Electrical and Utility workers, specifically those who work around high voltage (600+ volts) electrical components, those who work near electrical arcs and flammable substances that could ignite, as well as persons who work with molten metal, are at an increased risk for suffering severe and life-changing burn-related injuries. Various safety institutes, specifically the Occupational Health and Safety Administration (“OSHA”), have certain standards for requiring the use of Flame-Resistant (“FR”) Clothing by workers. OSHA requires employers to provide workers with FR Clothing who work under these conditions.
Generally, FR clothing is defined in the U.S. as clothing made from the fabrics that self-extinguish once the source of ignition is removed. However, the specific definition varies among industries.
OSHA Requirements for FR Clothing
For FR Clothing, OSHA requires employers do two things:
- Train their workers about the hazards associated with their jobs so that workers will know when FR Clothing is required, and
- Ensure that their workers are wearing the proper clothing required by the hazards associated with their jobs.
If an employer fails to enforce proper safety standards, they could be held liable by an employee who is injured after an accident occurs on the job. Employers are required to ensure that all FR Clothing worn by their employees meets OSHA standards, is in functional condition, and is not too worn, rendering it ineffective during a fire or when workers are exposed to high temperatures. Additionally, since FR properties can be compromised due to incorrect repairs or laundering – or simply by repeated washings – employers should instruct their workers on the proper care of FR Clothing.
OSHA Regulations and Standards to Safeguard Workers
As mentioned above, a variety of standards require the use of protective clothing when working under certain conditions. For example, OSHA 1910.132 requires employers to assess the workplace for hazards and ensure each affected employee wears the appropriate personal protective equipment for the job, also known as “PPE.” OSHA 1910.269 provides additional regulations that apply to those operating and maintaining electric power generation, transmission, and distribution lines and equipment. It requires employers to ensure that employees who may be exposed to flames or electric arcs do not wear clothing that could increase the extent of injury. It goes on to state the employer shall ensure that the outer layer of clothing worn by an employee, with some exceptions, is flame resistant under various conditions.
In 1995, OSHA’s Deputy Assistant Secretary, James W. Stanley, issued Guidelines for the Enforcement of the Apparel Standard, 29 CFR 1910.269(l)(6), of the Electric Power Generation, Transmission, and Distribution Standard. Stanley’s 1995 memorandum, which was updated in 2004, spells out OSHA’s enforcement policy with regard to the “296” standard. On April 11, 2014, OSHA published to the Federal Register the final rule revising 29 CFR 1910.269 and 1926 Subpart V, related to the construction and repair of electric power generation, transmission, and distribution in an effort to improve workplace safety.
After OSHA’s revisions to the rule, one frequent question asked is, “Does the revised OSHA 1910.269 ruling require FR clothing to be worn by employees?” The answer is yes. Employers shall ensure that the outer layer of clothing worn by an employee, except for certain head, hands, and feet items, is flame resistant under any of the following conditions:
- The employee is exposed to contact with energized circuit parts operating at more than 600 volts;
- An electric arc could ignite flammable material in the work area that, in turn, could ignite the employee’s clothing;
- Molten metal or electric arcs from faulted conductors in the work area could ignite the employee’s clothing, or
- The incident heat energy estimate exceeds 2.0 cal/cm2.
It’s not enough that workers exposed to flame and arc flash hazards wear FR; OSHA’s 296 standard requires the employer to train workers about apparel-related hazards.
Clothing made from 100 percent cotton or wool is considered inherently FR and may be acceptable – if its weight is appropriate for the flame and electric arc conditions to which a worker could be exposed. Some fabrics are chemically treated to make them flame-resistant. Many inherently FR fabrics will not ignite when exposed to flame in an environment with normal levels of oxygen present. The amount of heat required for ignition depends on factors including weight, texture, weave, and color of the fabric material. Clothing does not comply with the “269” standard if it is “capable of igniting and burning under the electric arc and flame exposure conditions found at the workplace.”
The revised ruling clarifies and expands the employer’s responsibility to provide appropriate arc-rated clothing to employees based on reliable estimates of workplace hazards.
In order to provide appropriate PPE, an employer must do the following:
- Assess the workplace to identify employees exposed 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;
- Ensure that the outer layer of clothing worn by an employee is flame resistant under certain conditions; and
- With certain exceptions, 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 (1).
It should be noted that “OSHA acknowledges considerable flexibility in the approaches employers can use to satisfy PPE requirements. The OSH Act requires employers to pay for the means necessary to create a safe and healthful work environment… Under the OSH Act, employers are responsible for providing at no cost to their employees the PPE required by OSHA standards to protect employees from a workplace injury or death.”
Clothing made from acetate, nylon, polyester, or rayon – either alone or in blends – is prohibited by OSHA “unless the employer can demonstrate that the fabric has been treated to withstand the conditions that may be encountered or that the clothing is worn in such a manner as to eliminate the hazard involved,” according to the OSHA guidelines.
OSHA also warns that even wearing a prohibited fabric as one of multiple layers of clothing could be hazardous. Worn as an outside layer of clothing, the fabric could ignite and burn the employee’s face – then likely continue burning and cause injuries to other parts of the body. If clothing made from a synthetic material is worn as a middle or inside layer of clothing – and if enough heat passes through the outer layer – the fabric also could ignite. As an inside layer, clothing made of prohibited fabric could melt when it comes into contact with the employee’s skin, causing a burn injury.
Additional Standards, Rules, and Regs to Safeguard Workers from Burns
In addition to those OSHA rules, the National Electrical Safety Code and the National Fire Protection Association (NFPA) 70E: Standard for Electrical Safety in the Workplace provide guidance on the specific types of PPE and arc ratings that are necessary for various environments and arc-flash energy exposure levels. The NFPA 70E standard also outlines four PPE categories based on the circumstances and level of protection needed. These PPE requirements take into account the task being performed as well as the condition and type of equipment being used.
Meanwhile, NFPA 2112 specifies the minimum performance requirements for FR fabrics and components, as well as the garment design requirements for protective apparel used in environments with a risk of flash fire. Although many employees typically provide some or all of their own work attire, it is the employer who will be issued a citation if a worker who is exposed to electric arc or flame hazards is not wearing FR clothing. Additionally, since FR properties can be compromised due to incorrect repairs or laundering – or simply by repeated washings – employers should instruct their workers on the proper care of FR apparel.