New OSHA regulations in effect August 2015 are designed to keep utilities workers safe on the job with stricter regulations for PPE. (TECGEN FR photo)

Utility Workers: Staying Safe and Up to Date with Appropriate FR Attire

Special attention must be paid to remain in compliance with NFPA 2112, NFPA 70E, and now OSHA 1910.269.

Incorporating a high-quality personal protective equipment (PPE) program is essential for keeping workers safe in any industry. But new OSHA regulations in the utility sector have increased guidelines to address the hazards arc flash can cause. Understanding these regulations and the need for comfortable, lightweight flame-resistant (FR) garments can help keep workers better prepared should an arc flash situation arise.

What's New in OSHA: A Breakdown of the Latest PPE Rules
In August 2014, OSHA introduced a final rule revising 29 CFR 1910.269—a standard for the construction and utilities industries that had been unchanged for around four decades. While the rule was enacted in July 2014, some of the new guidelines were delayed until August 2015. Following is a breakdown of the key changes for PPE and arc flash incidents.

Employers must1:

1. Assess the workplace to identify employees exposed to hazards from flames or electric arcs.

2. Make reasonable estimates of the incident heat energy of any electric arc hazard to which an employee would be exposed.

3. 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 the estimated heat energy.

4. Ensure that the outer layer of clothing worn by an employee is flame resistant under certain conditions.

5. 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.

OSHA has also established that full-body protection is necessary for all hazards greater than 2 calories or work above 600 volts. Therefore, in addition to FR shirts and coveralls, FR pants, boots, gloves, and face protection are also required.

In addition to these regulations, OSHA has initiated a change in how employers care for uniforms and maintain their PPE program. Home laundering is viewed as an acceptable method of cleaning FR uniforms, provided employers take the steps necessary to educate their employees on proper laundering techniques.

By implementing a regulation that requires employers to assess work environments and provide appropriate FR/PPE, OSHA estimates that 20 fatalities and 118 serious injuries will be avoided annually.

The Key to Comfortable, High-Performing FR Garments
With new OSHA regulations in place, employers in the utilities industries will need to begin implementing a FR garment program no later than August 2015. In order to ensure employee compliance, there are steps that should be taken when specifying garments to ensure the employees remain safe and comfortable year round.

The first step to implementing a successful flame-resistant garment program is supplying uniforms that will fit all workers regardless of height, weight, and gender. Extra small to plus size options should be available to accommodate all body types. Key considerations for garment fit include:

  • Shirt sleeves should be short enough that they do not need be rolled or cuffed.
  • Shirt tails should be long enough that they can be tucked in but short enough in the body to eliminate bunching when tucked into pants.
  • Coveralls should be fitted for hip and waist sizes so excess fabric does not get caught on equipment handles or affect mobility.
  • The body of the coverall should fit the wearer, not just the sleeve and pant length.

Selecting a Garment Program for Year-Round Protection
In addition to specifying garments based on fit, it is also important to consider the garment material, especially with new regulations about non-meltable and non-ignitable clothing. Garments should be constructed from lightweight, breathable, and moisture-wicking, inherently FR fabrics to ensure workers remain comfortable year round.

Considerations for Hot Environments
Working outdoors in the utilities industry brings about extra challenges for FR programs due to changes in temperature. In hotter environments and summer months, heat stress can be a risk for any worker outside. This is why it is important to select garments that are breathable and do not trap heat.

When selecting garments for hotter environments, employers should assess a garment's total heat loss (THL) rating. THL is a method used to measure the maximum workload or metabolic activity rate a person can sustain while still remaining comfortable in PPE. It can be defined as the amount of conductive (dry) and evaporative (wet) heat loss that occurs through PPE garments.2 By placing fabric samples on specially designed plates that simulate hot, sweaty skin under controlled lab conditions, the ability of the fabric to transfer heat can be precisely measured. In hot conditions, a fabric that holds less heat is more desirable. Selecting a garment with THL in mind can help avoid common problems associated with heat stress: discomfort, physiological strain, decreased productivity and performance, and increased accident rates on the job.3

By ensuring garments are comfortable in hot conditions, it is less likely that employees will make personal modifications to their garments—such as rolling up the sleeves. These modifications can lead to serious injury should an arc flash incident occur.

Considerations for Cold Environments
Cold environments also can pose challenges for employees wearing FR garments. In colder weather, workers may be tempted to pair a compliant FR garment with a non-FR layer for additional warmth. However, this could prove to be a deadly decision in an arc flash incident.

Special attention must be paid to remain in compliance with NFPA 2112, NFPA 70E, and now OSHA 1910.269. Garments that are not FR—especially heavy weight versions—can serve as additional fuel. Wearing a non-FR garment underneath a FR shirt will add comfort layers, but the exposed non-FR garment can be dangerous and is non-compliant with FR standards. Additionally, many non-FR winter base-layers are made from polypropylene and blends that contain polyester. Both of these materials have low melting points and can lead to tragic injuries if exposed to a thermal incident. Paragraph (l)(8)(ii)) of OSHA 1910.269 states employers must ensure that employees wear clothing that will not melt or ignite and continue to burn when exposed to flames or the estimated heat energy.

How to Select the Best FR Garment for the Job
Wear trials are the best way to evaluate the performance, comfort, usability, and applicability of any kind of personal protective equipment.

When selecting and specifying FR garments, there are often biases about brand and style that are made based on a wearer's taste in street clothing. These biases could lead to a poor decision for the workplace. While lab tests and promotional videos give an overview of prospective garments, performing a test on site helps put any hype aside to determine true performance. The right garment will be noticeably different than its competitors in performance and feel as a result of the wear trial.

Temperatures can play a key role in wear trials. For example, a utility in South Texas should run the wear trial in the intense heat of July instead of the cold month of January to evaluate the comfort of workers in high temperatures.

The Difference Between a Day on the Job and a Day in the Hospital
Without proper FR attire in arc flash incidents, a day on the job can quickly become a day in the hospital. With new OSHA regulations in effect as of August 2015, it is important for employers to take the steps necessary to educate themselves and their employees on FR garments. OSHA regulations outline not only the importance of selecting garments that will not melt onto the skin or ignite and continue to burn, but also the necessity for garments that meet the new arc flash requirements.

Keeping workers safe goes beyond just specifying FR. Employers should take into consideration how the garments fit, along with garment materials and how they perform in extreme temperatures. Lightweight, breathable and moisture-wicking garments with a high THL rating are ideal to comply with the new OSHA regulations and ensure utility workers' safety and comfort on the job.

References
1. OSHA FAQs
2. Fire Engineering
3. Extreme Physiology & Medicine

This article originally appeared in the August 2015 issue of Occupational Health & Safety.

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