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Understanding Critical Changes to OSHA 1910.269 During Electrical Safety Month

Tyndale Celebrates National Lineman's Day 2014

May is National Electrical Safety Month, an important time to bring electrical safety awareness to our communities, to help educate the public and prevent injury. Coinciding with National Electrical Safety Month is the recent change to OSHA 1910.269 which updates the standard providing electrical safety guidance for those in the operation and maintenance of electrical power.

Important Note: As of February 2015, compliance dates have changed for enforcement of OSHA standard 1910.269. These changes impact dates listed in this post. Click here for complete details and updated deadlines.

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 revised rule implements significant changes to utilities’ requirements for protecting workers from electric arcs and using arc rated clothing, among other areas. 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.

The Final Federal Rule updates a 40-year-old standard and incorporates important changes with regard to FR clothing that have significant impact on employers, who must comply by April 1, 2015.

Generally, OSHA has updated the standard for electric power line work to make it more consistent with the corresponding overall industry standards and requirements. Importantly, OSHA estimates the revised ruling will save more than 20 lives and prevent 118 serious injuries each year.

Electrical Safety in the Workplace & What This Means to Employers

OSHA’s revised ruling will require many utilities and electrical companies to provide more arc rated clothing to their employees.

In general, an employer must:

  • Assess the workplace to identify employees exposed to hazards from flames or from electric arcs;
  • Make reasonable estimates of the incident heat energy of any electric-arc hazard to which an employee would be exposed;
  • Ensure that employees exposed to hazards from flames or electric arcs do not wear clothing that could melt onto their skin or that could ignite and continue to burn when exposed to flames or estimated heat energy;
  • Ensure that the outer layer of clothing worn by an employee is flame resistant under certain conditions; and
  • With certain exceptions, ensure that employees exposed to hazards from electric arcs wear protective clothing and other protective equipment with an arc rating greater than or equal to the estimated heat energy (1).

6 Critical Changes to OSHA 1910.269

The industry views OSHA’s changes as much-needed measures to better protect the men and women who work on or near electrical power lines. It is now up to employers to comply with the following requirements as they relate to arc rated and flame resistant clothing:

  1. New Minimum Protection

Among the changes incorporated into the revised ruling, employers are to provide head-to-toe FR clothing for all hazards greater than 2 calories or for work above 600 volts. This requirement for full body protection means that workers will now be required to wear FR pants, balaclavas or face shields, boots and gloves, in addition to FR shirts and coveralls already commonly provided.

  1. Arc Rated and FR Clothing is Now Treated as PPE

OSHA now believes that it is reasonable and appropriate to treat FR and arc-rated clothing required by the revised ruling as personal protective equipment (PPE). This will be reflected as an increase to allowances and/or by adding additional items to approved clothing selections for employees.

  1. Indication of Support for Allowance Programs

OSHA makes several statements in the revised standard indicating support of an allowance-based FR clothing program and provides annual per-employee cost estimates, from which employers could derive annual allowance amounts. In fact, allowance programs provide a straightforward approach to meeting the PPE requirements for the revised ruling, as employers could leverage OSHA’s estimated per-employee cost figures and issue employee allowances in the amount of $455 annually and one-time new hire allowances of $1,534 (p. 287). However, OSHA also acknowledges considerable flexibility in the approaches employers can use to satisfy PPE requirements.

  1. OSHA Supports Home Laundering

While the designation of FR clothing as PPE requires additional employer oversight, it is clear OSHA allows home laundering of FR clothing. The final rule does not require employers to launder protective clothing for employees.

If you always thought industrial laundering was necessary for your employees’ protective garments, click here to find out Which is Best for FR Clothing: Home Laundering or Industrial Laundering?

  1. Employer Responsibility for Care & Maintenance of FR Clothing

OSHA explains that if employers rely on home laundering of FR clothing, they must train their employees in proper laundering procedures and techniques, and that employers must inspect the clothing on a regular basis to ensure that it is not in need of repair or replacement.

Regardless of whether or not a laundry service provider is utilized, the responsibility for maintaining PPE rests squarely with the employer under existing OSHA standards.

Experienced FRC suppliers offer guidance and support on training end users. Click here to Download Tyndale’s Sample FRC Clothing Retirement Policy or visit www.tyndaleusa.com for additional resources and training videos.

  1. Cost of Changes to 1910.269 to Employers

OSHA specifically addresses the total estimated cost for FR clothing in the Final Rule at an annualized cost of approximately $452.88 per employee. OSHA is basing its estimates on a cost of $1,534 per employee for eight sets of flame resistant clothing (using the estimated cost of $191.75 per set), or on the approximate annualized cost per employee mentioned above (p. 287). 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.

Important Dates for These Changes

Employers must make reasonable estimates of incident energy by February 17, 2015 (the original deadline was January 1, 2015 but OSHA has since stated it will not enforce this deadline until the extended date). 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.

For more detailed information on the updates above, Download Tyndale’s Frequently Asked Questions, or stay tuned for Tyndale’s upcoming series on each of these critical changes. In honor of Electrical Safety Month, Tyndale will discuss key aspects of OSHA’s revised ruling of 1910.269 as it applies to FR clothing and will seek to help employers understand its impact and how to properly protect employees.

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. Click here to read the next post on the first key update to OSHA 1910.269, that FR clothing is now designated as PPE.

References for this post were accessed April/May 2014:

(1) https://www.osha.gov/dsg/power_generation/faqs.html

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