Incident Prevention Magazine

The company I work for receives a lot of questions about flame-resistant (FR) and arc-rated (AR) clothing, including inquiries about what should be worn on extremely hot summer days and very cold winter days. We’re always happy to answer those questions because it’s our business and – in the electric utility industry – donning FR/AR apparel often is necessary for workers’ personal safety.

The fact is, extreme weather doesn’t appear to be stabilizing anytime soon. Both NASA and the American Meteorological Society have predicted that we can expect both more intense and more frequent heat and cold events across the country in the coming decades, with implications for both indoor and outdoor workers.

Given that information, it’s important that workers know what heat stress and cold stress are and what those types of stress can do to their bodies. So, let’s discuss some definitions of heat and cold stress, what can contribute to them, and what employers and workers can do to address them – including participating in a strong FR/AR clothing program. 

When the original version of the OSHA 29 CFR 1910.269 standard was published in the 1990s, flame-resistant (FR) and arc-rated (AR) clothing weren’t even mentioned. The dangers associated with electric arcs were known at the time, 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 sustained by the employee. This eliminated use of garments constructed with synthetic materials – such as polyester, nylon, rayon and acetate – so the default was for employees to wear clothing made of 100% cotton. The problem was that non-FR cotton, once exposed to thermal energies beyond its ignition point, will ignite and continue to burn, thus adding to the employee’s injury.

It has now been a little over five years since FR/AR clothing requirements were incorporated into the 1910.269 standard. The 2014 final rule (see www.govinfo.gov/content/pkg/FR-2014-04-11/pdf/2013-29579.pdf) states the following: “The new provisions for protection from electric arcs include new requirements for the employer to: Assess the workplace to identify employees exposed to hazards from flames or from electric arcs, make reasonable estimates of the incident heat energy to which the employee would be exposed, ensure that the outer layer of clothing worn by employees is flame resistant under certain conditions, and generally 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.”

When the original version of the OSHA 1910.269 standard was published, flame-resistant (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 sustained by the employee. This was covered under 1910.269(l)(6)(iii). The rule eliminated the use of garments constructed with synthetics such as polyester, nylon, rayon and acetate, which could melt and drip, and led to the adoption of clothing made with 100 percent cotton. The problem was that non-FR cotton – once exposed to thermal energies beyond its ignition point – will ignite and continue to burn, thus adding to an injury.

Now that the much-anticipated revisions to the 1910.269 standard have been published, they have introduced a number of new challenges to the electric utility industry and those entrusted with their employees’ safety. Specifically, page 20317 of the final rule (see www.gpo.gov/fdsys/pkg/FR-2014-04-11/pdf/2013-29579.pdf) states that the “new provisions for protection from electric arcs include new requirements for the employer to: Assess the workplace to identify employees exposed to hazards from flames or from electric arcs, make reasonable estimates of the incident heat energy to which the employee would be exposed, ensure that the outer layer of clothing worn by employees is flame resistant under certain conditions, and generally 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.”