Being Compliant With OSHA & Developments In FR Workwear

Transcription

1 Being Compliant With OSHA & Developments In FR Workwear Presented By Gary Zumstein February 17, 2016

2 OSHA ACT 1910 Under the OSH Act, employers are responsible for providing a safe and healthful workplace. OSHA's mission is to assure safe and healthful workplaces by: Setting and enforcing standards Providing training Outreach Education Assistance Employers must comply with all applicable OSHA standards. Employers must also comply with the General Duty Clause of the OSH Act, which requires employers to keep their workplace free of serious recognized hazards.

3 SUBPART R SPECIAL INDUSTRIES OF Pulp, paper, and paperboard mills Textiles Bakery equipment Laundry machinery and operations Sawmills Logging operations [Reserved] Telecommunications Electric power generation, transmission & distribution Grain handling facilities The federal regulation (law) defines practices of employees working in the generation, transmission and distribution of electricity.

4 OSHA On April 11, 2014, OSHA published to the Federal Register the final rule revising 29 CFR which updates the standard providing electrical safety guidance for those in the operation and maintenance of electrical power. This revision updates a 40-year old standard (1974) and incorporates major changes to PPE (Personal Protective Equipment), including FR clothing, which impacts the employer. All the published changes are still being implemented as there have been delays in enforcement of the guidelines.

5 So what prompted OSHA to make changes in ? OSHA estimates that the revised ruling will save more than 20 lives and prevent 118 serious injuries each year.

6 PROTECTING UTILITY LINEMEN Out of a group of 100,000 workers, about 30 to 50 are killed every year doing utility line work. Many more suffer non-fatal but lifechanging injuries. The fatality rate is more than twice that of police officers & firefighters making utility line work one of the ten most dangerous jobs in the US. Sourcing from ISHN article found in the January 2016 publication

7 PROTECTING UTILITY LINEMEN About 75% of arc flash incidents occur when a worker is near the equipment. The Fire Protection Research Foundation reported two-thirds of the workers involved in arc flash incidents were injured when companies failed to conduct an arc flash analysis for selecting PPE. A separate study found that 40% of electrical accidents involved 250 volts or less. Sourcing from ISHN article found in the January 2016 publication

8 HOW WAS FR CLOTHING ADDRESSED IN THE PAST REGULATIONS? It did not mandate the use of FR / Arc rated clothing. It did say that the clothing would not contribute to the burn injury caused by being exposed to an arc flash. It previously allowed the use of clothing made of heavy fabrics, such as denim jeans, made of natural fiber which were not treated.

9 REASON FOR CHANGES IN OSHA

10 WOULD YOU PREFER TO WEAR THIS?

11 WOULD YOU PREFER TO WEAR THIS?

12 OR HAVE THIS OUTCOME INSTEAD? These are survivable injuries. Can you imagine what the individuals looked like that did not?

13 PROTECTING UTILITY LINEMEN Based on the previous data presented, it had become apparent that more had to be done to protect the utility linemen in their working environment.

14 OSHA FOCUS My focus in today s presentation Employer s responsibility Employer s / contractor s responsibility Employee s responsibility PPE requirements Boots Face shield / balaclavas Gloves ARC & FRC Clothing Caring for PPE Selecting the right PPE ANSI 107

15 IN GENERAL, AN EMPLOYER MUST: Assess the workplace to identify employees exposure to hazards from flames or from electric arcs. Make reasonable estimates of the incident heat energy of any electric-arc hazard to which an employee would be exposed. 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.

16 IN GENERAL, AN EMPLOYER MUST: Ensure that the outer layer of clothing worn by an employee is flame resistant under certain conditions to ensure that employees exposed to hazards from electric arcs wear protective clothing and other protective equipment with an arc rating greater than or equal to the estimated heat energy. Assure that all working contractors abide by the same workplace hazards as it still is the employers responsibility to assure both contractors and their own workers are protected against the hazard.

17 NEW MINIMUM PROTECTION Among the changes incorporated into the revised ruling, employers are to provide head-to-toe FR / Arc rated clothing for all hazards. This requirement for full body protection means that workers will now be required to wear: FR pants Balaclavas / face shields Boots Gloves In addition to FR shirts and coveralls already commonly provided.

18 ARC RATED PPE CLOTHING STANDARDS Requires FR clothing for incident energy exceeding 2.0 cal/cm 2 or above 600 volts. Protection for head and face. Starts at 9 cal/cm 2 for single-phase arcs in air. Starts at 5 cal/cm 2 for other exposures. Protection for hands (rubber gloves with protectors or, for exposures 14 cal/cm 2, heavy-duty (12-oz) leather work gloves) Protection for feet (heavy work shoes or boots)

19 THE REQUIREMENTS FOR FEET PROTECTION When the employee is wearing heavyduty work shoes or boots, arc rated protection is not necessary. Payment of the work shoe or boot. The employer is not required to pay for non-specialty safety-toe protective footwear. If the employer requires EH-Rated boots or dielectric overshoes, then the employer could be responsible for payment.

20 THE HEAD PROTECTION REQUIREMENTS A face shield with a minimum arc rating if 8 cal/cm 2 for single-phase open-air exposure greater than 9 cal/cm 2 greater than 5 cal/cm 2 An arc rated balaclava is required for single-phase exposures greater than 13 cal/cm 2 three-phase exposure greater than 9 cal/cm 2 Balaclava arc rating must be a minimum of 4 cal/cm 2 less than the exposure. No head protection is required for single-phase exposure of 4 cal/cm 2 or less.

21 REQUIREMENTS FOR HAND PROTECTION Arc rated protection is not necessary for the employee s hands when wearing rubber insulation gloves with protectors, or the estimated incident energy is no more than 14 cal/cm 2, heavy-duty leather work gloves with a weight of at least 12 oz./yd 2

22 ARC RATED & FR CLOTHING IS NOW TREATED AS PPE 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 allowances and/or by adding additional items to approved clothing selections for employees.

23 COST OF CHANGES TO TO EMPLOYERS OSHA specifically addresses the total estimated cost for FR clothing Final Rule at an annualized cost of approximately: $ per employee. OSHA is basing its estimates on a cost of $1,534 per employee for eight sets of flame resistant clothing. Estimated cost of $ per set or on the approximate annualized cost per employee. The agency believes this final estimate is reasonable and captures the average cost of all flame-resistant clothing required by the new provisions of the final standard.

24 OSHA SUPPORTS HOME LAUNDER While the designation of FR clothing as PPE requires additional employer oversight, it is clear OSHA allows home laundering of FR clothing. The final rule does not require employers to launder protective clothing for employees. Home / Industrial laundry is acceptable.

25 EMPLOYER RESPONSIBILITY FOR CARE & MAINTENANCE OF FR CLOTHING OSHA explains that if employers rely on home laundering of FR clothing, they must train their employees in proper laundering procedures and techniques. Not only training required but has to be documented. Employers must inspect the clothing on a regular basis to ensure that it is not in need of repair or replacement. It is the responsibility for maintaining PPE rests squarely with the employer under existing OSHA standards. Home laundry Industrial laundry Experienced FRC suppliers offer guidance and support on training end users. Also applies to contractors.

26 LAUNDRY STANDARD GUIDANCE ASTM F : Standard guide for home laundering care and maintenance of flame, thermal and arc resistant clothing. ASTM F : Standard care and maintenance of flame, thermally and arc resistant clothing for industrial laundry. NFPA 2113: Standard on selection, care use and maintenance of FR garments for protection of industrial personnel against short-duration thermal exposures.

27 ASTM F Standard Guide for Home Laundering Care and Maintenance of Flame, Thermal and Arc Resistant Clothing This guide provides recommendations for home laundering of clothing that is flame, thermal, and arc resistant. This guide does not apply to dry cleaning of flame, thermal, and arc resistant clothing. For more information on dry cleaning, follow label instructions or contact your garment supplier or fabric manufacturer. This guide does not apply to industrial laundering of flame, thermal, and arc resistant clothing. For more information on industrial laundering, follow Guide F 1449 or contact your garment supplier. When garments are laundered properly, using the proper detergent, home laundering is an effective cleaning process. It is important that potentially flammable contaminants are removed from garments during the wash process. If flammable contaminants are not removed, the flame resistance of the garment may be compromised. To reduce the potential of employees wearing garments contaminated with flammable substances, the end user should analyze the soil conditions to which a worker may be exposed, along with the effectiveness of the wash procedure. In the event home laundering is deemed ineffective, alternative solutions should be pursued (dry cleaning, industrial laundering, disposable FR coveralls, etc.). Certain laundry chemicals that may have an adverse effect on fabric flame resistance are identified in this guide and should not be used. This guide does not apply to specialized protective garments such as specialized firefighter turnout gear and proximity firefighter ensembles. This guide also provides recommendations for inspection criteria that are significant to the performance of flame, thermal, and arc resistant clothing.

28 ASTM F (2015) Standard Guide for Industrial Laundering of Flame, Thermal & Arc Resistant Clothing This guide identifies the responsibilities of the fiber, fabric, and clothing manufacturers, as well as the processor, the processor's chemical supplier and the end user. This guide describes the key components involved in a program for the care and maintenance of flame, thermal, and arc resistant clothing. The guidelines in this standard will provide a processor assistance to develop a processing system that maintains the flame, thermal, and arc resistant characteristics of the clothing during its useful service life. The development of published formulas for each fabric and level of soiling is difficult at any given point in time due to ongoing continuous improvement of flame, thermal and arc resistant clothing, including new fibers, fabrics, and laundering equipment and procedures. The guide also provides suggestions as to when flame, thermal, and arc resistant garments should be removed from service.

29 ASTM LAUNDRY GUIDES Basically offer formula advice and recommend against: Chlorine bleaches or liquid nonchlorine bleaches Fabric softeners Liquid during washing Dryer sheets Starch Not cleaning garments on a regularly or daily basis.

30 HOME LAUNDRY MAINTENANCE OF FR GARMENTS Wash FR garments separately in a normal water temperature up to a maximum of 140ºF (60ºC). Use any typical home laundry detergent. Do not use soap (tallow soap containing animal fats). DO NOT use chlorine bleach or liquid non-chlorine bleach. Do not use: Starch Fabric softeners or dryer sheets The use of conditioned or soft water can help improve removal of contaminants from garments. It is important that all soils and other contaminants are completely removed from garments during the wash process. This may require the use of stain removal products or presoaking garments prior to washing. The use of hot water can often make detergents more effective in the removal of soils. Rise garments thoroughly after wash cycles. Do not over dry garments. If desired, you may press with an iron on the Permanent Press/Low setting. Always consult the garment manufacturer for detailed instructions and precautions.

31 STAIN REMOVAL MAINTENANCE OF FR GARMENTS If garments become contaminated with flammable substances, they should be removed immediately and replaced with clean flame resistant apparel. Either home or industrial laundering may successfully remove most types of both flammable and non flammable soils. However, home laundry detergents may not successfully remove some types of soil found in industry, especially heavy greases and oily soils. If flammable soils are not completely removed, the flame resistance of the garment may be compromised. It may be difficult to determine that flammable soils have been completely removed, but indicators would include the presence of stains and/or odors after laundering. However staining alone is not an indication that the soil has not been adequately removed. If it appears that the garments may still be contaminated after home wash, laundering at a local commercial or industrial laundry may be required. Dry cleaning may be used to remove oils and greases. Flammable materials are for the most part volatile substances that dissipate into the atmosphere, for example, gasoline. Stains remaining after laundering on the other hand are either un-removed contaminants or, more likely, simply discoloration of the fabric. Always consult the garment manufacturer for detailed instructions and precautions.

32 REPAIR & MAINTENANCE OF FR GARMENTS ASTM International has developed two standards for repair and maintenance of FR garments. Standard F 1449 Guide for Industrial Laundering of Flame, Thermal and Arc Resistant Clothing, covers maintenance of garments by industrial laundries. Newly adopted Standard F 2757 Guide for Home Laundering Care and Maintenance of Flame, Thermal and Arc Resistant Clothing provides information for home care and maintenance of flame resistant protective garments. Specific guidelines on repairs except to follow the ASTM standards. This would also apply to zippers and any other trim or findings item that needs to be replaced. Technical Bulletins that provide detailed laundry and dry cleaning recommendations are available for each type of fabric used. Essentially, all repairs must be made with materials equivalent to the original materials in the garments. FR sewing thread (Such as Nomex or Kermel) and FR mending fabrics equal to the materials used in the original garment. Heat seal FR patches are available and are often used to make small repairs. Always consult the garment manufacturer for detailed instructions and precautions.

33 AFTER ALL THE TRAINING Do not directly spray items such as DEET onto your FR garments. Items such as DEET are highly flammable and can contribute to the hazard by burning.

34 IMPROVEMENTS IN FR FABRICS & GARMENTS More selection in fabrics being offered in both: Treated Inherents New blends of FR fibers made available from around the world has allowed fabrics to: Increase protection Increase comfort Reduce weight Increased durability Abrasion Chemical Improved colorfastness Washing UV Multi-hazard protection Insect protection Wickable finishes Waterproof / breathable Water repellent Garment designs For both men and women Venting Layering options Increase protection Lower overall weight of the system Giving the wearer a wide range of cost options, level of protection and quality. Chose wisely in your PPE

35 RECOGNIZING SECONDARY/PRIMARY PROTECTION Primary and secondary refer to the degree of protection provided rather than frequency of use or order in which the garments are put on. Secondary Protection/ Daily Wear FR garments, mainly coveralls or shirts/pants, are worn daily in potentially hazardous environment Are comfortable & look like regular work clothes Most FR garments are for secondary protection Hi-vis garments that both FR and also meet ANSI requirements. Primary Protection / put on for a specific job function Protective garments, gloves, hoods, face shields, etc. worn where significant exposure to fire hazards is likely to occur Usually for occasional, not daily, wear Less comfortable than secondary protective FR Often worn over secondary protective FR Hi-vis vest

36 ONE ALSO HAS TO COMPLY TO ANSI 107 When working within 50 feet of a road or highway one must comply to ANSI 107 for hi-vis. While on the ground the worker must wear the proper ANSI Class garments that meets the workplace environment. Worker can comply by either wearing daily wear which meets the ANSI 107 or put on a FR hi-vis vest that meets ANSI 107 and is arc rated.

37 ANSI 107 & OSHA FR Hi-Vest being worn over FR daily wear must also comply: Cal rating of 2.0 cal/cm 2 which means it contains an arc rating Should not contribute to the hazard If a vest is to be labeled FR it must meet this section which uses ASTM 1506 as the basis for its FR provision. This is significant because the fabric is no longer allowed to melt and drip in order to meet previous FR thresholds. Vests claiming an FR capability like NFPA 701 will no longer be considered FR or to be ANSI compliant. FR treated nylons and polyesters are no longer be compliant.

38 REASON FOR CHANGES IN OSHA

39 IN SUMMARY New OSHA regulations for have been written to help improve safety in the workplace. The employer is responsible: Risk assessment of the worksite for both their employees and contractors Purchase PPE for their workers Properly train employees o How to wear PPE properly o How to care for their PPE including washing at home Lots of development has taken place in PPE to increase protection along with improving comfort.

40 THE NEW OSHA RULES FOR ELECTRIC COOPERATIVES The New OSHA Rules for Electric Cooperatives Thursday, February 18 th, :15 am 10:15 am Overview: On April 11, 2014, OSHA published the long awaited changes to OSHA regulations (sections and 1926). The Final Rule, consisting of more than 400 pages in the Federal Register, sets forth new requirements for electric cooperatives and other utilities when it comes to sharing information with contractors, fall protection, minimum approach distances and arc flash protection. Implementation dates were pushed back several times by OSHA but the new rules are now in full effect. Come hear David Wallis, a 40 year OSHA veteran and author of the rule, discuss the new requirements. This is your chance to ask any and all questions about what the rule requires. Instructor: David Wallis, Occupational Safety and Health Administration (Retired)

41 Thank You!