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

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

The final, and least rigorous, approach for meeting the OSHA 1910.132 requirements would be to use garments that meet the arc flash requirements of NFPA 70E, or are otherwise determined to be flame resistant. NFPA 70E addresses electrical safety requirements necessary to safeguard employees.

All NFPA 70E garments are required to meet ASTM F1506 “Standard Performance Specification for Flame Resistant Textile Materials for Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and Related Thermal Hazards.”

This specification has three core components:

1. The fabric must be flame resistant – it exhibits less than 2 seconds after-flame and less than 6” char length when tested according to ASTM D6413.
2. The fabric must be arc tested – it must have an arc rating determined by ASTM F1959 “Standard Test Method for Determining the Arc Rating of Materials for Clothing.”
3. It must include a label that states that the garment meets the requirements of ASTM F1506. Different colors of the same fabric do not need to be tested separately.

Garments that meet NFPA 70E and ASTM F1506 may also meet NFPA 2112 or be Flash Fire Rated. Furthermore, garments that are neither NFPA 2112 compliant, nor Flash Fire Rated may actually provide more protection than those that are. However, without ASTM F9130 Manikin 3 second flash fire test results, it would be difficult to determine the level of protection.

By definition, any garment carrying a label stating that it meets ASTM F1506 is flame resistant. You should check the garment label to determine which standards a garment meets. As such, it would likely be considered FRC and would likely meet the OSHA 1910.132 requirement.

Links to the rest of this blog series:

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

Part 1: NFPA 2112 and Compliance with OSHA 1910.132 FRC Flash Fire Memo

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

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