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Safety Updates
FR Safety: Your General Duty

Make no mistake—keeping FR on their backs falls squarely on your shoulders. In the United States, the responsibility for worker safety rests solely on the employer. In 1970, the OSH Act created the Occupational Safety and Health Administration (OSHA) and established the “general duty clause,” which delegated authority to OSHA to set the rules for implementing the standard.

The General Duty Clause states:

(a) Each employer –-

(1) shall furnish to each of his or her employees employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees;

(2) shall comply with occupational safety and health standards promulgated under this Act.1

When OSHA was first established in 1970, existing private professional organizations had already begun publishing safety standards and best practices specific to their industries and/or hazards. So, rather than trying to address every possible scenario in which an employee could be hurt and how to manage each, OSHA looked to these well-established entities to define the specifics. In fact, many of OSHA’s permanent standards originated as national consensus standards developed by organizations such as the National Fire Protection Association (NFPA) and the American National Standards Institute (ANSI).

The General Duty Clause requires employers to be aware of all actual and potential workplace hazards and to take necessary precautions to protect their employees. The only problem is, it doesn’t tell employers how they are supposed to do it.

Therefore, it falls on the employer not just to follow the rules, but also to determine the rules that apply to them and to enforce those rules.

Overall, employers are responsible for:

1. Referring to the industry consensus standards that meet OSHA requirements

2. Determining which standards are applicable

3. Reading and understanding the standards

4. Finding the right PPE suitable to meet the standards

5. Ensuring PPE is compliant

6. Ensuring employees know how to—and do—use and care for their PPE properly.

So, if you feel like the weight of the world is on your shoulders—you’re not so far off. That’s why Bulwark arms you with FR training and expertise to help ease the pressure and keep your guys safe.

For more information on building an effective safety program, read our blog post “The ABC’s of PPE” or get in touch with a Bulwark representative.

Safety Updates
Managing Cold Stress

Workers in the oil and gas and electric utility industries frequently face flash fire, arc flash and heat stress hazards. But one hazard that may not be as talked about is cold stress. Cold stress occurs when skin temperature drops, lowering internal body temperatures and disabling the body’s ability to warm itself. It can lead to several medical conditions, including trench foot, chilblains, frostbite and hypothermia.

 

Warning signs of cold stress:

• Shivering
• Teeth chattering
• Numbness
• Stiffness 
• Cold, stinging, aching
• Loss of coordination
• Dilated pupils
• Slurred speech
• Disorientation and confusion
• Unusual fatigue

According to OSHA General Duty Clause, the responsibility for worker safety is squarely on the employer. According to Section 5(a)(1):

Each employer (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees; (2) shall comply with occupational safety and health standards promulgated under this Act.

 

Tips on how you can reduce cold stress for you and your team:

• Train workers on the appropriate personal protective equipment (PPE) and work practices to reduce cold stress risk
• Implement safe work practices
• Help workers who are used to working in warm areas build up a tolerance for working in the cold environment
• Schedule maintenance and repair jobs for warmer months
• Schedule cold-weather jobs for the warmer parts of the day
• Reduce the physical demands of workers
• Use relief workers or assign extra workers for long, demanding jobs
• Provide workers with warm liquids
• Provide workers with warm areas during peak cold periods
• Include a thermometer and chemical hot packs in first aid kits
• Train workers to avoid touching cold metal surfaces with bare skin
• Monitor workers’ physical condition and have them monitor their coworkers

Another great method to keep workers safe from potential cold stress is to utilize a layering system. A layering system allows workers the flexibility to remain more comfortable and safer in a variety of conditions. As long as the layers are compliant to the assessed hazard and are layered correctly according to industry regulations. Try Bulwark Protection’s Arc Rating Calculator to see how your layers add up. 

 

Here are a few critical considerations when layering FR/AR garments:

• Always layer FR/AR garments underneath FR/AR outerwear
• The arc rating of the outermost FR/AR layer must be sufficient to prevent break open and ignition of any flammable base layer
• Non-FR/AR outerwear should never be worn over FR/AR garments

Cold stress shouldn’t be a risk you and your team overlook. That’s why it’s not only important to incorporate a comprehensive layered PPE program, but to be aware of the warning signs of cold stress and how you can reduce the risk.

How to manage cold stress on the job.

Cold stress may not be as well-known as heat stress, but when the temperature drops, it can pose a significant danger. Employers have many options for helping workers manage their exposure to cold while protecting them from flash fire and arc flash. This whitepaper discusses how you can layer FR/AR garments, how to implement a PPE program and the warnings signs of cold stress.

Fill out the form below to download the whitepaper.

Ask An Expert
What is a Hazard Risk Assessment?

AR, FR, ATPV, OSHA. The list goes on and on. If there’s one thing that’s true about FR safety, it’s that there are a lot of terms to memorize. It’s not always easy to keep the various words and acronyms straight, but when it comes to building and implementing an effective safety program, knowing your FR vocabulary is important. Here, our FR experts have compiled the most important of those terms in a handy alphabetized glossary so you can create a culture of compliance.

Arc Flash
An arc flash is a type of electrical explosion where temperatures can reach or exceed 35,000 °F. The Arc Flash hazard affects all who work in and around energized electrical equipment. This can include general industry electricians, maintenance workers and operators, as well as our electric utilities, including transmission, distribution, generation and metering.

Arc-Rated (AR) Protective Clothing
Arc-rated protective clothing protects from arc flash and electric arc hazards. AR garments are measured in cal/cm². The total AR clothing system must meet or exceed required arc protection levels. Remember, all AR is FR, but not all FR is AR.

Breakopen
Breakopen is the formation of holes in the fabric during arc rating testing. This is the point of failure of FR protective garments.

EBT
Energy Break-Open Threshold is an alternative measure to ATPV when that measure cannot be used due to breakopen.

Flash Fire
A rapid moving flame front that can be caused by a diffuse fuel, such as dust, gas, or the vapors of an ignitable liquid, without the production of damaging pressure. Flash fire is the primary hazard in the Oil & Gas industry, which includes exploration, drilling, field services and refining.

Hazard Risk Assessment
The first step in the creation of any PPE program is the Hazard Assessment. Federal regulations require employers to assess the workplace to determine if hazards that require the use of personal protective equipment are present or are likely to be present. These include impacts, combustible dust, fire/heat, and chemical hazards, among others.

HRC (Hazard Risk Category)
Hazard risk categories are defined by NFPA® 70E and assigned based on risk associated with electrical safety and arc flash. HRC levels determine the appropriate ATPV of flame-resistant clothing for a given task.

PPE Category
Replaces HRC in 2015 edition of NFPA 70E, the “0” category was eliminated in NFPA 70E 2015. The minimum ATPV’s for PPE Category 1 through 4 are the same as they were for HRC, and the new PPE table only specifies PPE for work within the arc flash boundary.

CAT 2
HRC 2 rated garments have an arc rating between 8 cal/cm² and 25 cal/cm² and are often referred to as “daily wear.”

CAT 3
HRC 3 rated garments have an arc rating between 25 cal/cm² and 40 cal/cm².

CAT 4
HRC 4 rated garments have an arc rating equal or greater than 40 cal/cm². These high ratings are achieved with a layered FR system. Download our FR Layering Fact Sheet to learn the do’s and don’ts of layering for FR.

Inherently Flame Resistant
Inherently flame resistant fabrics are engineered to be flame-resistant at the fiber level, and do not require any additional finishing.

NFPA®
The National Fire Protection Association is an agency whose task it is to promote and improve fire protection and prevention. They publish National Fire Codes.

NFPA® 2112
Refers to NFPA’s “Standard on Flame Resistant Garments for Protection of Industrial Personnel Against Flash Fire.” NFPA® 2112 is the “go-to” industry consensus standard that addresses flash fire. It defines the testing methods and performance requirements for flame-resistant fabrics for this hazard.

NFPA® 70E
The “Standard for Electrical Safety in the Workplace,” NFPA® 70E is meant to protect those working around potential arc flash hazards. Note that NFPA® 70E applies only to general industry electrical safety, not to electric utility workers.

OSHA

Founded by the Occupational Safety & Health Act of 1970, The Occupational Safety and Health Administration’s (OSHA) mission is to “assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.” Their general duty clause ensures a safe workplace for all employees and is the basis for all industry consensus standards. OSHA determines regulations and standards related to personal protective equipment.

OSHA 1910.269

The regulation states that power utilities make reasonable estimates of the incident heat energy to which their employee would be exposed, and that employees exposed to hazards from electric arcs wear AR clothing and other protective equipment with an arc rating greater than or equal to the estimated heat energy.

ANSI

Founded in 1918, The American National Standards Institute coordinates and develops voluntary standards for products, services, and systems. The organization’s goals include performance consistency and product safety. It is the U.S. member body to ISO and IEC.

PPE (Personal Protective Equipment)

Personal protective equipment is specialized safety gear worn by an employee for protection against a hazard. Flame resistant/arc rated garments are a form of personal protective clothing worn against thermal hazards.

Moisture Wicking

Moisture wicking fabrics pull moisture (sweat) away from the body and dry quickly, keeping the wearer cooler, dryer, and more comfortable. Bulwark iQ Series® FR Comfort Knits and Wovens are among the best moisture wicking FR garments available.

Breathability

Breathability refers to how well a fabric allows air to be transmitted through the material. The more air that passes through, the cooler the wearer stays. Bulwark iQ Series® Endurance Collection is the first of its kind to offer high level FR protection in a material that is extremely breathable and durable.

Industry News
Bulwark Protection Joins Partnership for Electrical Safety.

Proud Members. Shared Mission.

With our commitment to relentless protection comes a commitment to doing our part to help ensure worker safety by pushing for standards and oversight. Nowhere is this obligation more essential than the world of NFPA® 70E, and in the lives of those Americans working near energized equipment. It is our pleasure to announce Bulwark Protection is now a proud member of the Partnership for Electrical Safety.


FREQUENTLY ASKED QUESTIONS

The Partnership for Electrical Safety firmly believes that every American working on or near energized electrical equipment deserves equal protection from arc flash, including the appropriate arc rated clothing and associated PPE. We believe that the PPE requirements of NFPA 70E®: Standard for Electrical Safety in the Workplace® provide the appropriate best practices to ensure worker safety and should be broadly adopted for substantially all live or potentially live electrical work in the United States. We seek to educate those at risk and to make plain to relevant oversight entities the need for use of personal protective equipment (PPE) when doing electrical work, and the extreme human and financial costs of non-compliance.
We intend to help ensure all Americans have access to and properly wear the appropriate arc rated clothing and associated PPE. We accomplish this through visually compelling and impactful direst education in person and online, and by engaging standards and rulemaking entities such as OSHA, NESC® and others. We help these entities understand the magnitude of the hazard as well as the societal cost of not wearing appropriate PPE, to encourage them to apply arc flash safety regulations equally to all workers.
National Fire Protection Association (NFPA) 70E®, Standard for Electrical Safety in the Workplace®, 2018 Edition addresses electrical safety related work practices, safety-related maintenance requirements and other administrative controls for activities such as inspection, operation, repair or demolition of electric conductors, electric equipment, signaling and communications conductors and equipment, and raceways. It also includes safe work practices for employees performing other work activities that can expose them to electrical hazards such as installation of conductors and equipment or installations used by the electrical utility that are not an integral part of a generating plant, substation or control center.
NFPA 70E® is a national consensus standard that establishes “best practices” for protection from electric arcs. Employers must conduct a shock risk assessment to establish limited and restricted approach boundaries and an arc flash risk assessment to establish an arc flash boundary. Under NFPA 70E® employers must document and implement an overall electrical safety program that includes hazard/risk evaluation and job briefing procedures. This program must be audited annually. If energized electrical conductor or circuit parts operating at 50 volts or more are not placed in an electrically safe work condition, written authorization by work permit is required. Employees must be qualified to do the work and trained to understand the specific hazards and potential injury associated with electrical energy. Employees exposed to shock hazards must be retrained annually in cardiopulmonary resuscitation. When work will be performed within the arc flash protection boundary, the employer must document the incident energy exposure in calories per square centimeter. Section 130.7 (C)(7) states arc-rated clothing must conform to applicable state, federal, or local codes and standards, and appropriate PPE must be worn either based on the incident energy determined for the specific task or by using separate tables in NFPA 70E to determine the need for arc-rated PPE and the arc flash PPE category. In table 130.7(C)(14) the ASTM F1506 Standard Performance Specification is noted as an example of a standard that contains information on the care, inspection, testing, and manufacturing of appropriate PPE.
Employees during activities such as installation, operation, maintenance and demolition of exposed energized electrical conductors or circuit parts. Research shows that approximately 5% of the employees in any operation work as electricians, maintenance or other categories of work covered by this standard.
OSHA believes that the NFPA 70E® standard offers useful guidance for employers and employees attempting to control electrical hazards, but OSHA has not conducted a rulemaking and therefore does not “enforce” NFPA 70E®. OSHA does use consensus standards, such as NFPA 70E® as evidence of hazard recognition in evaluating General Duty Clause violations.

To learn more, please visit the Partnership for Electrical Safety website.

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