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Posts tagged ‘personal protective equipment (PPE)’

What Is the Difference Between Arc-Rated Clothing and FR Clothing?

Understanding all of the acronyms for clothing and standards in the electric industry can make your head spin. One common question we get is: what is the difference between arc-rated and flame resistant clothing – if there is any difference at all?

FR stands for “flame resistant clothing,” specifically. An easy way to think about the difference between arc-rated clothing and FR clothing is that all arc-rated clothing is FR but not all FR has an arc rating. Confusing, we know. Let’s look at the two in more detail below.

One primary requirement for both arc-rated and FR clothing is to resist ignition, as tested by ASTM D6413, or the Vertical Flame Test. The second requirement for arc-rated clothing, specifically, is to insulate the wearer from arc flash hazards, thus reducing or eliminating any 2nd or 3rd degree burns through the garment. This is where a garment’s arc rating is important.

The term arc-rated was first introduced in the 2012 version of NFPA 70E. Informational Note No. 1 on page 12 of the standard explains, “Arc-rated clothing or equipment indicates that it has been tested for exposure to an electric arc. Flame-Resistant (FR) clothing without an arc rating has not been tested for exposure to an electric arc.” Due to the misuse of the term “FR,” NFPA 70E removed the term favoring arc-rated.

ASTM 1959 is the official arc rating test standard, and requires fabrics to be FR in order to even qualify for testing. The purpose of the ASTM 1959 test is to determine how much heat a certain fabric (or system of fabrics) will block from an electric arc before the onset of second degree burns to the wearer. This is the reason why all arc-rated clothing is FR.

OSHA 1910.269 Update: Arc-Rated vs. FR Clothing Requirements

One of the goals of OSHA, in its update, is to require protection from arc flash hazards – going beyond the legacy of 1910.269’s “do no additional harm” requirement.

FR Clothing: In the new standard 1910.269, OSHA does not define FR. However, OSHA does specify that clothing must be “non-melting.” OSHA prohibits the use of clothing made from acetate, nylon, polyester, rayon, and polypropylene, either alone or in blends, unless the employer demonstrates that the fabric has been treated to withstand the conditions that may be encountered by the employee or that the employee wears the clothing in such a manner as to eliminate the hazard involved (1).

As part of the revised OSHA standard becoming law on July 10th, there is a federally-enforceable requirement for FR clothing under the following conditions:

  1. The employee is exposed to contact with energized circuits parts operating at more than 600 volts;
  2.  An electric arc could ignite flammable material in the work area that, in turn, could ignite the employee’s clothing;
  3.  Molten metal or electric arcs from faulted conductors in the work area could ignite the employee’s clothing, or
  4.  The incident heat energy estimate exceeds 2.0 cal/cm2 if a hazard analysis has been completed, or could reasonably be expected to exceed 2 cal/cm2 if a hazard analysis has not been completed (p. 390). (2)

Please Note: FR clothing, for use in instances outline above, does not currently have to be matched to the hazard, but must be provided by the employer at no cost to the employee. OSHA has issued a temporary delay on citations under the new rule until October 31, 2014. With this delay, workers need to be outfitted in “non-melting” FR clothing at minimum. The new ruling won’t be enforced by OSHA until the end of October.

There are several different methodologies that one could use to determine if an item is FR or not. The most common test in the United States is the Vertical Flame Test we previously mentioned. The European standard is a flame impingement test, which is a lower threshold of resistance to ignition. Some organizations cite 100% cotton denim’s natural resistance to ignition from electric arc as a type of flame resistance – assuming the hazard is electric arc (IEEE Paper No. PCIC-97-35 cites the ignition threshold of 12.8 oz. blue denim at 15.5 cal).

Under the third scenario, 100% cotton jeans may be considered acceptable as flame resistant since they are non-melting. However, depending on the weight, color and condition of cotton jeans, as well as the incident energy of the arc, 100% cotton jeans can ignite. Click here to watch Tyndale’s testing video showing results of FR and non-FR pants exposed to an electric arc. As the video shows, cotton fabric can and will ignite, and continue to burn if exposed to an ignition source. The non-FR jeans tested are made of 100% cotton, and continue to burn after the source of flame is removed (on the left), even though they do not “melt.” However, the FR jeans immediately self-extinguish (on the right). This video is a valuable demonstration of why it is important to protect both the upper and lower body with FR clothing.

Arc-Rated Clothing: OSHA is requiring employers to complete an arc flash assessment (previously called a hazard assessment) by January 1, 2015. Arc-rated clothing is required when employees are working on or near exposed live parts greater than 600V. Under such conditions, clothing could be ignited by:

-          nearby flammable material that could be ignited; and/or

-          molten metal splatter from electric arcs (1).

OSHA’s revised standard will be the first law with a national scope to require arc flash calculations (effective January 1, 2015) and electrical PPE to be arc-rated (flame resistant). Employer-provided arc-rated clothing matched to the hazard must be provided by April 1, 2015. This extended date for arc-rated clothing allows time for the industry to adapt from the old requirement of simply FR.

Tyndale FRMC Arc Rating Label

Exterior arc rating/HRC label with FRMC® on front shirt pocket.

FRC Suppliers, like Tyndale, can help you stay compliant with OSHA’s updated ruling, and help you explain how their clothing can protect your employees, and against which hazards. All Tyndale-branded clothing meets both FR and arc-rated clothing requirements, as defined by OSHA. As a safety enhancement, Tyndale now includes an exterior label on all our manufactured garments that indicates both a garment’s arc rating and its hazard risk/PPE category rating. This means that your employees’ garment protective levels are visible at all times—and that you know it’s arc-rated.

For more information on Tyndale’s complete line of arc-rated and flame resistant clothing, please visit www.tyndaleusa.com. Not in a Tyndale-managed clothing program? Email 1910.269@tyndaleusa.com to learn more about Tyndale’s solution for OSHA’s updated standard.

 

References for this post were accessed June & July 2014:

(1) Hugh Hoagland e-Hazard OSHA 1910.269 Presentation June 2014

(2) 2014 Final OSHA 1910.269 and 1926 Subpart V Rule

OSHA 1910.269 FR Clothing Update: 3 Reasons to Act Now

In April 2014, OSHA issued a ruling revising 29 CFR 1910.269 and 1926 subpart V, standards governing workplace safety in ele
ctric power generation, transmission and distribution work, that clarified and expanded employers’ responsibility to protect employees from arc flash hazards.

In fact, electric utilities large and small—including municipalities and cooperatives—will now be legally-required to supply employees with appropriate FR clothing.

Although the ruling will not be enforced by OSHA until October 31, 2014, employers should act now. Here’s why:

1. If you don’t currently provide full-body arc-rated clothing to your employees, your workers are at risk.

Based on the protective clothing your company currently provides, what would the quality of life be like for one of your employees after an arc flash incident?

OSHA’s previous requirement was simply that a worker’s clothing “do no harm” in the event of an arc flash. As a result, some utilities chose to meet the requirement by providing employees with natural fiber—rather than FR—pants.

The new ruling represents a distinct departure from the past, as it now explicitly requires employers to provide employees with full-body FR clothing matched to the hazard. Tyndale recently tested a pair of FR jeans against a pair of non-FR 100% cotton jeans. The video of the testing is a valuable demonstration of why the new requirement for full-body FR clothing is important.

Did you know that not all FR is created equal? FRC simply means non-melting whereas Arc Rated clothing is actually matched to the hazard workers face. Remember, all AR is FR but not all FR is AR.

2. As of July 10, 2014, it’s the law.

As part of this standard becoming law, the requirement for employers to provide employees with “non-melting” FR clothing is law as of July 10, 2014 and will be federally-enforced beginning October 31, 2014.

Further, under penalty of government-issued citation, employers are required to provide head-to-toe AR clothing matched to the mandated hazard assessment for hazards above 2 calories or work above 600v by April 1, 2015.

3. Supplies are Limited

Employers should take immediate action to evaluate current employee PPE offerings and schedule the required hazard assessment. The ruling will significantly increase demand for required arc rated items—particularly pants—and the effects of the demand will be felt throughout the supply chain.

The last time an FR clothing PPE standard was issued in 2010, there were significant industry-wide shortages.  Working with a supplier like Tyndale to reserve inventory now will ensure your Company is positioned to be in compliance before the April 1st 2015 deadline.

What to do next:

In a Tyndale managed FR clothing program today? You’re on your way to compliance! Contact your National Account Manager for next steps.

Not in a Tyndale managed FR clothing program? Contact Tyndale at 800.356.3433 to learn more about solutions for this new standard.

Access e-Hazard’s Side-By-Side Comparison of Changes to OSHA 1910.269 Standard

Tyndale, e-Hazard OSHA 1910.269 Update for Electric Utilities

OSHA last issued rules for the construction of transmission and distribution installations in 1972. As you may now know, OSHA has determined that those provisions are out of date and inconsistent with the more recently promulgated general industry standard covering the operation and maintenance of electric power generation, transmission, and distribution lines and equipment. The Final Federal Rule was published to the national register on April 11, 2014 and incorporates changes with regard to FR clothing that have significant impact for employers. The revised standards will ensure that employers, when appropriate, must meet consistent requirements for work performed under the construction and general industry standards (1).

OSHA’s new ruling provides a great deal of information. To help provide insight, e-Hazard has put together a side-by-side comparison document of the new OSHA 1910.269 standard with the previous version. Changes and variations to the standard are illustrated with highlights. In its document, e-Hazard has addressed new/different information, slight variations in grammar, clarifications, updated citations and references, and amended language that has impacted meaning from the previous version. This tool helps companies understand how the new ruling will impact their employees and helps those impacted to stay current on the latest information.

The final rule becomes law and employers must provide a minimum of “non‐melting” FR clothing on July 10, 2014. OSHA has since issued a temporary enforcement delay stating it will not begin to issue citations against the new rule until October 31, 2014. Employers must complete the mandated hazard assessment by January 1, 2015, and employees must wear the appropriate arc‐flash PPE matched to the hazard beginning April 1, 2015.

Please note the Disclaimer from e-Hazard that this document has been provided as a public service and is for informational purposes only.

As both a manufacturer and distributor of flame resistant and arc rated clothing, Tyndale seeks to help employers understand the final ruling’s impact and how to properly protect your employees. For additional information on the updated 1910.269 standard:

Or read Tyndale’s blog series which addresses important updates employers should be aware of:

 

References for this post were accessed April – June 2014:

(1) https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=24422

Final OSHA 29 CFR 1910.269 Update: Care, Maintenance and Laundering of FR Clothing

During Electrical Safety Month in May, Tyndale began discussing key aspects of OSHA’s revised ruling of 1910.269 as it applies to FR clothing and has aimed to help employers understand its impact and how to properly protect employees.

In this post, Tyndale identifies the last key component of OSHA’s final ruling as it relates to arc rated clothing worn by utility workers. In the updated standard, OSHA supports home laundering of arc rated and FR clothing. While the final rule does not require employers to launder protective clothing for employees, OSHA makes clear that it is the employer’s responsibility to ensure proper care and maintenance of employees’ protective clothing.

Is Home Laundering of FR Clothing Allowed? how to wash FR clothing

Yes, OSHA explicitly says that “The Agency is not prohibiting home laundering of FR and arc-rated clothing (p. 187).” While the designation of FR clothing as PPE requires additional employer oversight, it is clear OSHA allows home laundering of FR clothing. “OSHA concludes that there is no additional cost associated with laundering the flame-resistant clothing required by the final rule.

  • First, as stated, the final rule does not require employers to launder protective clothing for employees; and, therefore, while employers may choose to launder protective clothing for their employees, the rule does not impose the cost of laundering on employers.
  • Second, according to the record, employers or employees can generally follow the manufacturers’ care instructions that come with the clothing (Tr. 305-306, 1373-1374), and there is generally no additional cost to employees over that of laundering normal (that is, non-flame resistant) clothing (p.287).”

However, no longer can employers simply tell their workers to “follow washing instructions,” and trust that they will do so. “To comply with 1910.132 or 1926.95, employers cannot simply instruct employees to follow manufacturers’ instructions. If employers rely on home laundering of the clothing, they must train their employees in proper laundering procedures and techniques, and employers must inspect the clothing on a regular basis to ensure that it is not in need of repair or replacement (p. 187).”

Employers’ Responsibility for Care & Maintenance of FR Clothing

As noted above, “OSHA believes that it is the employer’s responsibility to ensure proper maintenance of PPE (p.187).” It is important to understand that engaging a laundry service does not exempt the employer from the responsibility of ensuring proper care of PPE. “In any event, the responsibility for maintaining PPE rests squarely with the employer under existing OSHA standards (p. 187).”

OSHA’s update to 1910.269 now implements an industry-wide requirement to perform regular checks of PPE where previously this was simply treated as a best practice. Tyndale recommends implementing brief visual inspection of FR clothing as a standard component of job briefings. A simple visual check for excessive soil, wear-and-tear, holes and/or stains can be accomplished quickly, and is an effective method to meeting this OSHA requirement.

Supervisors, safety personnel and other management retain the right to require that a garment be retired if they believe that it does not meet reasonable safety or image requirements. It is important to note that when it comes to arc flash protection, normal wear and tear of a garment does not necessarily result in a lower arc rating. Experienced FRC suppliers offer guidance and support on training supervisors and end users; click here to Download Tyndale’s Sample FRC Clothing Retirement Policy.

Repairs of flame, thermal, and arc resistant clothing should be made from components equivalent to those used in the original manufacturing to avoid reducing the performance properties of the flame resistant garment. Garments that have non-repairable damage, are worn out, or are unusable for other safety reasons, are not to be reused and should be discarded. Remember that regardless of laundering method, the employer is required to perform these inspections and has full responsibility in doing so.

Deadlines & Additional Resources

Employers must make reasonable estimates of incident energy by January 1, 2015. However, employers are required to provide protective clothing and other protective equipment meeting the arc-flash protection requirements of the final rule by April 1, 2015. Even with a later compliance date for protection, employers should not delay in engaging an arc rated clothing supplier. This ruling will significantly increase the demand for arc rated items which can impact the rest of the supply chain. The last time an FR clothing PPE standard was issued in 2010 there were significant industry-wide shortages.

As both a manufacturer and distributor of arc-rated and flame resistant clothing, Tyndale seeks to help employers understand the final ruling’s impact and how to properly protect your employees. For a summary overview of OSHA’s critical updates related to FR clothing, Download Tyndale’s Frequently Asked Questions.

Still have questions? Visit www.tyndaleusa.com for additional information and training videos or email: 1910269@tyndaleusa.com to learn how you can fulfill your FR clothing requirements with Tyndale today!

Links to other posts in this series:

References for this post were accessed May/June of 2014:

2014 Final OSHA 1910.269 and 1926 Subpart V Rule

Key OSHA 29 CFR 1910.269 Update: Employer Responsibility to Provide FR Clothing

During National Electrical Safety Month in May, Tyndale began discussing key aspects of OSHA’s revised ruling as it applies to FR clothing and during National Safety Month in June, Tyndale will continue to help employers understand how the new rule will impact their role, and the associated costs in properly protecting employees.

The third key component of OSHA’s final ruling as it relates to arc-rated clothing worn by utility workers is that OSHA makes several statements in its revised standard indicating support of an allowance-based FR clothing program, and provides recommendations for allowance amounts. An allowance ensures proper funding while allowing employees to purchase upgraded or personalized PPE with their own funds at no additional cost to the employer.

Support of Allowance Programs for FR Clothing

Now that OSHA has classified FR as PPE, Tyndale noted that “The OSH Act requires employers to pay for the means necessary to create a safe and healthful work environment… Under the OSH Act employers are responsible for providing at no cost to their employees the PPE required by OSHA standards to protect employees from workplace injury or death (p. 183).”

OSHA Recommendations for FR Allowances

While OSHA acknowledges considerable flexibility in the approaches employers can use to satisfy PPE requirements, the Final Rule outlines acceptance of an allowance program. In fact, OSHA makes several statements indicating support of an allowance-based FR clothing program. OSHA specifies in the Costs for Providing Arc-Flash Protective Equipment section that “the record indicates that annual employee stipends to cover all flame-resistant clothing…” (p. 287). By referencing that allowances/stipends are currently used to provide flame resistant clothing to employees, and not specifically prohibiting their future use, OSHA is implicitly acknowledging acceptance.

OSHA continues, “While it’s true that most employers pay for most PPE most of the time, the practices for providing PPE are quite diverse. Many employers pay for some items and not for others, either as a matter of collective bargaining or long standing tradition. In some cases, costs are shared between employees and employers. In other workplaces, the employer pays for more expensive or technologically advanced PPE while requiring employees to pay for more common items. However, in some workplaces, exactly the opposite is true (p. 183).”

Recommended Allowance Amount

How much will the OSHA 1910.269 changes cost an employer?

The most straightforward approach to meeting the PPE requirements under the revised Final Rule is to issue employee allowances of $455 annually, and a one-time new hire allowance of $1,534. This approach ensures that an employer is providing sufficient PPE (from OSHA’s perspective) at no cost to the employee, while allowing the employee the option to purchase specialized or enhanced flame resistant apparel with his or her own funds at his or her discretion.

OSHA addresses the total estimated cost for FR clothing in the Final Rule. “The general PPE-payment rule, including all exceptions, applies to the FR and arc-rated clothing used to comply with this final rule (p.696).” “OSHA notes that its estimate of eight sets is in the middle of the number of sets recommended by the commenters… the Agency is basing its estimates on a cost of $1,534.00 per employee for eight sets of flame resistant clothing (using the estimated cost of $191.75 per set), or on an annualized cost of approximately $452.88 per employee. The Agency believes this final estimate is reasonable and captures the average cost of all flame resistant clothing required by the new provisions of the final standard (p. 287).”

Upgraded PPE

OSHA Directive CPL 02-01-050 further addresses Upgraded and Personalized PPE. This instruction, Enforcement Guidance for Personal Protective Equipment in General industry, was issued in 2011 and established OSHA’s general enforcement and guidance policy for its standards addressing personal protective equipment (PPE).

The Directive states that an employer does not have an obligation to pay for PPE requested by an employee that exceeds the PPE requirements, given that the employer provides PPE that meets the standards at no cost to the employee. If the employer allows the employee to acquire and use upgraded or personalized PPE, then the employer is not required to reimburse the employee for the equipment, provided that the employer has provided adequate PPE at no cost to the employee. An employer is still required to evaluate an employee’s upgraded or personalized PPE to ensure that it is:

  • Adequate to protect from hazards present in the workplace,
  • Properly maintained, and
  • Kept in a sanitary condition.

Replacement PPE

In its revised ruling of 1910.269, OSHA gives recommendations regarding replacement PPE when an employee has lost or intentionally damaged the PPE. Existing PPE standards require that the employer provide replacement PPE used to comply with OSHA standards as necessary:

  • When the PPE no longer provides the protection it was designed to provide, or
  • When the previously provided PPE is no longer adequate or functional.

The final rule clarifies that when an employee has lost or intentionally damaged the PPE issued to him or her, an employer is not required to pay for its replacement and may require the employee to pay for such replacement.

(*See 29 CFR 1910.132(h)(5); 29 CFR 1915.152(f)(5); 29 CFR 1918.106(e); 29 CFR 1926.95(d)(5))

Additional Recommendations for Meeting OSHA’s PPE Requirement

In addition to the annual allowance, which ensures proper funding for PPE, and allows employees the option of upgraded PPE, Tyndale recommends the following:

  • The utility maintain a stocking program for the lowest-cost coverall, or shirt and pants, which would be available through standard storeroom supply, much in the same way safety glasses and hardhats are provided.
  • Such low-cost garment options ensure that employees can have access to employer-paid PPE at any time.
  • Because they are the most basic options, this minimizes cost to the employer, while eliminating the motivation for employees to acquire unnecessary PPE.
  • Suppliers like Tyndale can provide suggestions on stocking quantities, based on number of workers associated with a specific storeroom, and a standard sizing distribution.

OSHA’s support of allowance programs in the new 1910.269 standard is important because an allowance ensures proper funding while allowing employees to purchase upgraded or personalized PPE with their own funds at no additional cost to the employer.

In our final post, Tyndale will discuss whether or not laundering of garments is required under the final rule, and Employers’ Responsibility for Care & Maintenance of FR Clothing. To learn how you can fulfill your arc rated or FR clothing requirements with Tyndale, please visit www.tyndaleusa.com or email: 1910269@tyndaleusa.com

Links to other posts in this series:

References for this post were accessed May/June of 2014:

2014 Final OSHA 1910.269 and 1926 Subpart V Rule

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