Read Tyndale’s article, featured on page 44 of the October 2014 edition of Industrial Safety & Hygiene News (ISHN) Magazine, for guidance to employers looking to understand both OSHA’s 2014 update to 29 CFR 1910.269 and OSHA’s view of care and maintenance for PPE in a broader context—beyond the utility industry.
Posts tagged ‘personal protective equipment (PPE)’
NFPA 70E is a voluntary standard advising on electrical safety in the workplace. This standard is geared toward workers and employers, and is designed to assist in the understanding and implementation of electrical safety precautions. NFPA 70E includes guidance for making hazard identification and risk assessments, selecting appropriate PPE (including flame resistant clothing), establishing electrically-safe working conditions and employee training.
The Technical Committee’s goal is to develop a standard that is usable, easy to interpret and provides a means to guide electricians to establish a safe work environment. The most recent update to standard NFPA 70E – the 2015 edition – became effective July 29, 2014. This standard is updated every three years and the release of the 2015 edition updates the 2012 version.
Changes important to workers wearing flame resistant apparel include the following:
1. Terminology Change:
- PPE Category has replaced HRC
According to note (14) on page 7, “Hazard/risk category [HRC] will now be referred to as PPE category.”
- Hazard Analysis now referred to as Risk Assessment
NFPA 70E 2015 edition defines Risk Assessment as “An overall process that identifies hazards, estimates the potential severity of injury or damage to health, estimates the likelihood of occurrence of injury or damage to health, and determines if protective measures are required.” (p. 17)
Risk Assessment is further examined in the footnote to Table 130.7(C)(15)(A)(a): “Hazard identification is one component of risk assessment. Risk assessment involves a determination of the likelihood of occurrence of an incident, resulting from a hazard that could cause injury or damage to health.”
2. A Change to “Coverage” Requirements
In section (d) on page 31, “Coverage,” a couple of changes can be seen:
- The word coverall was added to two parts:
- “Shirt and coverall sleeves shall be fastened at the wrists…”
- “…shirts, coveralls, and jackets shall be closed at the neck.”
- Additionally, a statement was added, “shirts shall be tucked into pants…”
The second change to “Coverage” requiring shirts to be tucked into pants is in-line with OSHA’s recent updates to standard 29 CFR 1910.269. According to e-Hazard, “NFPA 70E helps employers meet the performance requirements of the OSHA standards for electrical safety. (1)” To further assist employers in understanding what is required under OSHA’s standard pertaining to arc-rated PPE maintenance and inspection, Tyndale has developed this helpful employee training video.
3. Elimination of HRC 0
According to note (14) on page 7, “Hazard/risk category 0 has been removed from Table 130.7(C)(16)… Hazard/risk category 0 was deleted because the new PPE table only specifies work within the arc flash boundary. If there is no arc flash hazard, then no arc flash PPE is required and it is therefore not necessary on a table devoted to PPE.”
HRC 0 was eliminated, as the Committee felt that this table should only show requirements where arc-rated clothing was required. HRC 0 would mean the worker was outside the arc flash boundary and did not need arc-rated PPE or clothing.
Even with the HRC 0 requirement removed, there are still requirements when it comes to clothing—such as not wearing any melting fiber clothing when working on or operating energized electrical equipment. Section 130.7(C)(11) states, “Clothing consisting of fabrics, zipper tapes, and findings made from flammable synthetic materials that melt at temperatures below 315C (600F)—such as acetate, acrylic, nylon, polyester, polyethylene, polypropylene, and spandex, either alone or in blends, shall not be used. (2)”
However, it’s important to note that PPE Categories 1, 2, 3, and 4 still have the same requirements and the same minimum arc ratings as before.
4. New Arc Flash PPE Category Tables: 130.7(C)(15)(a) and (b)
The NFPA 70E Technical Committee has agreed to a new format for choosing arc-rated clothing and PPE. Details of the impending changes were outlined clearly in this May ISHN article. Predicted changes reflected in the updated standard include splitting Table 130.7(C)(15)(a) into two. The first table is used to determine if an arc flash hazard exists. One of the complaints about the previous table method was that tasks that do not pose an arc flash hazard are listed in the table – hence the decision to remove PPE Category/HRC 0. Under the new table method, if there is an arc flash hazard, you must wear the required PPE and arc-rated clothing matched to the hazard (3).
As the ISHN article states, “The new table is designed to simplify the selection of PPE for tasks where the type of equipment is selected first. No arc flash hazard means nothing further is required. If there is an arc flash hazard, then you would move to the second (new) table and choose the arc flash category of the recommended clothing and PPE.(3)” Again, this is based on the same limits as the previous table and the categories remain the same.
“Note that in this new table there is no perceived arc flash hazard if the equipment is properly installed, properly maintained and there is no evidence of impending failure on some of the listed tasks. This is critical, as these factors have to be part of the Risk Assessment required by NFPA 70E. For example, if a worker is troubleshooting electrical equipment, it is no longer normally operating; it is in distress and arc flash protective equipment must be worn to operate it or perform any other task on or with it. (3)”
A qualified person should be able to assess the hazards and risks involved in performing the task at hand and also be able to assess equipment condition. If they are unable to perform those requirements, they should not be considered a qualified person and require additional training.
Changes for FR Manufacturers
Due to the changes in standard outlined above, manufacturers will need to modify labeling on arc-rated clothing to reflect the new terminology. For example, Tyndale will soon phase out the old labeling method including a garment’s arc rating as defined by HRC levels. Now, Tyndale will use CAT (short for PPE Category) to communicate to wearers which protective category the garment falls into. All Tyndale-made shirts and outerwear include both arc rating and CAT on the exterior of the garment, giving instant visibility to a garment’s protective characteristics.
For more information or assistance navigating the changes to this industry standard and others, contact your Tyndale National Account Manager or check out the Industry Standards page on blog.tyndaleusa.com!
Sources for this post were accessed October 2014:
A copy of the updated standard is available on NFPA’s website.
OSHA’s 2014 updates to 29 CFR 1910.269 are generally embraced as much-needed measures to better protect the men and women who work on or near electric power lines. Read Tyndale’s article featured on page 44 of the July 2014 issue of Industrial Safety & Hygiene News Magazine (ISHN) for four important next steps employers should take prompt action to accomplish now that the OSHA 1910.269 final rule has been published.
In April, OSHA updated standard 29 CFR 1910.269 and 1926 subpart V to clarify and expand the employer’s responsibility to better protect employees working on or near electrical power lines. With this update, it is now the responsibility of employers to comply with the new requirements as they relate to flame resistant and arc-rated clothing.
We all know that FR clothing provides protection from arc flash and flash fire hazards. However, situations where your primary FR clothing may become heavily soaked in oil or covered in excessive dirt may cause unsafe conditions in which your primary FR clothing should no longer be worn. Disposable FR coveralls provide cost-effective protection that preserve the useful life of a worker’s primary FR. This ensures that the FRC will perform as expected in the event of an arc flash or flash fire incident.
Under the new 1910.269 and 1926 subpart V ruling, OSHA clarified its stance that FR and arc-rated clothing should reasonably and appropriately be treated as Personal Protective Equipment (PPE). This designation reinforces the employer’s legal obligation to provide, pay for, and retain ultimate responsibility for care and maintenance of FR and arc-rated clothing.
When considering strategies to comply with the new care and maintenance requirements, consider the facts: Read more
On April 11, 2014, OSHA published to the Federal Register the final rule revising 29 CFR 1910.269 and 1926 Subpart V, related to the construction and repair of electric power generation, transmission and distribution in an effort to improve workplace safety. This recent change to OSHA 1910.269 updates the standard providing electrical safety guidance for those in the operation and maintenance of electrical power.