Voice of Experience: Flame-Resistant Apparel is Now PPE

It’s official: Flame-resistant clothing is now considered PPE, and employers are required to furnish it to employees when there is a chance that they may be exposed to electric arcs or flames. This change has been a long time coming as the industry has been in limbo for years. A number of forward-thinking companies have been furnishing arc-rated FR clothing to their employees for some time, while others have waited for regulations to require them to do so. The company from which I retired as well as other large investor-owned utilities have uniform policies that incorporated arc-rated FR clothing years ago.

The Evolution of FR Clothing
When the original version of the 29 CFR 1910.269 standard was published in the early 1990s, FR clothing wasn’t even mentioned. The dangers associated with electric arcs were known, but the standard only required that an employer not allow an employee to wear clothing that, when exposed to flames or electric arcs, could increase the extent of injury that would be sustained by the employee. This was covered under 1910.269(l)(6)(iii). Many company safety rule books prevented the use of synthetic materials such as acetate, nylon, rayon and polyester because they can melt into the skin when exposed to arcs; this type of injury is severe and often fatal. Nomex was once the material of the day, but over time FR clothing has evolved, and today’s apparel has been proven to be more beneficial in protecting employees exposed to electric arcs.

The 2007 edition of the National Electrical Safety Code, an electric industry consensus standard that is updated every five years, gave the industry notice that, based on testing, arcs are a definite hazard to employees. The safe work procedures section, Rule 410.A.3, gave the industry until January 1, 2009, to perform engineering evaluations on their respective systems, determine the incident energy that employees were exposed to and protect employees from the hazard. At that time, many companies were transitioning into FR clothing.

Meanwhile, the OSHA performance standards remained unchanged. If an employee was involved in an arc flash incident, typically a General Duty Clause citation was issued. A 1995 OSHA memorandum, corrected in 2004, states the following: “Paragraph 1910.269(l)(6)(ii) – This paragraph shall be cited when employees who are exposed to flames or electric arcs have not been trained regarding apparel-related hazards covered by paragraph 1910.269(l)(6). This is consistent with paragraph 1910.269(a)(2)(i), which requires training in safety practices” (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21878). The wording in 1910.269(l)(6)(iii) was not amended or changed.

New Challenges
Now that the much-anticipated revisions to the 1910.269 standard have been published, they have brought many challenges to the electric utility industry. First and foremost, the standard now states – in 1910.269(l)(8)(i) and (l)(8)(ii) – that the employer “shall assess the workplace to identify employees exposed to hazards from flames or from electric arcs. For each employee exposed to hazards from electric arcs, the employer shall make a reasonable estimate of the incident heat energy to which the employee would be exposed.”

The standard also gives the industry the following direction in Note 1 to paragraph (l)(8(ii): “Appendix E to this section provides guidance on estimating available heat energy. The Occupational Safety and Health Administration will deem employers following the guidance in Appendix E to this section to be in compliance with paragraph (l)(8)(ii) of this section. An employer may choose a method of calculating incident heat energy not included in Appendix E to this section if the chosen method reasonably predicts the incident energy to which the employee would be exposed.”

Note 2 continues the requirement, stating that “[t]he employer may make broad estimates that cover multiple system areas provided the employer uses reasonable assumptions about the energy-exposure distribution throughout the system and provided the estimates represent the maximum employee exposure for those areas.”

This language is similar to that used in the NESC that requires employers to determine the amount of protection to be used based on exposure estimates through engineering calculations. The updated OSHA standard still contains language about preventing an employee from wearing synthetics that is similar to the former version of 1910.269. This can be found in 1910.269(l)(8)(iii), which reads, “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.”

Paragraph (l)(8)(iii) also has a note that states, “This paragraph prohibits 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.”

The industry must understand the difference between the ASTM 1506 vertical flame (FR) test requirements of self-extinguishing and the electric arc rating with an arc thermal protective value (ATPV). Hazard risk categories are expressed in ratings measured in heat calories of incident energy. Arc-rated clothing is required when the incident energy is greater than 2 calories as stated in 1910.269(l)(8)(iv)(D).

FR Clothing Exceptions
The only body parts not required to be protected by arc-rated FR clothing are an employee’s hands when he or she is wearing electrically rated dielectric rubber gloves, and an employee’s feet when he or she is wearing heavy leather boots. Testing has proved that dielectric gloves and heavy leather boots each have about 40-calorie protection from an electric arc.

One of the standard’s new additional measures of arc-rated protection is found in 1910.269(l)(8)(v)(C). That paragraph states that “[a]rc-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.”

Final Thoughts
When purchasing protective clothing, be sure to look for an ATPV or hazard risk category. Hazard risk category ratings are determined through testing and rated in thermal values. Without either the ATPV or hazard risk category, the chance of a clothing break-open is great if an employee is exposed to an electric arc, which can lead to further injury.

There are many questions about the new standard and possible future delays in implementation, but some of the PPE portions of the standard have already been implemented. The remainder will soon become the rule. The most important message here is to identify dangers to employees and wear appropriate protection.

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.

Special note: FR-rated fabric is different from – and cannot be substituted for – ATPV-rated fabric for work in potential electric arc environments.

There is a significant difference between the heating effects of a flame, which are primarily convective heat with low force, and those of an electric arc, which are primarily radiant heat accompanied by forceful expulsion gases carrying molten metal particles that can tear apart FR fabric and expose the skin underneath.

It is not enough to just resist ignition; ATPV apparel must also resist the blast forces and limit transmittal of radiant energy, which all too many FR fabrics simply will not do.