Key OSHA 29 CFR 1910.269 Update: Full Body Protection Against Arc Hazards

During National Electrical Safety Month, Tyndale has been discussing key aspects of OSHA’s revised ruling as it applies to FR clothing and seeks to help employers understand how the new rule will impact their role in properly protecting employees.

The second key component of OSHA’s final ruling as it relates to FR clothing worn by utility workers that Tyndale will review in this post is that head-to-toe protection is now required. 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.

FR Pants Now Required 

Employees are now required to wear FR pants as part of the revised OSHA standard. The employer shall ensure that each employee exposed to hazards from electric arcs wears protective clothing and other protective equipment with an arc rating greater than or equal to the heat energy estimate whenever that estimate exceeds 2.0 cal/cm2. “This protective equipment shall cover the employee’s entire body,” except for certain exemptions for hands, feet and head protection (p. 390).

This new requirement for FR pants is a departure from the former standard which prescribed that clothing simply “do no harm” in the event of an arc flash. In a previous blog post, Tyndale shared a testing video demonstrating why it is important to protect both the upper and lower body with FR clothing. Because of this older OSHA language, many employers have chosen to provide non-FR jeans for their employees. Below you can watch the difference in performance between FR and non-FR jeans in an electric arc flash test.

As the video shows, cotton can and will ignite, and continue to burn if exposed to a sufficient ignition source. The option to provide FR pants is now in direct conflict with OSHA’s revised ruling requiring employers to 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 (1).

Head, Hand and Feet Protection

Head Protection

The revised OSHA rule requires:

• A face shield with a minimum arc rating of 8 cal/cm2 for single-phase open air exposures greater than 9 cal/cm2 and three-phase exposures greater than 5 cal/cm2.
• Additionally, for single-phase exposures greater than 13 cal/cm2 and three-phase exposures greater than 9 cal/cm2, an arc-rated balaclava is required.
• The arc rating of the balaclava must be a minimum of 4 cal/cm2 less than the exposure.
• For single-phase exposures of 8 cal/cm2 or less, and three-phase exposures of 4 cal/cm2 or less, no arc-rated head protection is required (p. 376-7).

These requirements are outlined in the table below:

Hand Protection

“Arc-rated protection is not necessary for the employee’s hands when the employee is wearing rubber insulating gloves with protectors or, if the estimated incident energy is no more than 14 cal/cm2, heavy-duty leather work gloves with a weight of at least 407 gm/m2 (12 oz/yd2). (l)(8)(v)(A)”

Feet Protection

“Arc-rated protection is not necessary for the employee’s feet when the employee is wearing heavy-duty work shoes or boots.” The OSHA 1910.132 PPE standard addresses payment for these boots in (h)(2), “The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots)… provided that the employer permits such items to be worn off the job site.” However, if the employer requires EH-rated boots or dielectric overshoes, the employer may be required to pay for these items as PPE. (l)(8)(v)(B)

This requirement for full body protection means that workers will now be required to wear FR pants, balaclavas or face shields, boots and gloves, in addition to the FR shirts and coveralls already commonly provided to employees in FR clothing programs. Since OSHA now believes that it is reasonable and appropriate to treat FR and arc-rated clothing required by the revised ruling as PPE, this will be reflected as an increase to allowance and/or by adding additional items to approved clothing selections for employees.

OSHA makes several statements in the revised standard indicating support of an allowance-based FR clothing program, which Tyndale will discuss it our upcoming blog post. For more information on OSHA’s Final Ruling of 29 CFR 1910.269, please visit www.tyndaleusa.com.

Links to other posts in this series:

• Understanding Critical Changes to OSHA 1910.269
• FR is Now Considered PPE
• Employers’ Responsibility to Provide FR: OSHA Supports Allowance-Based Clothing Programs
• Employers’ Responsibility to Ensure Proper Care, Maintenance & Laundering of FR Clothing

References for this post were accessed April/May 2014:

(1) https://www.osha.gov/dsg/power_generation/faqs.html