8/7/26 Oregon OSHA Heat Illness Prevention and Wildfire Smoke Requirements Refresher

August 7, 2026

As temperatures rise and wildfire season intensifies across Oregon, employers should review their workplace safety practices to ensure compliance with the Oregon Occupational Safety and Health Administration (“OR-OSHA”) heat illness prevention and wildfire smoke standards. These rules are intended to protect employees working in hazardous conditions and impose protection obligations on employers.

Heat Illness Prevention

OR-OSHA’s heat illness prevention standard, Or. Admin. Code § 437-002-0156, generally applies when the heat index reaches 80 degrees Fahrenheit or higher. Employers should ensure they have the following measures immediately and readily available for all exposed employees.

Access to Shade

Employees must have access to at least one adequately shaded area. If shade is not safe or feasible, employers must provide alternative cooling measures that offer equivalent protection.

Drinking Water

Employees must have access to free, cool or cold drinking water, and adequate opportunities to hydrate throughout their shifts. Caffeine-free electrolyte drinks may supplement, but not replace, the employer’s water requirements.

High-Heat Practices

When employee exposure cannot be reduced below a heat index of 90 degrees Fahrenheit, employers must implement additional protective measures, including enhanced employee symptom monitoring, communicating with employees in a language and manner they can understand, emergency medical service response protocols, and a written heat illness prevention rest-break schedule. The rest breaks may coincide with required meal or rest periods, as long as employees are relieved of all duties. 

Emergency Medical Plan

Employers must maintain an emergency medical plan addressing excessive heat hazards specific to their workplace and industry.

Acclimatization Plan

Employers must implement a written acclimatization plan to help employees safely adjust to working in hot conditions. Employers may develop their own plan or adopt the model plan developed by the Centers for Disease Control and Prevention and the National Institute for Occupational Safety and Health.

Training

Employers must provide annual heat illness prevention training to applicable employees and maintain records documenting all completed trainings.

Certain industries and employees are exempt from portions, or all, of the heat illness standards, so employers should review all applicable laws to ensure they remain compliant with industry requirements.  

Protection from Wildfire Smoke

OR-OSHA’s wildfire smoke standard generally applies when employees are exposed, or are reasonably expected to be exposed, to an Air Quality Index (“AQI”) of 101 or higher due primarily to wildfire smoke.

Monitoring

Employers must monitor employee exposure to wildfire smoke before each shift, and as needed throughout the workday.

Training

Employers should provide all applicable employees with annual training that addresses the health effects and symptoms of wildfire smoke exposure, methods for monitoring AQI conditions, and other information required by OR-OSHA.

Exposure Controls

Employers must use feasible measures to reduce employee exposure to potentially dangerous fine particulate matter, which may include relocating outdoor employees, modifying work practices, or providing respirators when needed.

Employers are required to implement a wildfire smoke assessment when employees are or are likely to be exposed to an AQI of 101 or above. 

As with the heat illness standard, certain employees and industries, including remote employees, may be exempt from some or all wildfire smoke protection requirements.

Employer Takeaways

As Oregon enters the height of wildfire season and hottest part of the year, employers should take proactive steps to ensure compliance with OR-OSHA’s standards. Employers should:

• Review and update their heat illness and wildfire smoke policies;

• Confirm that all required trainings have been completed and documented;

• Ensure emergency response procedures are current; and

• Monitor weather forecasts and local air quality conditions before and during each workday.

Please contact Abby Fitts at 503-276-2190 or afitts@barran.com or Winslow Robinson at 503-276-2103 or wrobinson@barran.com with any questions or for assistance in determining your employment compliance.