Do OSHA 1910.269 PPE Rules Impact Oil, Gas, and Other Industries?

Tyndale's Overview of API RP 99

OSHA’s 1910.269 ruling for the electric utility industry defines FR clothing as PPE–similar to 2010’s OSHA 1910.132 Enforcement Policy Memo regarding protection from flash fire in oil and gas well drilling, servicing, and production-related operations. In fact, the Preamble to the 1910.269 ruling introduces additional commentary from OSHA that paints a broader picture of the agency’s stance on proper care and maintenance of PPE in general. As a result, key messages in 1910.269 are relevant to the oil and gas industries and other industries that use arc/flame resistant (FR) clothing to protect workers from arc flash or flash fire hazards. Get the overview from Tyndale VP of Technical, Scott Margolin.

Employer Responsibility to Inspect FRC PPE for Proper Care & Maintenance

The Preamble to 1910.269 specifically references 1910.132. In its own words, “OSHA stresses that §§1910.132(a) and (b) and 1926.95(a) and (b) require employers to properly maintain FR and arc-rated clothing required by this final rule. These provisions make PPE maintenance the responsibility of employers, not employees” (Preamble to OSHA 29 CFR 1910.269, p.187; emphasis added).

As such, the ruling clarifies the employer’s federally-enforceable responsibility to perform inspections for proper maintenance.

While the designation of FR Clothing as PPE requires additional oversight, OSHA is equally clear in its commentary in the Preamble to 1910.269 that “the responsibility for maintaining PPE rests squarely with the employer” (p.187; emphasis added).

As such, outsourcing care and maintenance to an industrial laundry service or other vendor does not absolve employers of the responsibility to inspect PPE.

Laundering FRC PPE at Home

OSHA 1910.269 also includes language supporting home laundering of FR clothing PPE as a safe, effective, and acceptable cleaning method.

  • This is consistent with the OSHA 1910.132 Enforcement Policy Memo, which cites NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire (2007 Edition), as a resource for compliance with the enforcement of 1910.132.
  • NFPA 2113, in turn, states that “[f]lame-resistant garments shall be cleaned in accordance with manufacturer instructions, or if cleaning instructions are not provided, in accordance with the recommendations provided in ASTM F2757-09, Standard Guide for Home Laundering Care and Maintenance of Flame, Thermal and Arc Resistant Clothing.”
  • ASTM F2757-09 rules that, “when garments are laundered properly, using the proper detergent, home laundering is an effective cleaning process” (emphasis added).

Although home laundry is clearly supported in both OSHA documents, the 1910.269 ruling clarifies that employers can no longer simply tell their workers to “follow washing instructions,” and trust that they will do so. To comply, employers using home laundry “must train their employees in proper laundering procedures and techniques, and employers must inspect the clothing on a regular basis to ensure that it is not in need of repair or replacement” (OSHA 29 CFR 1910.269 p. 187).

Ultimately, whether employers take advantage of the convenience and cost effectiveness of home laundry or choose to pay for industrial laundering, the employer—and only the employer—has full responsibility to perform inspections for proper maintenance.

Next Steps

Tyndale has developed a video, among other tools, that outlines best practices for maintenance and inspection of FR and arc-rated clothing. For assistance training employees and managing the requirement for employers to inspect PPE for proper care and maintenance, view Tyndale’s video.

In a Tyndale managed FR clothing program today? You’re on your way to compliance! Contact your National Account Executive for next steps.

Not in a Tyndale managed FR clothing program? Learn more about OSHA’s updated PPE requirements by exploring other posts on this blog, or contact Tyndale at 800.356.3433 to learn more about our customized service-based solution. 

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