Designing and Implementing an Arc Flash Clothing Program Understanding The Electric Arc Flash Hazard Background • Involved with the Flame Resistant Clothing market from the service, manufacturing and garment sides for over 20 years. • Over the past 11 years worked closely with fortune 1000 companies as they look develop PPE programs within their Electrical Safe Work Practices to comply with NFPA70E/NESC and also Flash Fire programs for NFPA 2113. • Developed and conducted over 250 educational and informational seminars on the Hazards of Arc Flash and Flash Fire for NSC, ASSE, VPPPA, NJATC, NECA, CAER and numerous other associations. Content • What is an Arc Flash? • Why AR/FRClothing? • Creating and AR/FR Program OSHA General Duty Clause • Employer’s responsibility / Choosing AR/FR “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm.” References OSHA: • 1910.132(a) – Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing,… • 1910.137 - Electrical Protective Equipment • 1910.147: LOTO • 1910.269: Power Generation & Distribution • 1910.331-.335 - ESWP • 1910.334 Use of equipment - Portable - Fixed Test • 1910.335 PPE & warning Arc Flash Event • A dangerous release of energy created by an electrical fault - Arc temp can reach 35,000 F • Release will contain: – – – – Thermal energy Acoustical energy Pressure wave Debris -Copper expands 67,000 times when vaporized • Fatal burns can and do occur at >10 feet What Equipment can Cause Arcs? • Typical equipment can be: – Motor Control Centers (MCC’s) – Circuit Breakers – Disconnects – Metering Devices (remove – install) – Panel Boards – Switchgear (low and high voltage) – Transformers Why is AR/FR Needed? • Most severe burn injuries and fatalities are caused by non-flame resistant clothing igniting and continuing to burn • Flame resistant clothing will selfextinguish, thus limiting the injury • Body area under non- AR/FR clothing is often burned more severely than exposed skin What Is a Burn? A chemical process which progressively injures skin; severity relates to depth 1st : redness, pain – not permanent 2nd: blistering – skin will regenerate 3rd: total skin depth destroyed. Will not regenerate – requires grafting 4th : Underlying muscle damaged Burn Survival • Burn percentage, more than severity, predicts survival because skin is infection barrier • 2nd and 3rd degree break skin, providing an infection pathway • Most hospital deaths 2-4 weeks post-exposure are infection Burn Injury – Chances of Survival % Survival 100 80 25% Body Burn 50% Body Burn 75% Body Burn 60 40 20 0 20 - 29.9 30 - 39.9 40 - 49.9 50 - 59.9 Age Range, Years American Burn Association 2000 - 2009 Burn Injury Costs • Burn treatment requires approx. 1.5 days hospitalization per % burn • Average hospitalization is 19 days, at costs exceeding $25,000/day • Total hospitalization cost typically ranges from $200,000 to $750,000, with many over $1,000,000 USD Burn Costs: AR/FR vs Non-AR/FR Accidents Before FR Accidents After FR Paid Reserve Medical Indemnity Vocational Expenses Total 562,677.78 52,182.14 2510.36 931.53 $618,301.81 250,000.00 721,431.00 7,438.00 0.00 $978,928.00 32,707.38 6,035.28 1,903.55 36.00 $40,682.21 Medical Indemnity Vocational Expenses Total 184,572.12 30,143.43 2,393.43 20.00 $217,128.98 124,999.00 19,226.00 7,606.00 0.00 $151,863.00 9,213.25 1,890.57 1,195.40 10.00 $12,309.92 Source: PECO Presentation by Bill Mattiford, PES-IEEE Seminar. What is Flame Resistant Clothing? • Clothing made from fabrics that self-extinguish • Fabrics may be natural or synthetic • Designed to limit (not eliminate) burn injury • Survival, extent of injury, recovery time and quality of life are all dependent on FRC performance “Primary” vs. “Secondary” • Primary Protective Clothing – Definition; “Clothing that is designed to be worn for work activities where significant exposure to molten substance splash, radiant heat, and flame is likely to occur.” Example- Firefighter Turnout Gear • Secondary Protective Clothing – Definition; “Clothing that is designed for continuous wear in designated locations where intermittent exposure to molten substance splash, radiant heat, and flame is possible.” What Flame Resistant Clothing is Not! Hierarchy of Controls • • • • Eliminate or replace Engineering Admin and/or policies PPE Arc Flash Incident – Chicago April 18, 2004 NFPA 70E • Standard for Electrical Safety in the Workplace • Covers industrial personnel – Electricians – Maintenance workers – Operators • • • • • NFPA 70E, Standard for Electrical Safety in the Workplace, developed by the National Fire Protection Association, is one of the foremost consensus standards for electrical safety. It covers employee protection from the electrical hazards of shock, arc flash and arc blasts. Although it is only referenced in OSHA 29 CFR Part 1910 Subpart S, Appendix A, NFPA 70E is considered by OSHA to be the recognized industry practice for electrical safety. In its standard interpretation of the relevance of NFPA 70E, OSHA states: Industry consensus standards, such as NFPA 70E, can be used by employers as guides to making the assessments and equipment selections required by the standard. Similarly, in OSHA enforcement actions, they can be used as evidence of whether the employer acted reasonably. And while the 2004 edition of NFPA 70E emphasizes that working on live parts is "the last alternative work practice," it contains extensive requirements for "working on or near electrical conductors or circuit parts that have not been put into an electrically safe work condition." When such work is to be performed, the required electrical hazard analysis has specific requirements for analysis of shock and flash hazards. Other sections provide guidance on selecting the proper PPE. Standard for Electricians NFPA 70E – – – – – – 2015 Edition updated 3 - 5 years Install, maintain, repair electrical system Arc Rated (ATPV and EBT) ASTM F-1506 3rd Party Testing Garments labeled Changes for 2012 The 2012 Edition of NFPA 70E has been published and there are a large number of changes. There are a few key changes related to arc flash protective apparel. The three most notable are: • • • First the terms Arc Rated & AR have replaced Flame-Resistant & FR. This is an attempt to prevent the use of garments using fabrics that use the term FR but have not actually been tested to establish an arc rating. This was done because there are flame-resistance tests used for products like draperies that are not suitable of arc protection but have been sold as “FR.” Users therefore assumed they provide protection against electric arc flashes. The change does not require a garment be labeled as AR versus FR but does require the garment to have been arc tested and adhere to ASTM F1506 which requires it to be labeled with the arc rating (cal/cm² or EBT.) Second is the consolidation of Hazard Risk Categories 2 and 2*. By doing this, HRC 2 now requires the use of either an arc rated wrap-around face shield and arc rated balaclava, or an arc rated flash suit hood. Previously only an arc rated face shield was required. This was done to provide full head protection. With the face shield alone the sides and back of the head were not protected. The standard now states that flammable synthetic fabrics, zipper tape and findings shall not be used. Previously it only referred to synthetic fabrics, not findings. This was done to specifically address the use of none FR zipper tape and other findings that could fail in an arc flash event. 25 Changes 2015 Edition The 2015 edition of NFPA 70E reflects a major shift in how stakeholders evaluate electrical risk. In support of this, new definitions were added to Article 100, including Hazard, Hazardous, Risk, and Risk Assessment. Throughout the document changes were made to provide clarity to users, such as changing “arc flash hazard analysis” to “arc flash risk assessment,” “shock hazard analysis” to “shock risk assessment,” “electrical hazard analysis” to “electrical hazard risk assessment,” and “hazard identification and risk assessment” to “risk Why 100% Cotton Is not safe! Definitions • Hazard. A source of possible injury or damage to health. • Hazardous. Involving exposure to at least one hazard. • Incident Energy Analysis. A component of an arc flash risk assessment used to predict the incident energy of an arc flash for a specified set of conditions. • Risk. A combination of the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health that results from a hazard. • Risk Assessment. An overall process that identifies hazards, estimates the potential severity of injury or damage to health, estimates the likelihood of occurrence of injury or damage to health, and determines if protective measures are required. Article 130 – Work involving Electrical Hazards Changes • 130.5 Arc Flash Risk Assessment. An arc flash risk assessment shall be performed and shall: (1) Determine if an arc flash hazard exists. If an arc flash hazard exists, the risk assessment shall determine: a. Appropriate safety-related work practices b. The arc flash boundary c. The PPE • (A) Documentation. The results of the arc flash risk assessment shall be documented. • (C) Arc Flash PPE. One of the following methods shall be used for the selection of PPE. Either, but not both, methods shall be permitted to be used on the same piece of equipment. The results of an incident energy analysis to specify an arc flash PPE Category in Table 130.7(C)(16) shall not be permitted. (you either use the info from your risk assessment to determine the level of PPE or use the tables to select PPE category) Article 130 – Work involving Electrical Hazards Changes • (1) Incident Energy Analysis Method. The incident energy exposure level shall be based on the working distance of the employee’s face and chest areas from a prospective arc source for the specific task to be performed. Arc-rated clothing and other PPE shall be used by the employee based on the incident energy exposure associated with the specific task. Recognizing that incident energy increases as the distance from the arc flash decreases, additional PPE shall be used for any parts of the body that are closer than the distance at which the incident energy was determined. Informational Note: For information on estimating the incident energy, see Informative Annex D. For information on selection of arc-rated clothing and other PPE, see Table H.3(b) in informative Annex H. • (2) Arc Flash PPE Categories Method. The requirements of 130.7(C)(15) and 130.7(C)(16) shall apply when the arc flash PPE category method is used for the selection of arc flash PPE. Article 130 – Work involving Electrical Hazards - Changes 130.7 Personal and Other Protective Equipment. • (9) Factors in Selection of Protective Clothing • (d) Coverage. Clothing shall cover potentially exposed areas as completely as possible. Shirt and coverall sleeves shall be fastened at the wrists, shirts shall be tucked into pants, and shirts, coveralls, and jackets shall be closed at the neck. New Simplified Tables - New Tables for AC and DC Systems Table 130.7(C)(15)(A)(a) Arc Flash Hazard Identification for Alternating Current (ac) and Direct Current (dc) Systems New PPE Category Task Tables Table 130.7(C)(15)(A)(b) Arc-Flash Hazard PPE Categories for Alternating Current (ac) Systems Table 130.7(C)(15)(B) Arc-Flash Hazard PPE Categories for Direct Current (dc) Systems Article 130 – Work involving Electrical Hazards Changes Table 130.7(C)(16) Personal Protective Equipment (PPE) • HRC (Hazard Risk Category) has changed to PPE Category • HRC 0 – has been removed Simplified Task Table for AC and DC to determine if Arc Flash PPE is required Simplified Task Table to determine the level of PPE Category Annex - H To be used in conjunction with the tables – If tables show no PPE needed for task – non FR, nonmeltable garments can be used When Incident Energies are known and the IE is below 1.2cal/cm2 – only then is non FR non meltable garments are allowed NFPA 70E Categories One needs an Energized Work Permit NFPA 70E Hazard Analysis Three Options Available • Calculate specific equipment hazard and match Arc Rating of clothing to hazard • Use task based matrix to determine hazard risk category of job • Simplified two category approach in Annex H ANSI Z535.4 Safety Label. • Warning Arc Flash and Shock Hazard Appropriate PPE Required Arc Flash Protection.. Simplified Approach to Compliance PPE C 1 PPE C 2 PPE C 4 41 Hazard/Risk Categories defined…… PPE Category Clothing Description Req’d Min ATPV (cal/cm2) 1 Arc-rated FR shirt and FR pants or FR coverall 4 2 Arc-rated FR shirt(s) and FR pants or FR coverall 8 3 Arc-rated FR shirt and pants or FR coverall and arc flash suit selected so that the system arc rating meets the required minimum 25 4 Arc-rated FR shirt and pants or FR coverall and arc flash suit selected so that the system arc rating meets the required minimum 40 Big Change in 2015 • Hazard/risk category 0 has been removed from Table 130.7(C)(16). Hazard/risk category will now be referred to as PPE category. • Hazard/risk category 0 was deleted because the new PPE table only specifies PPE for work within the arc flash boundary. If there is no arc flash hazard, then no arc flash PPE is required and it is therefore not necessary on a table devoted to PPE. [Table 130.7(C)(16)] NFPA 70E Changes important to workers wearing flame resistant apparel include the following: 1. Terminology Change: PPE Category has replaced HRC – According to note (14) on page 7, “Hazard/risk category [HRC] will now be referred to as PPE category.” Hazard Analysis now referred to as Risk Assessment - NFPA 70E 2015 edition defines Risk Assessment as “An overall process that identifies hazards, estimates the potential severity of injury or damage to health, estimates the likelihood of occurrence of injury or damage to health, and determines if protective measures are required.” (p. 17) Risk Assessment is further examined in the footnote to Table 130.7(C)(15)(A)(a): “Hazard identification is one component of risk assessment. Risk assessment involves a determination of the likelihood of occurrence of an incident, resulting from a hazard that could cause injury or damage to health.” 2. A Change to “Coverage” Requirements: In section (d) on page 31, “Coverage,” a couple of changes can be seen - The word coverall was added to two parts: “Shirt and coverall sleeves shall be fastened at the wrists…” “…shirts, coveralls, and jackets shall be closed at the neck.” Additionally, a statement was added, “shirts shall be tucked into pants…” The second change to “Coverage” requiring shirts to be tucked into pants is in-line with OSHA’s recent updates to standard 29 CFR 1910.269. According to e-Hazard, “NFPA 70E helps employers meet the performance requirements of the OSHA standards for electrical safety. (1)” To further assist employers in understanding what is required under OSHA’s standard pertaining to arc-rated PPE maintenance and inspection. 3. Elimination of HRC 0 According to note (14) on page 7, “Hazard/risk category 0 has been removed from Table 130.7(C)(16)… Hazard/risk category 0 was deleted because the new PPE table only specifies work within the arc flash boundary. If there is no arc flash hazard, then no arc flash PPE is required and it is therefore not necessary on a table devoted to PPE.” 4. New Arc Flash PPE Category Tables: 130.7(C)(15)(a) and (b) The NFPA 70E Technical Committee has agreed to a new format for choosing arc-rated clothing and PPE. Details of the impending changes were outlined clearly in this May ISHN article. Predicted changes reflected in the updated standard include splitting Table 130.7(C)(15)(a) into two. The first table is used to determine if an arc flash hazard exists. One of the complaints about the previous table method was that tasks that do not pose an arc flash hazard are listed in the table – hence the decision to remove PPE Category/HRC 0. Under the new table method, if there is an arc flash hazard, you must wear the required PPE and arc-rated clothing matched to the hazard (3). • OSHA is the “SHALL” • NFPA 70E is the “HOW” – Industry consensus standards, such as NFPA 70E, are used in OSHA enforcement actions as evidence as to whether the employer acted reasonably Industries Requiring AR/FR Clothing Manufacturing Food Paper Chemicals Machinery Electronics Transportation Universities Hospitals Hospitality Equipment Failure – When any piece of the equipment or system fails, all calculations and predictions fail with it. By definition, one can no longer be certain of maximum possible incident energy, or, by extension, probability of ignition of non FR cotton. Testing Video Arc Flash Slo Mo The details of injury and long term effects • 2 workers suffered more than 60% 2nd and 3rd degree body burn. • One subjected to induced coma for 60 day period • 3rd worker treated and released, today experiencing long term neurological problems – “similar to shaking a baby” • Worker pulling off hard hat – mesh liner and helmet plastic harness melted – requiring surgical removal • Incident energy calculated to approx. 22.7 cal/cm² HRC 2 Arc with FRC OSHA Requirements • The General Duty Clause requires work places free from recognized hazards • The general Duty Clause requires employees to comply with the rules pursuant to the Act. • The specific Duty Clause requires employers to comply with OSHA Standards How large is the problem? • According to CapSchell, Inc., a Chicago-based research and consulting firm that specializes in workplace injury prevention, there are five to 10 arc flash explosions every day in the United States, resulting in 1 to 2 deaths. • Moreover, over the course of a seven-year study tracking electrical accidents conducted by the U.S. Department of Labor’s Bureau of Labor Statistics, 2,576 U.S. workers died and another 32,807 were injured -- losing an average of 13 days away from work -- due to electrical shock or burn injuries. • A second study involving more than 120,000 employees determined arc flash injuries accounted for 77% of all recorded electrical injuries -- The final cost to employers and their insurers for a single, serious injury can approach $10 million. (CapSchell) -- 2,000 workers are admitted annually to burn centers for extended injury treatments caused by arc flash, according to the U.S. Department of Labor. • A recent study from the National Institute for Occupational Safety and Health (NIOSH) determined 17,101 injuries were caused by electric arc flash burns between 1992 though 2001. OSHA alleges safety violations at MillerCoors 08/04/2009 • • • • • • • • • (AP) – 19 hours ago DENVER — Regulators have proposed fining MillerCoors $128,500 over alleged safety violations at its brewery in Golden. The Occupational Safety and Health Administration said Monday a maintenance electrician who was missing for several hours was found dead outside an open, energized electrical panel Feb. 2, and two others were burned by an electrical arc flash April 9. OSHA investigators in the fatal accident found inadequate safety measures for electrical hazards, but coroner's officials couldn't determine if that led to the death, said John Healy, OSHA's area director in Englewood. OSHA cited MillerCoors LLC for 10 alleged violations of rules for electrical hazards. That included one alleged willful violation over allegations that MillerCoors failed to ensure employees used proper protective equipment when working near energized electrical parts. OSHA also alleged nine serious violations over work practices and protective equipment. A MillerCoors spokesman didn't immediately return a phone message seeking comment. MillerCoors received the citations Friday and has 15 business days to contest the findings, Healy said. "We found dangerous conditions that existed at MillerCoors in the area of electrical work," Healy said. "The company does need to take necessary steps to mitigate workplace threats to ensure the safety of the work force." Contractor Faces $148,000 in Fines Following Arc Flash Injury OH&S 9/6/09 • • • • • OSHA has proposed $148,000 in fines against C.W. Pond Contractors Inc., a Norwalk, Conn., electrical contractor, in connection with a March 4 electrical fire at the Old YMCA at 980 Washington Blvd. in Stamford, Conn. Two apprentice electricians were working on and around an energized 480 volt electrical distribution panel when an electrical arc flash and blast occurred, burning one of the workers. OSHA's investigation found that the panel had not first been de-energized before being worked on, as required, and the employees had not been supplied with the required personal protective equipment. As a result of these conditions, OSHA has issued C.W. Pond Contractors two willful citations, carrying $140,000 in proposed penalties. OSHA defines a willful violation as one committed with plain indifference to or intentional disregard for employee safety and health. The contractor also has been issued one serious citation, with a $7,000 fine, for not training employees on safety-related electrical work practices, and one other-than-serious citation with a $1,000 fine for an incomplete illness and injury log. Serious citations are issued when death or serious physical harm is likely to result from hazards about which the employer knew or should have known. "The lethal potential of electricity cannot be underestimated. This accident could easily have resulted in a double fatality, as electricity moves--and can kill--at the speed of light," said Robert Kowalski, OSHA's area director in Bridgeport. "Due to the grave nature of these hazards, we are proposing the maximum fines allowed under the law." Creating an FRC Program • Hazard Assessment • PPE Selection – Protection – Comfort – Value • Care and Maintenance The Next Step • Already performed hazard analysis • Decided level of protection needed, i.e. Arc Ratings • Clothing must be chosen – – – – Everyday garments Arc flash suits Outerwear? Layering to meet levels Engineered Flame Resistant Fabrics • Natural fibers • Synthetic fibers • Natural / synthetic blends NOTE: Flame resistance must be durable to launderings, wear, the environment, etc. for the service life of the garment All – FR fabrics are engineered do not let marketing terms confuse you – inherent –treated etc. Look for proven products! Comfort – The Bottom Line • Never make comfort decisions from graphs, data, office samples or appearance • There is simply no substitute for a wear test Proper Use • • • • • • AR/FR should be appropriate to hazard Always the outermost layer Worn correctly; zipped, buttoned, etc All natural, non-melting undergarments Clean, no flammable contaminants Repaired correctly and removed from service when needed Don’t let this be your Legacy Maintenance of FRC • Garments should be cleaned to maximize performance • Contaminants can “mask” or negate flame resistance • Care choices – Home laundry – Industrial Laundry – Dry-cleaning Significant 2015 Changes • New PPE Category Tables – No Hazard Risk Categories???? • HRC 0 Eliminated – How are we going to sell clothes???? • Prohibitive Approach Boundary Eliminated • Arc Flash risk is now based on a Risk Assessment for each piece of equipment Summary • Objections to AR/FR are usually based on either cost or comfort… • Durability, productivity and liability issues reduce real over-time cost of AR/FR to, or below, non AR/FR cotton in energized environments • Wear tests and current programs clearly show comfort of newer generation AR/FR clothing is equal to like weights of non AR/FR cotton clothing • Get your assessment done – know your hazard • Any AR/FR is better than No AR/FR • Get your layering solutions tested The Bottom Line Incidents & Accidents Happen “Street Clothing” can and does worsen injury You Can’t Rely on “It’s Not Going to Happen to Me” You Can Do Something About Your Clothing Remember…. Thank You! Questions & Discussion Bulwark Protective Apparel Derek Sang [email protected] Be very cautious in Rainwear and Vests Rainwear has specific standards for both Arc Flash and Flash Fire FR Rainwear claims can and are very misleading Do not jeopardize your safety and your FR/AR program by implementing noncompliant Rainwear and/or vests Rainwear and vests that are marketed as FR should not be used in a Flash Fire – do your homework Make sure to match the Rainwear to the hazard – for Arc Flash ASTM 1891 and they will have an ATPV and for Flash Fire ASTM 2733 better yet get raingear that is tested to both Don’ts What could be wrong here??? Always – rolled, tucked and buttoned! Care Essential to your PPE’s performance and life expectancy is caring for your garments Objectives • Be able to identify additives that cannot be used on your FR/AR garments • To be able to understand and recognize the effect of stains and secondary accelerants on your FR/AR garments 1910.132(f)(1) The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following: 1910.132(f)(1)(i) - When PPE is necessary; 1910.132(f)(1)(ii) - What PPE is necessary; 1910.132(f)(1)(iii) - How to properly don, doff, adjust, and wear PPE; 1910.132(f)(1)(iv) - The limitations of the PPE; and, 1910.132(f)(1)(v) - The proper care, maintenance, useful life and disposal of the PPE. 1910.132(f)(2) - Each affected employee shall demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE. • Important to read the manufacturers laundry instructions on the label • Written care instructions are available for all employees. • They can also be accessed at: http://www.bulwark.com/Safety-Care The Top 3 – 1. Do not use chlorine bleach, peroxide or fabric softener 2. Do not wear if soiled with flammable contaminants 3. Retire garment if worn out Soiled Garments • Monitor the accumulation of secondary accelerants on your garments through out the day. • After laundering make sure accelerants are removed. If your garments still have a hydrocarbon/petroleum odor a flammable contaminant may still be present, rewash the garment until the odor is gone. If flammable soils are not completely removed, the protective qualities of the garment may be compromised. • Discoloration/stains alone are not an indicator of reduced protection How Much is too much???? Laundering Guidelines • Wash FR/AR garments separately • Turn FR/AR garments inside out both assist in color retention and appearance • Use liquid detergent for best results • Avoid the hottest temperature to reduce the impact of shrinkage • For tough stains applying liquid detergent to the stain or stain remover and allow garment to soak • Bulwark FR/AR garments can be dry cleaned for tougher stains • Tumble dry on low setting and do not over dry What can you Use?? The No’s Important to Read the Label Maintenance Objectives • Identify when garments need to be repaired and or replaced • Understand proper repair process for your FR/AR Garments Inspect garments daily – • Check for holes, rips and tears • Check for areas of heavy wear such as elbows and knees where the fabric may be worn thin • Check the integrity of the seams In general check the integrity of the garment and repair or replace accordingly Inspecting Garments - General • Evaluate fit • Worn correctly: shirts are tucked in, sleeves are rolled down, cuffs are buttoned and shirts are buttoned up (second button from the top) • Outermost layer is FR/AR • Wear and tear - thin spots, holes, abrasions, rips, and/or tears, check for open seams • No Alterations or modifications • Not soiled with oils, greases and/or other flammable contaminants • The easiest time to inspect FR/AR Clothing is just before you put it on in the morning • However make sure that you are vigilant throughout the day to avoid common errors in proper wear • Repair garments with like materials and FR threads • If that is not possible retire the garment and replace What to ask for: • To see the UL Certification or other independent organization on that particular garment • Specify only certified compliant garments are allowed on site • Ask for the test data most fabric suppliers have data sheets with the most common test results • Work with a proven supply chain • Periodically police your program for compliance Questions, Comments, Feedback? Bulwark University Thank You From Your Bulwark Team Property of Bulwark, not for reproduction without written permission
© Copyright 2026 Paperzz