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OSHA 1910.269 Revised Ruling: Download Tyndale’s Frequently Asked Questions

Please be advised that OSHA’s final rule for 29 CFR 1910.269 and 1926 Subpart V – Federal standards governing employee safety in activities related to the construction and repair of electrical power generation, transmission, and distribution equipment – has officially been issued and will be published to the national register on Friday, April 11.

The Final Federal Rule incorporates important changes with regard to FR clothing that have significant impact for employers, who must comply by April 1, 2015.

The ruling contains a great deal of information. To help you understand its impact and properly protect your employees, Tyndale faqhas prepared a quick-reference guide. The guide discusses key aspects of the update as it applies to FR clothing and addresses Frequently Asked Questions (FAQ).

Complete the form below to receive your complimentary PDF copy of Tyndale’s FAQ, which answers important questions:

Does the revised 1910.269 require FR clothing to be worn by employees?

Are employees required to wear FR pants as part of the revised standard?

Is FR Clothing required by this standard considered PPE?

Recognizing that FR will be PPE, is an allowance FR clothing program acceptable under this Final Rule?

Is Home Laundering of FR Clothing allowed under the new Final Rule?

What are the employer’s responsibilities for care and maintenance of FR clothing under the new rule?

What are the requirements for head protection?

What are the requirements for hand protection?

What are the requirements for feet protection?

How much will these changes to 1910.269 cost my employer?

When does the FR Clothing portion of the Final Rule take effect?

 

Request your PDF copy of this FAQ:

Additional Resources:

How to Evaluate the Experience and Expertise of an FRC Clothing Supplier

This is the first post in a series looking at Keys to Selecting an FRC Clothing Supplier. Click here to read the series introduction.

Tyndale on FRC Suppliers' Experience & ExpertiseThe flame resistant clothing industry has experienced rapid growth and increased demand over the past decade. Along with an expanding marketplace come new entrants selling the clothing you will invest in to protect your workers. But how do you know who to trust? You understand that flame resistant clothing equals safety for your workforce. What you may not know is that the knowledge and experience of your FRC clothing supplier can also affect the effectiveness of your clothing program. The majority of knowledge and expertise a supplier has is quite simply gained just from their experience in the flame resistant clothing industry.

While OSHA, NFPA, ASTM and other industry organizations set the regulations for what you need to protect against, FRC suppliers can guide you through the options of apparel and protective clothing to help you meet such industry requirements. The right supplier will be able to help you understand the best products for your specific hazard and to meet your protective needs and budgetary requirements. In order to do this effectively, the flame resistant clothing industry should be the supplier’s core business.

Ways FRC Suppliers Can Earn Your Trust

Consider the following seven items to help you gauge any FRC supplier’s experience, expertise and/or credibility:

  1.        Tenure in the industry
  • How long has the company been selling FR products and services specifically?
  • Has the company been able to endure the recent economic climate – have they laid off workers or have they closed any of their business centers/operating units?
  • Is the leadership team active in the industry or do any company representatives participate on industry committees?
  1.        Sales representative and program manager dedication to FR
  • What level of experience and knowledge do the individuals have selling you these products?
  • How many years have they been working in the flame resistant clothing industry?
  1.        Current customers
  • Look at the industries their current customers operate in and what types of programs those customers have.
  1.        Reference list
  • It’s impressive to have a long list of customers, but is their reference list equally as long?
  • Any supplier should be able to give you at least three strong references that will expect you to call.
  1.        Programs similar to yours
  • You’ll get the best information from customers that are similar in size to your company, and that have similar protective needs to yours. Ask for such examples as their references.
  1.        Size and scalability
  • Even though you’re in the market for flame resistant clothing, different industries (oil and gas versus electric utilities) can have very different needs from their suppliers. Take a look at the size of the FR clothing supplier: can they service several large accounts at once? Quite frankly, can they handle your business?
  • Consider suppliers that are large enough to ensure consistency and redundancy, but small enough for personalized and flexible service.
  1.        Retention rates
  • Internal: This will help you understand the expected frequency of change in account management assignment (i.e. account management turnover).
  • External: This will help you understand how happy customers are with the supplier as determined by how often the company brings on new customers and loses current customers.

How FRC Suppliers Can Really Stand Out

Site Visits: Some suppliers offer potential customers a visit to their site to take a look at how the company operates and to give you a peek inside their company culture. This is an important item to take advantage of, especially if you are located in close proximity to the supplier, or if you are going back and forth between multiple suppliers. It affords you the opportunity to speak to individuals at the company outside of the sales staff and give you insight into how working with them will be. Plus, you will be able to ascertain from a site visit whether or not that supplier can scale their services and operations to meet the unique demands of your company.

Wear Trials: A comprehensive wear trial will give you and your workers a true picture of how a particular supplier’s products perform while in real situations. It’s a chance for employees involved in the wear trail to give their feedback and it also encourages employee buy-in prior to any contract being signed.

Fittings: On-site fittings bring value that fit kits just can’t compete with. In-person fittings ensure that workers have face-to-face meetings with the supplier, allowing them to resolve any clothing issues personally. Fittings are another opportunity for the supplier to provide support to end-users and give employees guidance during the ordering process.

Do Your Research: Public and private safety organizations are typically reliable sources of background information on FRC suppliers. Additionally, technical assistance should be offered by the FRC supplier from professionals with experience and understanding of the FR standards and testing, the industry as a whole, and end-use applications of various garments their company sells.

Next up, we’ll take a look at How to Evaluate Products and Programs Offered by FRC Clothing Suppliers.

Arc Ratings for FR Clothing: What Is the Difference Between ATPV and Ebt?

A common question in arc flash clothing protection is whether an ATPV value or an Ebt value is better protection for FRC. Let’s start by defining these two values and seeing what each actually means. First, it’s important to understand that the arc rating of a fabric is either an ATPV (Arc Thermal Performance Value) or an Ebt (Energy breakopen threshold).

Arc Thermal Performance Value (ATPV) is “the incident energy on a fabric or material that results in sufficient heat transfer through the fabric or material to cause the onset of a second degree burn based on the Stoll curve. (1)” ATPV indicates the level of protection provided by flame resistant clothing as measured in cal/cm2.

An arc rating (ATPV) means that you have a 50% chance of being burned if exposed to an electric arc with the same number of calories of heat. The fabric will usually not break open unless exposed to energy levels higher than the arc rating.

Ebt is similar to ATPV but is determined when breakopen occurs before the onset of a second degree burn. Energy breakopen threshold (Ebt) is “the average of the five highest incident energy exposure values below the Stoll curve where specimens do not exhibit breakopen. (1)” An arc rating (Ebt) means that the garment will break open if exposed to the same number of calories, but you will not be burned.

All FR fabrics will breakopen if exposed to sufficient energy. If an arc rated fabric is exposed to energies higher than its breakopen value, the potential for direct skin exposure or non-FR inner layer ignition may result in additional injuries. Important factors influencing a protective system’s arc rating (ATPV or Ebt) are the fabric’s weight, construction and fiber make-up. (2)

ATPV vs. Ebt for Arc Ratings 

Tyndale F025T Arc Rating Label

This garment has an Arc Rating (Ebt) 4.7

ATPV and Ebt are both evaluated in the same test, ASTM F1959, but the first one to be reached is the reported arc rating. While both values (ATPV and Ebt) can be reported, only one arc rating is given to fabric. Only the lowest value will be used on the clothing label according to ASTM F1506 specification. To be arc rated in the ASTM F1506 standard, the fabric must pass several tests including wash testing and the vertical flammability test using ASTM D6413.

If an Ebt value is determined and found to be equal or below a determined ATPV value, then the Ebt value is reported as the arc rating and will be noted as “Arc Rating (Ebt)” on the garment label. Ebt fabrics are typically more insulative than they are strong, and generally ATPV fabrics are stronger than they are insulative.

Understanding Arc Ratings and Calories

Now that you understand FR clothing is tested and given an arc rating, you know that the arc rating measures the amount of heat the flame resistant fabric blocks when exposed to electric arc. The arc rating is the number of calories that the garment is expected to “absorb” if exposed to an electric arc. Arc rating is, in essence, the level of protection provided to you, the wearer. (1)

Calorie is the unit of measure of the heat energy of an arc flash and the protective level of FR clothing. The bigger the calorie number, the greater the heat energy level of arc flash and the greater the protective level of the clothing. You will be protected from an electric arc if your clothing has a higher calorie arc rating than the calories of heat generated by the arc.

While it does not matter if the fabric has an Ebt or ATPV value, it is important to pay attention to the calorie level the fabric can support (as expressed in cal/cm2):

Level

Minimum Arc Rating (cal/cm2)

Maximum Arc Rating (cal/cm2)

HRC 0 0.0 0.0
HRC 1 4.0 7.9
HRC 2 8.0 24.9
HRC 3 25.0 39.9
HRC 4 40.0 +

For more on this Hazard Risk Category table, reference NFPA 70E, the Standard for Electrical Safety in the Workplace.

5 Keys to Selecting an FRC Clothing Supplier

Proper protection starts with a flame resistant clothing supplier that has the industry knowledge and experience to provide you the correct quality products. However, what to look for in a FR clothing supplier is based on a number of additional factors, including: price, quality, performance and overall value.

FRC is the last line of defense, and its primary function is to protect workers in the event of accidental exposure. What most companies don’t consider is that FRC does more than protect your employees; it can protect the company as a whole as well. The cost of one serious burn injury can be significant – often exceeding the cost of an entire FR program.

After identifying the hazards your workers face and conducting your hazard assessment, you can review the applicable standards for your hazard to determine the appropriate clothing and level of protection needed. To be effective, a protective clothing program must not only ensure proper selection based on the hazard, but also address cost and care of the garment as well as employee comfort.

What you need to know is that you can rely on your FRC manufacturer, supplier and program manager to do their job while you do yours. In this upcoming series, we will outline five key points you should address when selecting an FRC supplier: Tyndale FRC Supplier Series

1.       Experience and Expertise 

Consider the supplier’s current customers and reference list to gauge their experience, expertise and credibility. What is their retention rate? How big is the supplier – do they have the capacity and capabilities in place to handle new accounts, both small and large? The right supplier will be able to help you understand the best products for your specific hazard to meet your protective needs and budgetary requirements.

2.       Products and Programs Offered 

If your workers need protection, it’s important to know that your budget will be respected and enforced. Understand that products and programs initially perceived as being the “cheapest” or most cost-effective solutions in the short-term can end up being more costly in the long run. What is a supplier’s product mix and do they have the technology to customize programs to meet different companies’ needs? Be sure to consider products that will last and suppliers that are not only flexible, but whose services also save your company time, money and headaches.

3.       Inventory and Manufacturer Relationship

Not all FR is created equal. Do you know where your FR clothing comes from, how it’s manufactured, or how the supplier assures quality? Suppliers should be able to compete in the marketplace by offering a variety of garments that provide different levels of protection, comfort and durability. Additionally, in today’s economy, it’s more important than ever to support companies that are doing their part to keep jobs in America. Diverse companies, such as minority-owned or women-owned businesses, also positively impact on our economy. However, buying Made in USA products or sourcing a diverse supplier doesn’t necessarily equal more cost.

4.       Purchasing Process

Know what terms and conditions you’re agreeing to, as well as length and exclusivity of the contract you are signing. Consider how often your company – and employees – could experience price increases on their FR clothing. A supplier’s quality control and assurance process will ultimately affect your bottom line and impact how frequently your company, and employees, are spending money on new or replacement garments. Select a provider that can get your employees the apparel they need, when they need it, and at a price your company is willing to pay.

5.       Program Administration and Management

Choose a company that has support available and will give you the individualized attention needed to ensure your program runs smoothly. When you have a question or issue, will you deal with an employee you recognize who is also familiar with the details of your program? Know where the supplier’s team is located, including their customer service and account management teams. The supplier you choose should be providing support that allows you to concentrate on larger issues and your professional priorities.

Implementing an FR clothing program can be complex and your employees will trust these products with their lives. With so much that needs to be taken into consideration, we are here to help simplify what to look for and answer some basic questions. Protection afforded by FRC is too great to manage without a good understanding of all of these factors.

Stayed tuned for the first post in this series, How to Evaluate the Expertise and Experience of an FRC Clothing Supplier.

Tyndale Celebrates Women’s History Month

Women have made strides in the working world over the past several decades and the energy industry, and those servicing this sector, is no different. In an industry where men dominate the workforce, the role of women in today’s industrial sector proves that skills and talent are slowly trumping gender. Women’s History Month represents an opportunity to reflect on the progress that women have made.

Quick facts about women in the workplace:

  • 12% of ExxonMobil executives today are women, compared to 9% in 2000
  • The percentage of women executives at BP more than doubled between 2000 and 2007
  • Currently, about 24% of the managers at StatoilHydro are women (1)
  • Tyndale’s workforce as of January 2014 was comprised of 62% women
  • Women account for 25% of PG&E’s workforce but only 8% of entry-level gas and electric field positions (2)
  • Nearly half of all new oil industry jobs during Q1 2013 went to women, in an industry where men still make up nearly 80% of the workforce (3)

A major motivator for recruiting, retaining and developing women in the energy industry is a looming labor shortage expected in the near term. With the age of the average worker in the oil field over 50, 40% of older employees are expected to retire before the end of this decade (4). Energy companies are looking for bright, talented, young people to fill this void – and that means cutting across genders to fill open positions.

Even with the progress women have made in the energy business, many admit it wasn’t easy to get to where they are. The silver lining, if it can be called that, is that many of the challenges women are confronted with are no different than the struggles their male counterparts face. Generally, though, women are still under-represented in important technical fields, and currently only comprise a fraction of the energy industry’s total workforce.

Women-Owned Businesses

It’s important to note that progress of women in the working world varies from country to country and industry to industry. When you look at strides made domestically in the United States, there are several organizations committed to recognizing and furthering the success of women.

One example is the Women’s Business Enterprise National Council (WBENC) which was founded in 1997. WBENC is dedicated to advancing the success of businesses owned, controlled and operated by women in the United States. WBENC provides its members access to contacts, opportunities, markets, solutions and resources, and recognition based on certification.

Tyndale Company CEO, Gail Whittenberger

Tyndale Company CEO, Gail Whittenberger

In 2007, Tyndale became independently certified as a woman-owned business, with Gail Whittenberger rising to become the company’s Chief Executive Officer. Tyndale was independently certified by the Women’s Business Enterprise National Council in April 2011. Suppliers with WBE status deliver an important differentiator for many companies, and Tyndale is proud of this designation.

Women’s History Month exists to help us remember the past so we can acknowledge just how far the female gender has come and how far we still need to go.

Please visit the Library of Congress’ official site to learn more about Women’s History Month. For more information on Tyndale’s story, and what sets us apart from other FR suppliers, please visit the About Us page on www.TyndaleUSA.com.

References for this post were accessed March 2014:

(1) http://www.world-petroleum.org/docs/docs/wpc_women.pdf

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