NFPA 2112 and Compliance with OSHA 1910.132 FRC Flash Fire Memo

July 30, 2013

This is the second post of a four-part series where we cover recommendations for compliance with OSHA 1910.132 FRC Flash Fire Memo.

The first option for garment specification that would meet OSHA 1910.132 standard requirements is the threshold that garments meet NFPA 2112. NFPA 2112 specifies the minimum design, performance, certification requirements and test methods for flame resistant garments for use in areas at risk from flash fires.

As we previously noted, the language used in the March 19, 2010 letter referring to NFPA 2112 is suggestive (i.e. “Employers may consult consensus standards such as NFPA 2112 and 2113 to comply.”). It is unclear at this point whether OSHA will require complete NFPA 2112 compliance.

With that said, garments that meet NFPA 2112 must meet a variety of performance standards and a comprehensive 3^rd party certification program. Generally, the key NFPA 2112 fabric performance standards are as follows:

A flash fire manikin test (ASTM F1930) at a 3 second burn time with a predicted body-burn of less than 50%.
Less than 2 second after-flame and 4” char length in ASTM D6413 vertical flame test.
A Thermal Protective Performance (TPP) rating of more than 3 seconds un-spaced, or 6 seconds spaced. TPP estimates the amount of time before the onset of second degree burn in fire entry.

In addition to these tests, NFPA 2112 requires various additional testing of components (such as zippers, snaps, pocketing material, etc.), as well as specific labeling.

A final key component of NFPA 2112 is that it requires 3^rd party certification of all testing and production-related activities. Generally, this means UL Certification, although 2112 does not specifically require UL as the certification agency. NFPA 2112 does require the certifications symbol or mark to be on the garment label. Due to the cost of certification, many manufacturers limit their 2112-compliant offering to a narrow selection of garments – typically only coveralls, shirts and pants.

It is important to note that NFPA 2112 establishes a minimum threshold of performance. Garments that meet NFPA 2112 will have differing levels of protection, depending on the hazard, fabric and garment.

Links to the rest of this blog series:

Introduction: Recommendations for Compliance with OSHA 1910.132 FRC Flash Fire Memo

Part 2: Flash Fire Rated Garments Complying with OSHA 1910.132 FRC Flash Fire Memo

Part 3: The OSHA 1910.132 FRC Flash Fire Memo: FR Fabrics Not Flash Fire Tested

This post references the OSHA memo dated March 19, 2010:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27296