Being Compliant With
OSHA 1910.269 &
Developments
In FR Workwear
Presented By
Gary Zumstein
February 17, 2016
OSHA ACT 1910
• Under the OSH Act, employers are responsible for providing a
safe and healthful workplace.
• OSHA's mission is to assure safe and healthful workplaces by:
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Setting and enforcing standards
Providing training
Outreach
Education
Assistance
• Employers must comply with all applicable OSHA standards.
• Employers must also comply with the General Duty Clause of the
OSH Act, which requires employers to keep their workplace free
of serious recognized hazards.
SUBPART RR –– SPECIAL
SPECIAL INDUSTRIES
SUBPART
INDUSTRIES OF
OF 1910
1910
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1910.261
1910.262
1910.263
1910.264
1910.265
1910.266
1910.267
1910.268
1910.269
1910.272
Pulp, paper, and paperboard mills
Textiles
Bakery equipment
Laundry machinery and operations
Sawmills
Logging operations
[Reserved]
Telecommunications
Electric power generation, transmission & distribution
Grain handling facilities
The federal regulation (law) defines practices of employees working in the
generation, transmission and distribution of electricity.
OSHA 1910.269
• On April 11, 2014, OSHA published to the Federal Register
the final rule revising 29 CFR 1910.269 which updates the
standard providing electrical safety guidance for those in
the operation and maintenance of electrical power.
• This revision updates a 40-year old standard (1974) and
incorporates major changes to PPE (Personal Protective
Equipment), including FR clothing, which impacts the
employer.
• All the published changes 1910.269 are still being
implemented as there have been delays in enforcement of
the guidelines.
So what prompted OSHA to
make changes in 1910.269?
OSHA estimates that the revised ruling will save more
than 20 lives and prevent 118 serious injuries each year.
PROTECTING UTILITY LINEMEN
• Out of a group of 100,000 workers, about
30 to 50 are killed every year doing utility
line work.
• Many more suffer non-fatal but lifechanging injuries.
• The fatality rate is more than twice that
of police officers & firefighters making
utility line work one of the ten most
dangerous jobs in the US.
Sourcing from ISHN article found in
the January 2016 publication
PROTECTING UTILITY LINEMEN
• About 75% of arc flash incidents occur
when a worker is near the equipment.
• The Fire Protection Research Foundation
reported two-thirds of the workers
involved in arc flash incidents were
injured when companies failed to conduct
an arc flash analysis for selecting PPE.
• A separate study found that 40% of
electrical accidents involved 250 volts or
less.
Sourcing from ISHN article found in
the January 2016 publication
HOW WAS FR CLOTHING ADDRESSED IN THE
PAST REGULATIONS?
• It did not mandate the use of FR /
Arc rated clothing. It did say that
the clothing would not contribute
to the burn injury caused by being
exposed to an arc flash.
• It previously allowed the use of
clothing made of heavy fabrics,
such as denim jeans, made of
natural fiber which were not
treated.
REASON FOR CHANGES IN OSHA 1910.269
WOULD YOU PREFER TO WEAR THIS?
WOULD YOU PREFER TO WEAR THIS?
OR HAVE THIS OUTCOME INSTEAD?
These are survivable injuries.
Can you imagine what the individuals looked like that did not?
PROTECTING UTILITY LINEMEN
• Based on the previous data presented, it had become
apparent that more had to be done to protect the
utility linemen in their working environment.
OSHA 1910.269 FOCUS
• My focus in today’s presentation
– Employer’s responsibility
– Employer’s / contractor’s
responsibility
– Employee’s responsibility
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PPE requirements
– Boots
– Face shield / balaclavas
– Gloves
– ARC & FRC Clothing
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Caring for PPE
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Selecting the right PPE
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ANSI 107
IN GENERAL, AN EMPLOYER MUST:
• Assess the workplace to identify employees
exposure to hazards from flames or from
electric arcs.
• Make reasonable estimates of the incident
heat energy of any electric-arc hazard to
which an employee would be exposed.
• 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 estimated heat energy.
IN GENERAL, AN EMPLOYER MUST:
• Ensure that the outer layer of clothing
worn by an employee is flame resistant
under certain conditions to 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.
• Assure that all working contractors abide
by the same workplace hazards as it still is
the employers responsibility to assure
both contractors and their own workers
are protected against the hazard.
NEW MINIMUM PROTECTION
• Among the changes incorporated into
the revised ruling, employers are to
provide head-to-toe FR / Arc rated
clothing for all hazards.
• This requirement for full body
protection means that workers will
now be required to wear:
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FR pants
Balaclavas / face shields
Boots
Gloves
• In addition to FR shirts and coveralls
already commonly provided.
ARC RATED PPE – CLOTHING STANDARDS
• Requires FR clothing for incident energy exceeding
2.0 cal/cm2 or above 600 volts.
• Protection for head and face.
• Starts at 9 cal/cm2 for single-phase arcs in air.
• Starts at 5 cal/cm2 for other exposures.
• Protection for hands (rubber gloves with protectors
or, for exposures ≤ 14 cal/cm2, heavy-duty (12-oz)
leather work gloves)
• Protection for feet (heavy work shoes or boots)
THE REQUIREMENTS FOR FEET PROTECTION
• When the employee is wearing heavyduty work shoes or boots, arc rated
protection is not necessary.
• Payment of the work shoe or boot.
– The employer is not required to
pay for non-specialty safety-toe
protective footwear.
– If the employer requires EH-Rated
boots or dielectric overshoes, then
the employer could be responsible
for payment.
THE HEAD PROTECTION REQUIREMENTS
• A face shield with a minimum arc rating
if 8 cal/cm2 for single-phase open-air
exposure greater than 9 cal/cm2 greater
than 5 cal/cm2
• An arc rated balaclava is required for
single-phase exposures greater than 13
cal/cm2 three-phase exposure greater
than 9 cal/cm2
• Balaclava arc rating must be a minimum
of 4 cal/cm2 less than the exposure.
• No head protection is required for
single-phase exposure of 4 cal/cm2 or
less.
REQUIREMENTS FOR HAND PROTECTION
• Arc rated protection is not
necessary for the employee’s
hands when wearing rubber
insulation gloves with
protectors, or the estimated
incident energy is no more
than 14 cal/cm2, heavy-duty
leather work gloves with a
weight of at least 12 oz./yd2
ARC RATED & FR CLOTHING IS NOW TREATED AS PPE
• OSHA now believes that it is
reasonable and appropriate
to treat FR and arc-rated
clothing required by the
revised ruling as PPE.
• This will be reflected as an
increase to allowances
and/or by adding additional
items to approved clothing
selections for employees.
COST OF CHANGES TO 1910.269 TO EMPLOYERS
• OSHA specifically addresses the total estimated
cost for FR clothing
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Final Rule at an annualized cost of
approximately:
– $452.88 per employee.
– OSHA is basing its estimates on a cost of
$1,534 per employee for eight sets of flame
resistant clothing.
– Estimated cost of $191.75 per set or on the
approximate annualized cost per employee.
– The agency believes this final estimate is
reasonable and captures the average cost of
all flame-resistant clothing required by the
new provisions of the final standard.
OSHA SUPPORTS HOME LAUNDER
• While the designation of FR
clothing as PPE requires
additional employer oversight,
it is clear OSHA allows home
laundering of FR clothing. The
final rule does not require
employers to launder
protective clothing for
employees.
• Home / Industrial laundry is
acceptable.
EMPLOYER RESPONSIBILITY FOR CARE &
MAINTENANCE OF FR CLOTHING
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OSHA explains that if employers rely on
home laundering of FR clothing, they must
train their employees in proper laundering
procedures and techniques.
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Not only training required but has to be
documented.
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Employers must inspect the clothing on a
regular basis to ensure that it is not in need
of repair or replacement.
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It is the responsibility for maintaining PPE
rests squarely with the employer under
existing OSHA standards.
– Home laundry
– Industrial laundry
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Experienced FRC suppliers offer guidance
and support on training end users.
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Also applies to contractors.
LAUNDRY STANDARD GUIDANCE
• ASTM F2757-09: Standard guide for
home laundering care and maintenance
of flame, thermal and arc resistant
clothing.
• ASTM F1449-01: Standard care and
maintenance of flame, thermally and arc
resistant clothing for industrial laundry.
• NFPA 2113: Standard on selection, care
use and maintenance of FR garments for
protection of industrial personnel against
short-duration thermal exposures.
ASTM F2757-09
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Standard Guide for Home Laundering Care and Maintenance of Flame, Thermal and
Arc Resistant Clothing
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This guide provides recommendations for home laundering of clothing that is flame,
thermal, and arc resistant.
This guide does not apply to dry cleaning of flame, thermal, and arc resistant clothing.
For more information on dry cleaning, follow label instructions or contact your
garment supplier or fabric manufacturer.
This guide does not apply to industrial laundering of flame, thermal, and arc resistant
clothing. For more information on industrial laundering, follow Guide F 1449 or
contact your garment supplier.
When garments are laundered properly, using the proper detergent, home laundering
is an effective cleaning process.
It is important that potentially flammable contaminants are removed from garments
during the wash process. If flammable contaminants are not removed, the flame
resistance of the garment may be compromised.
To reduce the potential of employees wearing garments contaminated with
flammable substances, the end user should analyze the soil conditions to which a
worker may be exposed, along with the effectiveness of the wash procedure. In the
event home laundering is deemed ineffective, alternative solutions should be pursued
(dry cleaning, industrial laundering, disposable FR coveralls, etc.).
Certain laundry chemicals that may have an adverse effect on fabric flame resistance
are identified in this guide and should not be used.
This guide does not apply to specialized protective garments such as specialized
firefighter turnout gear and proximity firefighter ensembles.
This guide also provides recommendations for inspection criteria that are significant
to the performance of flame, thermal, and arc resistant clothing.
ASTM F1449-08 (2015)
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Standard Guide for Industrial Laundering of Flame, Thermal &
Arc Resistant Clothing
– This guide identifies the responsibilities of the fiber, fabric, and
clothing manufacturers, as well as the processor, the processor's
chemical supplier and the end user.
– This guide describes the key components involved in a program
for the care and maintenance of flame, thermal, and arc resistant
clothing.
– The guidelines in this standard will provide a processor assistance
to develop a processing system that maintains the flame,
thermal, and arc resistant characteristics of the clothing during its
useful service life.
– The development of published formulas for each fabric and level
of soiling is difficult at any given point in time due to ongoing
continuous improvement of flame, thermal and arc resistant
clothing, including new fibers, fabrics, and laundering equipment
and procedures.
– The guide also provides suggestions as to when flame, thermal,
and arc resistant garments should be removed from service.
ASTM LAUNDRY GUIDES
• Basically offer formula advice and
recommend against:
– Chlorine bleaches or liquid nonchlorine bleaches
– Fabric softeners
• Liquid during washing
• Dryer sheets
– Starch
– Not cleaning garments on a
regularly or daily basis.
HOME LAUNDRY MAINTENANCE OF FR GARMENTS
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Wash FR garments separately in a normal water temperature
up to a maximum of 140ºF (60ºC).
Use any typical home laundry detergent. Do not use soap
(tallow soap containing animal fats).
DO NOT use chlorine bleach or liquid non-chlorine bleach.
Do not use:
– Starch
– Fabric softeners or dryer sheets
The use of conditioned or soft water can help improve removal
of contaminants from garments.
It is important that all soils and other contaminants are
completely removed from garments during the wash process.
– This may require the use of stain removal products or
presoaking garments prior to washing.
– The use of hot water can often make detergents more
effective in the removal of soils.
Rise garments thoroughly after wash cycles.
Do not over dry garments. If desired, you may press with an
iron on the Permanent Press/Low setting.
Always consult the garment manufacturer for detailed
instructions and precautions.
STAIN REMOVAL MAINTENANCE OF FR GARMENTS
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If garments become contaminated with flammable substances, they
should be removed immediately and replaced with clean flame
resistant apparel.
– Either home or industrial laundering may successfully remove
most types of both flammable and non flammable soils.
However, home laundry detergents may not successfully
remove some types of soil found in industry, especially heavy
greases and oily soils. If flammable soils are not completely
removed, the flame resistance of the garment may be
compromised.
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It may be difficult to determine that flammable soils have been
completely removed, but indicators would include the presence of
stains and/or odors after laundering. However staining alone is not
an indication that the soil has not been adequately removed. If it
appears that the garments may still be contaminated after home
wash, laundering at a local commercial or industrial laundry may be
required. Dry cleaning may be used to remove oils and greases.
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Flammable materials are for the most part volatile substances that
dissipate into the atmosphere, for example, gasoline. Stains
remaining after laundering on the other hand are either un-removed
contaminants or, more likely, simply discoloration of the fabric.
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Always consult the garment manufacturer for detailed instructions
and precautions.
REPAIR & MAINTENANCE OF FR GARMENTS
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ASTM International has developed two standards for repair and
maintenance of FR garments.
– Standard F 1449 Guide for Industrial Laundering of Flame,
Thermal and Arc Resistant Clothing, covers maintenance of
garments by industrial laundries.
– Newly adopted Standard F 2757 Guide for Home Laundering
Care and Maintenance of Flame, Thermal and Arc Resistant
Clothing provides information for home care and maintenance
of flame resistant protective garments.
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Specific guidelines on repairs except to follow the ASTM standards.
This would also apply to zippers and any other trim or findings item
that needs to be replaced. Technical Bulletins that provide detailed
laundry and dry cleaning recommendations are available for each
type of fabric used.
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Essentially, all repairs must be made with materials equivalent to the
original materials in the garments.
– FR sewing thread (Such as Nomex or Kermel) and FR mending
fabrics equal to the materials used in the original garment.
– Heat seal FR patches are available and are often used to make
small repairs.
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Always consult the garment manufacturer for detailed instructions
and precautions.
AFTER ALL THE TRAINING
• Do not directly spray
items such as DEET
onto your FR
garments.
• Items such as DEET are
highly flammable and
can contribute to the
hazard by burning.
IMPROVEMENTS IN
FR FABRICS & GARMENTS
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More selection in fabrics being offered
in both:
– Treated
– Inherents
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Insect protection
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Wickable finishes
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Waterproof / breathable
New blends of FR fibers made available
from around the world has allowed
fabrics to:
– Increase protection
– Increase comfort
– Reduce weight
– Increased durability
• Abrasion
• Chemical
– Improved colorfastness
• Washing
• UV
– Multi-hazard protection
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Water repellent
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Garment designs
– For both men and women
– Venting
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Layering options
– Increase protection
– Lower overall weight of the system
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Giving the wearer a wide range of cost
options, level of protection and quality.
Chose wisely in your PPE
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RECOGNIZING SECONDARY/PRIMARY PROTECTION
Primary and secondary refer to the “degree of protection” provided rather than
frequency of use or order in which the garments are put on.
Secondary Protection/ Daily Wear
• FR garments, mainly
coveralls or shirts/pants,
are worn daily in
potentially hazardous
environment
Primary Protection / put on for a specific
job function
• Protective garments,
gloves, hoods, face
shields, etc. worn where
significant exposure to
fire hazards is likely to
occur
• Are comfortable & look
like regular work clothes
• Usually for occasional,
not daily, wear
• Most FR garments are for
secondary protection
• Less comfortable than
secondary protective FR
• Hi-vis garments that both
FR and also meet ANSI
requirements.
• Often worn over
secondary protective FR
• Hi-vis vest
ONE ALSO HAS TO COMPLY TO ANSI 107
• When working within 50 feet of a road or
highway one must comply to ANSI 107
for hi-vis.
• While on the ground the worker must
wear the proper ANSI Class garments that
meets the workplace environment.
• Worker can comply by either wearing
daily wear which meets the ANSI 107 or
put on a FR hi-vis vest that meets ANSI
107 and is arc rated.
ANSI 107 & OSHA 1910.269
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FR Hi-Vest being worn over FR daily wear must also
comply:
– Cal rating of 2.0 cal/cm2 which means it contains
an arc rating
– Should not contribute to the hazard
– If a vest is to be labeled FR it must meet this
section which uses ASTM 1506 as the basis for its
FR provision.
– This is significant because the fabric is no longer
allowed to melt and drip in order to meet previous
FR thresholds.
– Vests claiming an FR capability like NFPA 701 will
no longer be considered FR or to be ANSI
compliant.
– FR treated nylons and polyesters are no longer be
compliant.
REASON FOR CHANGES IN OSHA 1910.269
IN SUMMARY
• New OSHA regulations for 1910.269 have been written to
help improve safety in the workplace.
• The employer is responsible:
– Risk assessment of the worksite for both their employees
and contractors
– Purchase PPE for their workers
– Properly train employees
o How to wear PPE properly
o How to care for their PPE including washing at home
• Lots of development has taken place in PPE to increase
protection along with improving comfort.
THE “NEW” OSHA RULES FOR ELECTRIC
COOPERATIVES
The ‘New” OSHA Rules for Electric Cooperatives
Thursday, February 18th, 2016
9:15 am – 10:15 am
Overview:
– On April 11, 2014, OSHA published the long awaited changes
to OSHA regulations (sections 1910.269 and 1926). The Final
Rule, consisting of more than 400 pages in the Federal
Register, sets forth new requirements for electric
cooperatives and other utilities when it comes to sharing
information with contractors, fall protection, minimum
approach distances and arc flash protection. Implementation
dates were pushed back several times by OSHA but the new
rules are now in full effect. Come hear David Wallis, a 40 year
OSHA veteran and author of the rule, discuss the new
requirements. This is your chance to ask any and all
questions about what the rule requires.
Instructor:
David Wallis, Occupational Safety and Health Administration (Retired)
Thank You!