Voice of Experience: OSHA Updates to Arc-Rated FR Clothing Requirements

Over the last few months I have delivered several presentations and webinars on the recent revisions to OSHA 29 CFR 1910.269. During these sessions, attendees asked for clarification on a variety of topics, particularly arc-rated flame-resistant (FR) clothing. This month’s “Voice of Experience” is devoted to helping readers understand more about the impact of OSHA’s changes on this subject.

At the time I am writing this, some of OSHA’s enforcement dates have recently changed due to a number of issues, questions and clarifications that the agency is working to address. The updated enforcement dates can be found in Exhibit C of OSHA’s recent settlement with Edison Electric Institute, which is accessible at www.osha.gov/dsg/power_generation/SubpartV-final-settlement.html. Given these changes, it is important that all readers understand that the use of arc-rated FR clothing is now mandatory. Hopefully companies have completed their plans and are ensuring that employees are wearing properly rated protective clothing when work activities require it.

Let’s take a moment to be sure that the intent of the new standard is understood. To begin, what is meant by the term “arc-rated”? An arc-rated piece of clothing is made of special treated material that has an arc thermal protective value (ATPV). If an employee wearing the clothing is exposed to a thermal arc, the material will resist a break-open and a flame up to the treated value of the ATPV or, if the material has one, the hazard risk category (HRC) rating. HRCs usually are rated as follows:
• HRC 1: up to 4 calories
• HRC 2: up to 8 calories
• HRC 3: up to 25 calories
• HRC 4: up to 40 calories

There are certain conditions and equipment that have excessive exposures up to 100 calories. Special flash suits, arc blankets and related items are required for those activities if de-energizing and grounding are infeasible. For instance, it would not be feasible to de-energize when working in network cable vaults or on switchgear.

Following are a number of paragraphs found in the revised 1910.269 standard that relate to arc-rated FR clothing, along with a greater explanation of each. It is important that employers and employees are aware of what these paragraphs mean and the impact they have in the workplace.

1910.269(l)(8)(iv)
“The employer shall ensure that the outer layer of clothing worn by an employee, except for clothing not required to be arc rated under paragraphs (l)(8)(v)(A) through (l)(8)(v)(E) of this section, is flame resistant …”

This includes rain suits, traffic vests and heavy coats. It must be pointed out that this rule requires only that outer clothing be arc-rated. There is no mention of what type of clothing can be worn between outer garments and the undergarments that touch an employee’s skin. A word of caution: Synthetics – which are popular in colder climates as a method of insulation – will melt in some cases and cause harm to the employee due to heat transfer of the arc through the outer garment. Also see the following section for more information regarding synthetics.

1910.269(l)(8)(iii)
“The employer shall ensure that each employee who is exposed to hazards from flames or electric arcs does not wear clothing that could melt onto his or her skin or that could ignite and continue to burn when exposed to flames or the heat energy estimated under paragraph (l)(8)(ii) of this section.”

Based on this statement, employees should be sure to prohibit employees from wearing synthetics whenever they could be exposed to arcs or flames. Additionally, both employers and employees should be aware that any arc-rated FR shirts should be tucked into pants and buttoned at the sleeves and neck. If skin is exposed, the clothing will not provide maximum protection.

1910.269(l)(8)(iv)(A)
“The employer shall ensure that the outer layer of clothing worn by an employee … is flame resistant under any of the following conditions: The employee is exposed to contact with energized circuit parts operating at more than 600 volts …”

This paragraph is relatively straightforward. Essentially, an employee shall be protected by arc-rated FR clothing if he is working on or exposed to any equipment that is energized at more than 600 volts; any equipment that was previously energized at more than 600 volts and is now de-energized and not grounded; or any conductors operating at more than 600 volts.

1910.269(l)(8)(iv)(B)
“The employer shall ensure that the outer layer of clothing worn by an employee … is flame resistant under any of the following conditions: An electric arc could ignite flammable material in the work area that, in turn, could ignite the employee’s clothing …”

Again, this is straightforward language that requires protection of an employee anytime there is a chance that an arc might ignite flammable material in the work area.

1910.269(l)(8)(iv)(C)
“The employer shall ensure that the outer layer of clothing worn by an employee … is flame resistant under any of the following conditions: Molten metal or electric arcs from faulted conductors in the work area could ignite the employee’s clothing …”

Faults can potentially damage conductors or equipment and also start fires that can ignite an employee’s clothing. Consequently, employees must wear arc-rated FR garments in order to protect themselves. Conductors rated for maximum fault currents are not covered by this section.

1910.269(l)(8)(iv)(D)
“The employer shall ensure that the outer layer of clothing worn by an employee … is flame resistant under any of the following conditions: The incident heat energy estimated under paragraph (l)(8)(ii) of this section exceeds 2.0 cal/cm².”

Incident heat energy must be estimated by the employer by performing an analysis on the system for the benefit of protecting employees from higher incident energy rates.

Note: There are no exceptions to paragraphs 1910.269(l)(8(iv)(A), (B), (C) and (D) if any of the conditions exist as described.

Specific Body Part Coverage
I have received a number of questions about what body parts need to be covered and if there are any exceptions. The following paragraphs answer nearly everyone’s questions.

1910.269(l)(8)(v)(A)
“Arc-rated protection is not necessary for the employee’s hands when the employee is wearing rubber insulating gloves with protectors or, if the estimated incident energy is no more than 14 cal/cm², heavy-duty leather work gloves with a weight of at least 407 gm/m² (12 oz/yd²) …”

One of the questions I am asked most is if an employee has to wear a long-sleeve shirt under rated sleeves when performing energized work. As of press time, there is no exception when wearing rated sleeves. Long-sleeve shirts are still required under rated sleeves until OSHA offers a letter of clarification and exception.

The four paragraphs of the standard found below cover rules related to foot and head protection. Like some of the other paragraphs we’ve covered in this article, 1910.269(l)(8)(v)(B) and (C) are fairly straightforward. Paragraph (D) defines the type of protection required – a Class E hard hat and HRC 2 face shield – and paragraph (E) provides an exception of estimated energy if the energy estimate doesn’t exceed 13 calories. The equipment can be rated at HRC 2 because of the 4-cal reduction allowed due to single-phase open-air arcs. The reason for the exception is that a serious burn likely will not occur at that level.

1910.269(l)(8)(v)(B)
“Arc-rated protection is not necessary for the employee’s feet when the employee is wearing heavy-duty work shoes or boots …”

1910.269(l)(8)(v)(C)
“Arc-rated protection is not necessary for the employee’s head when the employee is wearing head protection meeting § 1910.135 if the estimated incident energy is less than 9 cal/cm² for exposures involving single-phase arcs in open air or 5 cal/cm² for other exposures …”

1910.269(l)(8)(v)(D)
“The protection for the employee’s head may consist of head protection meeting § 1910.135 and a faceshield with a minimum arc rating of 8 cal/cm² if the estimated incident-energy exposure is less than 13 cal/cm² for exposures involving single-phase arcs in open air or 9 cal/cm² for other exposures …”

1910.269(l)(8)(v)(E)
“For exposures involving singlephase arcs in open air, the arc rating for the employee’s head and face protection may be 4 cal/cm² less than the estimated incident energy.”

Conclusion
As of January 1 of this year, your company’s energy analysis should have been completed, and arc-rated FR clothing should have been implemented by April 1. The one exception to the arc-rated FR clothing rule is that – until August 31, 2015 – OSHA will not issue any citations under 29 CFR 1910.269(l)(8)(v) or 29 CFR 1926.960(g)(5) if an employer fails to provide protective clothing or equipment rated higher than 8 cal/cm².

It is my hope that the information provided in this article has answered any remaining questions you may have had about arc-rated FR clothing relevant to the revised 1910.269 standard. If you are still unclear about anything, please don’t hesitate to reach out to me or the Incident Prevention staff.

About the Author: Danny Raines, CUSP, safety consultant, distribution and transmission, retired from Georgia Power after 40 years of service and opened Raines Utility Safety Solutions LLC, providing compliance training, risk assessments and safety observation programs. He is also an affiliate instructor at Georgia Tech Research Center OSHA Outreach in Atlanta. For more information, visit www.electricutilitysafety.com.