Worker Safety and Health During Fire Cleanup

Cal/OSHA is charged with protecting workers on the frontlines of disaster recovery, ensuring their safety and health as they work to restore what has been lost. All workers have a right to a safe and healthful workplace, including work done at fire cleanup sites. Whether it's a single structure fire or a large-scale disaster like the recent Southern California fires, Cal/OSHA enforces safety and health standards that protect workers during and after a fire occurs.

Workers face multiple hazards during fire cleanup, removal, and demolition work. Employers doing this work are required to identify, evaluate, and control these hazards in addition to providing training and personal protective equipment (PPE) to employees (California Code of Regulations, Title 8, sections  1509151115183203,  and 5192).

Existing Cal/OSHA standards do not cover "household domestic service," such as cooking, cleaning, and childcare performed for a family. However, fire cleanup work, including ash, soot, and debris removal and cleaning of fire-damaged structures, is not household domestic service. Employees performing this work are covered by Cal/OSHA health and safety standards, and their employers must ensure their safety and health, including providing the proper protective equipment.

In addition, even if a worker usually performs household domestic service work, they are covered by Cal/OSHA safety standards when performing all other types of work, such as fire cleanup, removal, demolition, and reconstruction work. All employers whose employees are engaged in such work should consult the resources in this document and must comply with Cal/OSHA standards to protect the safety and health of their employees.

In addition to workplace safety and health, the following protections apply to all employees, including those engaged in household domestic service:

  • Workers that are employees under California law are protected by Cal/OSHA standards, even if their employers treat them as independent contractors.
  • Workers are protected regardless of their immigration status.
  • It is unlawful to direct an employee to enter or remain in an area subject to a mandatory evacuation (Labor Code section 6311.5).
  • Employees have the right to leave or refuse to report to work in a disaster area if they believe it is unsafe. It is unlawful for an employer to take action against an employee for refusing to work in such situations. This does not apply to first responders or certain other emergency services workers. (Labor Code section 1139).

Fire and Fire Byproducts

Burning material can continue to be a hazard during cleanup of fire-damaged areas. Heat sources from smoldering debris can come into contact with flammable material and ignite.. Employers must provide fire extinguishers, first-aid kits, and eye wash materials at every cleanup site (sections 1922 and 1512).

In addition, toxic, flammable, or asphyxiating gases or vapors from fires may persist indoors, in enclosed spaces, and under debris. See Respiratory Protection During Fire Cleanup Operations for further information.

Electricity

After an outage, electrical deaths and injuries can occur as power lines are reenergized and electrical equipment is turned on.

  • Employers must only allow qualified electrical workers, as defined in section 2700, to work on or near power lines and restore electrical power.
  • No worker is allowed to work near downed power lines except qualified electrical workers authorized by the utility and only after the utility has confirmed all lines are de-energized.
  • Employers must only allow qualified line clearance tree trimmers, as defined in section 2700, to conduct tree trimming operations in the vicinity of energized power lines (sections 2950–2951).
  • Other workers must not be allowed to perform any function in proximity to energized high-voltage lines (section 2946).
  • Overhead power lines must be considered energized until the utility company verifies that the lines are not energized, and the lines are visibly grounded at the work site (section 2946).

If water is or has been near electrical circuits or electrical equipment, employers must ensure that the following precautions are taken:

  • Turn off power at the main breaker or fuse of the service panel for the building.
  • Do not turn power on or use electrical equipment until electrical circuits and equipment are inspected by a qualified person, as defined in section 2300 and section 2700.
  • Do not use electrical equipment or circuits that have been exposed to heat from fire until inspected by a qualified person, as defined in section 2300 and section 2700.
  • Unless all electrical power is off, never enter flooded areas or areas with standing water.
  • Do not touch electrical equipment if wet or if the ground or surface is wet.

If generators are used at a cleanup site, employers must ensure they comply with the following requirements:

  • Generators should be properly grounded, except for portable and vehicle-mounted generators under certain circumstances, provided certain other safety measures are taken(sections 2395.1-2395.114. Exceptions and alternative safety measures are provided in section 2395.6).
  • 120-volt, alternating current, single-phase, 15-ampere and 20-ampere receptacle outlets on construction sites that are not a part of the permanent wiring of the building or structure must have approved ground-fault circuit interrupters (GFCIs) to protect employees (section 2405.4, subsection (c)). Otherwise, the employer must implement an assured equipment grounding conductor program (section 2405.4, subsection (d)).
  • No electrical power source, including a generator, is allowed to be connected to a premises' wiring system, or parts of such a system, unless positive means are used to prevent the transmission of electricity beyond the premises' wiring system or beyond any intentionally segregated parts of the wiring system. Steps to ensure that electricity is not transmitted beyond the premises wiring system include switching the main power breaker or fuse to the "off" position; however, this may not be sufficient in all cases (section 2320.9).
    • Once switched off, employers must lock out or tag out the main power breaker or fuse to ensure they are not inadvertently turned on (section 2320.4).
    • Contact the utility provider before connecting a generator to a premises' wiring system.
  • See additional information from PG&E on generator safety:

(See sections 2320.1–2320.10, 2340.1, 2380.1 and 2485.2)

Flammable Gases

Employers must ensure that pipes and tanks containing flammable gases, if potentially damaged or leaking, are properly shut off (subsection (c) of section 3329 and subsection (a) of section 5416). See additional information from the Pacific Gas and Electric Company (PG&E).

Unstable Structures

Never assume that fire-damaged structures or buildings are stable. They may be structurally damaged or weakened and can collapse without warning. Employers must ensure that precautions, such as the following, are taken:

  • Do not allow work to be performed in or around any fire-damaged structure until it has been examined and certified as safe by a registered professional engineer or other qualified person.
  • Assume that all stairs, elevated floors, and roofs are dangerous until inspected and verified as safe.
  • Establish procedures and provide training to ensure that employees leave the structure immediately if it shifts, if there are unusual noises, or other signs of impending collapse.

(Sections 3203 and 3241).

Note: Even after a building or structure is determined to be safe, employees working in or around these structures may be exposed to falling objects. Employers must therefore provide and ensure that employees wear hardhats or helmets, safety glasses, gloves and adequate foot protection such as steel-toed boots (sections 3380–3385).

Demolition

During demolition or dismantling of damaged buildings, structures, and equipment, there is an increased risk of hazards such as unexpected collapse, falling objects, exposed utilities, and hazardous chemicals and fuels. Before commencing work, employers must review all demolition safety requirements in sections 1733 –1737. Requirements include the following:

  • A qualified person must conduct a written survey of the structure to determine the condition of the structural components and the possibility of an unplanned collapse of any portion of the structure and adjacent structures (section 1734).
  • Employers must determine if any type of hazardous chemicals, gases, explosives, flammable materials, or other dangerous substances have been used in any pipes, tanks, or other equipment on the property. These hazards must be eliminated before demolition is started (section 1735).
  • Demolition work must be performed under the immediate supervision of a qualified person with the authority to ensure the safety of employees (section 1734).
  • Utility companies must be notified and all utility services shut-off or otherwise controlled before starting demolition, unless electricity or water is needed for demolition. In these cases, the utility services must be relocated or rearranged as necessary and protected from damage (section 1735).

Sharp or Flying Objects

Employees handling, cutting or breaking up debris may be exposed to sharp objects, flying objects and other cutting hazards. Employers must therefore provide and ensure that employees wear appropriate eye, hand and foot protection (sections 3380, 3382, 3384 and 3385). See guidance on Personal Protective Equipment During Fire Cleanup Operations.

Excavations

Digging with an excavator or other equipment presents the risk of striking and damaging underground installations such as natural gas, electric, sewer, and communication lines. Damage to underground installations may cause fire, explosion, electric shock, or release of toxic materials.

Employees entering an excavation may be injured or killed due to cave-ins, falling materials, or falling equipment.

Identifying underground installations before excavating

  • Before starting excavation work, the approximate locations of all underground installations that may be encountered during excavation operations must be determined (section 1541 and Government Code section 4216.4).
  • An excavator planning to conduct excavation work must notify the following entities of the excavator's intent to dig at least two working days before starting an excavation: (1) the appropriate regional notification center, and (2) all known owners of underground installations in the area who are not members of a notification center.
    • Before notifying the appropriate regional notification center, the excavation areas must be marked as specified in Government Code section 4216.2 (section 1541).
    • For northern California, the regional notification center is Underground Service Alert North 811. Website: http://usanorth811.org/. Phone: 811
    • For southern California, the regional notification center is Underground Service Alert of Southern California. Website: http://www.digalert.org/. Phone: 811
  • After notifying the regional notification center and prior to beginning excavation work, the excavator must receive positive responses from all known owners/operators of underground installations confirming the locations of underground installations or confirming the owner/operator does not operate an underground installation that would be affected by the proposed excavation (section 1541).
  • After the approximate locations of underground installations are determined and excavation work begins, the exact location of underground installations must be determined by safe and acceptable means (such as digging with hand tools), when approaching the approximate location of an underground installation (section 1541 and Government Code section 4216.4).
  • All employees exposed to excavation hazards during excavation work must be trained in the notification requirements and excavation practices provided in section 1541 and Government Code sections 4216 through 4216.9 (section 1541).
  • Any damage to underground installations discovered or caused during excavation work must be reported to the facility owner/operator or regional notification center (section 1541).

Protecting employees entering excavations

  • A permit from Cal/OSHA must be obtained before the construction of excavations 5 feet or deeper into which any person is required to descend (section 341).
  • Adequate protective systems must be used to protect employees entering excavations 5 feet or greater in depth, and where a potential for cave-in exists (section 1541.1).
  • A stairway, ladder, ramp or other safe means of egress must be provided for excavations that are 4 feet or more in depth (section 1541).
  • Employees must not be allowed to work in excavations where there is accumulated water, unless adequate precautions have been taken to protect employees (section 1541).
  • Support systems must be installed to ensure the stability of structures adjacent to or adjoined to excavations (section 1541).
  • Adequate protection must be used to protect employees from loose rock or soil that could fall or roll from an excavation face (section 1541).
  • Materials and equipment must be kept at least 2 feet from the edge of excavations, or retaining devices must be used to keep materials from falling into excavations, or a combination of both if necessary (section 1541).
  • Inspections of excavations, the adjacent areas, and protective systems must be done by a competent person each day and as needed during each shift for indications of possible cave-ins, failure of protective systems, hazardous atmospheres, or other hazardous conditions (section 1541).

See Article 6 of the Construction Safety Orders for a complete listing of title 8 requirements for excavation activities.

Tree Work

Tree work includes trimming, pruning, felling, and removal of trees and bushes. Tree workers climb trees, use portable ladders, work at heights while using hand and portable power tools, work near energized overhead or downed power lines, feed chippers, and perform other hazardous operations. Employers engaged in tree work during wildfire cleanup must ensure it is done safely and in compliance with Cal/OSHA's tree work regulations.

Review Cal/OSHA's Tree Work Safety web page for more information on ensuring tree work safety, such as developing a comprehensive health and safety program that includes written safety rules and safe work procedures for all tasks performed by tree workers, and providing proper protective equipment and training.

Haulage Vehicles

Haulage vehicles used during wildfire cleanup present hazards to pedestrians, nearby workers, and operators if not used or maintained properly. Employers should ensure that all machinery and equipment used for haulage are:

  • Designed to safely sustain all reasonably anticipated loads,
  • Used in accordance with the manufacturer's recommendations, and
  • Inspected daily and maintained as recommended by the manufacturer.

Haulage vehicle and earthmoving equipment operations must comply with Cal/OSHA's haulage and earthmoving regulations in general industry, haulage and earthmoving regulations in construction, and machinery and equipment regulations.

Carbon Monoxide Poisoning

Gasoline or diesel-powered pumps, generators, pressure washers, and other equipment may be used during cleanup. When in use, these machines generate carbon monoxide gas, which is colorless, odorless, tasteless and potentially lethal. It is nearly impossible to tell whether ventilation is sufficient to prevent excessive carbon monoxide buildup (section 5155) without using personal carbon monoxide monitors. Therefore, in most situations, employers must not use gasoline or diesel-powered equipment indoors (sections 3662, 5141 and 5146).

Ash, Char, Soot, Smoke Particles, and Debris

Residential, commercial, and industrial structures, vehicles, equipment, and synthetic materials release or break down into hazardous substances when burned. These materials include plastics, synthetic fabrics and textiles, furniture, home décor, petroleum products (such as asphalt shingles), treated wood, adhesives, and metals. Residences and business also contain items that are composed of hazardous substances or that become hazardous when burned, such as electronics, appliances, batteries, household chemicals, paints, and pesticides. After a fire, the remaining ash, char, soot, debris, and underlying soil will be contaminated with many hazardous substances. The dangers may not be obvious, because contaminated materials may look the same as uncontaminated material.

Some of the hazardous substances that can harm workers through inhalation, ingestion, or skin contact include:

  • Arsenic is a known human carcinogen that can also cause nausea and vomiting, and damage to the heart, blood vessels, nerves and skin.
  • Cadmium is a known human carcinogen that can also damage the lungs and bones.
  • Lead damages almost every organ and system in the body, particularly the brain and kidneys, and can damage or cause the loss of an unborn infant. Lead exposure also causes high blood pressure.
  • Manganese can damage the nervous system and cause changes in behavior and cause Parkinson’s-like symptoms, including slowness of movement, stiffness, and tremors.
  • Mercury can damage the central nervous system (including brain damage), kidneys, liver, and lungs.
  • Nickel can damage the skin and lungs and cause lung and nasal cancer.
  • Zinc can damage the skin.
  • Polycyclic aromatic hydrocarbons (PAHs) are carcinogenic and can damage the immune system and skin. .
  • Polychlorinated biphenyls (PCBs) are carcinogenic and can damage the liver and skin.
  • Polybrominated biphenyls (PBBs) may be carcinogenic and can damage the skin.
  • Dioxins and furans are carcinogenic, can damage an unborn infant, and can damage the liver, reproductive system, immune system, and disrupt hormones.

These hazardous substances endanger workers when they:

  • Are breathed in and inhaled when dust is created during cleanup, demolition, and removal activities
  • Come into contact and damage skin, eyes, and hair, and be absorbed into the body
  • Are accidentally ingested from contaminated hands, face, and facial hair
  • Contaminate workers’ clothes and vehicles, and are brought home, where they endanger workers’ families.

To protect against breathing in and inhaling hazardous substances, employers must implement the following:

  • Use feasible engineering controls to ventilate and provide filtered air to indoor work areas (section 5141).
  • Use a high-efficiency particulate air (HEPA) vacuum when cleaning ash, soot and dust (section 5141).
  • Provide and ensure proper use of the following respiratory protective equipment:
    • Elastomeric air-purifying respirator (APR) equipped with high-efficiency air (HEPA) filters combined with an organic vapor (OV) and formaldehyde cartridge. A P100, N100, or R100 filter can be used instead of a HEPA filter. N95 respirators can be used in place or elastomeric APRs for the following:
      • In areas where only vegetation or untreated wood have burned, or
      • Inside homes with no fire damage, but where light cleaning is needed for smoke odors or dust as a result of adjacent fires.
    • All respiratory equipment, filters, and cartridges must be NIOSH approved
    • The employer must have a written respiratory protection program that includes fit testing, medical evaluations, and procedures for cleaning and maintaining respirators. Please see Respiratory Protection During Fire Cleanup Operation for further information.

To protect against skin, eye, and hair contact with hazardous substances, employers must provide and ensure proper use of the following personal protective equipment (PPE):

  • Full body Tyvek or equally effective coveralls with head covering
  • Safety glasses or goggles
  • Cut- and chemical-resistant gloves
  • Shoe covers
  • PPE must be made of materials such that hazardous substances cannot pass through the PPE and reach the employee's clothes, skin, or hair (sections 3380 and 5192))

Employers must train workers on, and ensure proper use of PPE (sections 3380 and 5192). Employers must ensure PPE is kept in a safe and sanitary condition (sections 3380 and 5192). Please see Personal Protective Equipment During Fire Cleanup for further information.

If employees are cleaning an undamaged structure that is affected only by smoke, employers must provide at least N95 respirators, and must replace them regularly. Employees may also choose to wear a more protective respirator voluntarily under these conditions if they prefer, such as the APR described above.

To protect against accidentally ingesting hazardous substances and to avoid contaminating private vehicles and residences with hazardous substances, employers must ensure the following steps are followed before employees eat, drink, or smoke, and before breaks or leaving the worksite:

  • Remove personal protective equipment
  • Wash hands and face thoroughly with soap and water

Employers must make washing facilities with soap and water accessible to all employees (sections 1527, 3366, 5192). Workers must remove PPE before leaving the worksite and should shower and change clothing and shoes immediately upon arriving home.

If necessary to prevent heat illness (see below), employers must provide potable drinking water to employees and must implement, provide training on, and ensure compliance with written safe drinking procedures. The employer must ensure employees follow these procedures and are able to drink water in a manner that prevents ingestion of hazardous substances.

Asbestos

Insulation, flooring, roofing materials, appliances, and furnishings in fire-damaged structures may contain asbestos, which can damage the lungs and cause cancer. Since asbestos does not burn, it becomes concentrated in the ash and debris when a structure burns. Respiratory protection and engineering controls are required for asbestos work. At a minimum, elastomeric respirators with HEPA filters must be used. N95 respirators are insufficient for protection against asbestos and are not allowed. For further information and requirements, please see Cal/OSHA's Asbestos Information page and section 1529.

Hazardous Liquids

Fires in commercial and residential buildings and water used to fight fires can damage or dislodge tanks, drums, pipes and equipment that may contain hazardous liquids. Any cleanup of hazardous spills must be performed only by employees who have the required skills, knowledge and training (subsection (q) of section 5192). Employers must provide these employees with the proper personal protective equipment (PPE) and equipment to perform the work (subsection (q) of section 5192). Employers must ensure that damaged or dislodged equipment containing hazardous liquids is not moved or altered without first obtaining authorization from a government agency.

Heat Illness

Employers must protect workers from heat illness in both indoor and outdoor workplaces under sections 3395 and 3396. For employees working outdoors, employers must provide potable drinking water, appropriate rest breaks and access to shade to prevent heat illness (section 3395). For employees working indoors when the indoor temperature is over 82 degrees, employers must provide potable drinking water, appropriate rest breaks, access to cool down areas, and must implement other control measures to reduce heat illness risks. For more information, see Cal/OSHA'’'s Heat Illness Prevention page.

Confined Spaces

A confined space is a space that has limited means for entry and exit and is not designed for continuous employee occupancy. Examples include manholes, crawl spaces, pits, tanks and silos. Employees working in confined spaces can face life-threatening hazards such as toxic exposures, asphyxiation, electrocution and unguarded moving machinery. Employers must evaluate worksites to determine if there are confined spaces, and must implement protections to ensure the safety of employees who enter confined spaces. These requirements include, but are not limited to:

  • Procedures to identify confined spaces that may contain hazards
  • Procedures to ensure unauthorized persons do not enter these spaces
  • A written confined space program if employees will enter these spaces that includes a confined space entry permit system
  • Identification and evaluation of all potential hazards that may exist before workers enter a space, as well as those that may develop as a result of work activities
  • A plan to eliminate or control all identified hazards
  • Continuous monitoring of atmospheric and other hazards
  • A training program for all workers who will enter a confined space or who will serve as an attendant to protect authorized entrants
  • An emergency access and rescue plan with trained personnel and equipment immediately available on site in the event an emergency occurs inside a confined space

(Sections 1950-1962 and 5156-5158)

Additional Information

Fire Cleanup Hazards and Safety Precautions

Wildfire Cleanup Training Tools in English and Spanish

April 2025