Do Logos Used on FRC Need to be Flame Resistant?

Note: We cover this topic in a more recent post: Should FR Clothing Embellishments Be Flame Resistant?

One of the most common questions in the flame resistant clothing industry is whether or not company logos or other types of embroidery should be FR. While industry standards agree that logos for FR garments do not themselves need to be FR, it is a best practice to put FR logos on FR clothing, especially if the logo is larger in size or when multiple logos are used.

What do the Standards Say Regarding Logos and Embroidery?

OSHA 1910.269

OSHA 1910.269 is the standard covering the operation and maintenance of electrical power generation, control, transformation, transmission and distribution lines and equipment. It is the only federally enforceable law that requires FR clothing for electric arc hazards.

Although logos and embroidery are not discussed in OSHA 1910.269, a letter of interpretation from 2006 states that the employer is responsible for choosing between FR and non-FR logo thread. This places the onus back on the employer, similar to how employers are responsible for deciding which FR fabrics to purchase and what type of FR clothing to require their employees to wear.

The letter states that, “OSHA’s standard at Section 1910.269(l)(6)(iii) requires that employees, who are exposed to flames or electric arcs, wear clothing that doesn’t increase the extent of any injury sustained by the employee. That provision does not specify the construction methods or materials (including the embroidery) of the clothing, but it does list fabrics, including blends, that are prohibited (e.g., acetate, nylon, polyester, rayon) unless the employer can prove that the clothing made of these fabrics is worn in such a manner as to eliminate the hazard involved.” (1)

The 2006 letter also suggests that ASTM F1506 can be used as a guide for this decision, which we take a look at next. For additional information on OSHA 1910.269 and imminent changes to the electrical rule regarding FR clothing, see our previous blog post on the much anticipated final OSHA ruling.

ASTM F1506 – 10a

ASTM F1506-10a is the Standard Performance Specification for Flame Resistant and Arc Rated Textile Materials for Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and Related Thermal Hazards. This is the governing ASTM standard for FR clothing for electric arc hazards. Two excerpts have been pulled from this standard relating to logos and embroidery on flame resistant garments:

• 6.3.6.1: “When garments are made with a different number of fabric layers in different areas of the garment, the arc rating for each area shall be designated. Pockets, trim, closure, seams, label, and heraldry shall not be considered as extra layers.”

• X.1.2.5 (appendix section): “Logos, name tags, and other heraldry, such as flag patches and company award insignias, are used to identify the organization and individual. If these items are constructed of non-flame resistant materials (such as polyester or rayon), their overall area should be minimized on the garment. For example, large company logos across the back of the garment should not be applied. In addition, the use of several logos over the entire garment should be avoided.” (2)
  

Because the Note X.1.2.5 explicitly refers to non-flame resistant materials used in logo applications, it appears that ASTM condones the use of NFR logo materials. However, F1506 provides language around size. Although this language is non-specific, the industry rule-of-thumb is that an NFR logo should be no larger than the size of a credit card.

Plus, ASTM F1506 only covers workers facing electric arc and related thermal hazards, so what about workers facing other hazards, such as flash fire? NFPA 2112 should be referenced for employees in the oil and gas industry, which is discussed next.

NFPA 2112

NFPA 2112 is the Standard on Flame Resistant Garments for Protection of Industrial Personnel Against Flash Fire. NFPA 2112 specifies the minimum design, performance, certification requirements, and test methods for flame resistant garments for use in areas at risk of flash fires. Again, two sections have been pulled from this standard relating to logos and embroidery on flame resistant garments:

• Section 1.3.4: “The requirements of this standard shall not apply to accessories that might be attached to flame-resistant garments…”

• Section 7.1.4.1: “Labels and emblems [logos] shall not be required to be tested for heat resistance.”(3)
  

Clearly, each case needs to be reviewed separately and each company must choose the appropriate type of logo thread for their own use. There is no overarching requirement for logo/embroidery use on flame resistant clothing for companies to turn to or abide by in either the electric industry or in oil and gas.

When trying to determine whether or not FR thread should be used for your company’s logos or embroidery, consider the following four items:

Thread Colors – FR thread is available in a limited number of colors. Therefore, it is not always feasible for a company to reproduce their logo exactly using FR thread.

Risk – Non-FR thread might be appropriate for small logos that don’t introduce much flammable material or space to the FR garment. Also, the position of the logo on the garment should help you determine whether or not it poses a risk to the wearer.

Cost – FR thread does cost more than non-FR thread. For some companies, they simply cannot afford to embroider a large quantity of items in FR thread if this means adding an extra dollar in cost for each logo. For other companies, cost is not the main factor here.

Alternatives – FR ink silkscreens are a popular brand enhancement that many companies use instead of logo embroidery. FR ink silkscreens are a cost effective printing method with outstanding durability.

Generally, for logo embroidery, a smaller logo is acceptable in non-FR thread. If the embroidery is relatively large or has a solid embroidered background, using FR thread is safest for garment wearers. As best practice, Tyndale recommends using FR thread for logos on FR garments.

Did you know?

Tyndale provides logo, embroidery, heat transfer, silk screening, and reflective striping services onsite at our headquarter location in Pipersville, PA. Visit www.tyndaleusa.com to see a full list of the services we offer our customers, or click here.

References for this post were accessed December 2013:

(1) https://www.osha.gov/pls/oshaweb/owadisp.show_documentp_table=INTERPRETATIONS&p_id=25544