Final Steps for OSHA 1910.269 Compliance

Important Note: As of February 2015, compliance dates have changed for enforcement of OSHA standard 1910.269. These changes impact dates listed in this post. Click here for complete details and updated deadlines.

As part of OSHA’s 2014 final rule for 29 CFR 1910.269, OSHA mandated employers in electric power generation, transmission, and distribution and related fields to complete hazard assessments by January 1, 2015 (OSHA has since issued and extended an enforcement delay stating it would not begin to issue citations against the provisions of the new rule until February 17, 2014).

Now that you’ve completed your hazard analysis, the next step is to provide employees full-body arc-rated/flame resistant (FR) clothing and other personal protective equipment (PPE) matched to the hazard by OSHA’s final deadline of April 1, 2015.

1.  Identify groups within the company that require PPE under the new rule, as well as items and quantities your company will require.

Based on the OSHA-mandated hazard analysis, employers will need to provide head-to-toe arc-rated/ flame resistant (FR) clothing for all hazards greater than 2 calories or for work above 600 volts. While many utilities commonly provide FR shirts and outerwear, FR pants are now required and your analysis may also indicate the need for balaclavas or face shields, boots, and gloves.

2.  Engage an arc rated clothing solution provider ahead of time.

 A critical path to compliance is determining and implementing the service solution that best fits your company’s needs. OSHA acknowledges flexibility in the approaches employers can use to satisfy PPE requirements, and makes several statements indicating support of an allowance-based FR clothing program. Allotment-based programs and programs that combine allowances with allotments will help bridge the gap to the new requirements.

Do not wait to engage an arc rated clothing supplier, as OSHA’s ruling has significantly increased the demand for arc-rated garments. The last time an FR clothing PPE standard was issued (2010), there were significant industry-wide shortages! Promptly partnering with an arc-rated clothing solution provider like Tyndale will ensure your workers are protected and compliant by OSHA’s April 1, 2015 deadline.

3.  Partner with selected arc rating clothing supplier to develop resources and plans for teaching and enforcing proper care and maintenance.

Although OSHA specifically states that industrial laundry is not required, the new ruling solidifies OSHA’s requirement for employers to provide, pay for, and retain ultimate responsibility for care and maintenance of arc rated clothing.

Whether employers choose to take advantage of the convenience and cost effectiveness of home laundry or pay for industrial laundering, employers must train their employees in proper care and maintenance techniques and regularly inspect the clothing for repair or replacement. The requirement for garment inspection rests squarely with employers and cannot be outsourced to service providers!

Accordingly, the most reliable solution for safety and compliance is to partner with an arc-rated/FR clothing supplier that can provide straightforward multimedia resources and care and maintenance instructions to support your company in educating employees and enforcing proper care and maintenance practices. Qualified suppliers will also be able to recommend a practical jobsite garment inspection procedure.

Have questions or need assistance protecting your workforce by OSHA’s April 1, 2015 deadline? Contact us at 1910269@TyndaleUSA.com or 800-356-3433.

Not ready for the April 1st compliance date? Tyndale has proactively increased inventory levels to an all-time high to support utilities in gaining compliance. Contact us at 800-356-3433 to check stock or shop online at www.TyndaleUSA.com to place an order.

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