke to include smoke from prescribed burns.

Assistant Vice President Priscilla Rodriguez testified in opposition to these changes and questioned whether sufficient occupational exposure data has been provided to justify the substantially lower thresholds or for expanding a regulation specifically developed to address wildfire smoke to other sources. Rodriguez stated. “We have significant concerns with lowering the Air Quality Index (AQI) threshold from 151 to 101 without clear occupational data demonstrating that this significant expansion is necessary.” Rodriguez also questioned the justification for treating agricultural workers differently from other outdoor employees. “Agriculture is not the only industry with employees performing work outdoors,” Rodriguez said. “If Cal/OSHA believes agricultural workers face a unique risk requiring a substantially lower threshold, it should provide the data demonstrating that difference.”

The Associations stressed that these changes could significantly increase compliance obligations and costs for agricultural employers and urged Cal/OSHA not to adopt lower thresholds or include burns beyond the scope without sufficient scientific and occupational evidence.

Cal/OSHA will consider written and verbal stakeholder comments as it evaluates potential revisions to the standard. Another advisory meeting is expected to be scheduled to continue the discussion.