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.
Our free FR Home Wash magnet is packed with FR laundering quick tips. Request your free magnet to learn more, and keep it handy wherever you launder your garments.
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Arming your crew with the appropriate FR gear is a feat in itself. Navigating the ever-changing sea of standards? Now that’s another beast entirely. Bulwark is here to help you choose the right FR program by ensuring you have a thorough grasp on the standards and what they mean for you—and your crew.
When the National Fire Protection Association (NFPA) introduced the term “Arc-Rated” or “AR” in its 2012 revision to NFPA 70E, it was a bit of a head-scratcher. The question on every safety manager’s mind was: what’s the difference between AR and FR? According to Bulwark’s Technical Training Manager, Derek Sang, the most basic and important thing to know when it comes to AR and FR is that all arc-rated clothing is flame resistant, but not all flame resistant clothing is arc-rated.
For a piece of clothing to be considered flame resistant, the fabric used to make the garment must withstand ignition and/or rapidly self-extinguish in order to protect the wearer from the dangers of flash fire, arc flash, molten metals and other hazards. In the event of a flash fire or arc flash, the FR PPE worn must resist catching fire, melting, and continuing to burn after the initial flash to act as a barrier between the wearer and the hazard.
The fabric used to create arc-rated clothing is subject to additional tests, above and beyond fabric labeled simply “FR.” Primarily, it is exposed to a series of arc flashes to determine how much energy the fabric is able to block before it would likely cause the wearer to obtain a 2nd degree burn, 50% of the time. The result of this test, expressed in calories, is known as the Arc Thermal Performance Value (ATPV).
Current standards for arc flash protection, detailed by NFPA 70E, state that all PPE clothing must also be flame resistant to qualify for an arc rating. In other words: all AR clothing is FR, but not all FR clothing is AR. This is because, based on the results of the series of tests outlined above, equipment rated FR may not always provide the adequate level of protection for workers who are at risk of encountering arc flashes. These employees—general industry electricians (70E)— must wear the appropriate level of AR clothing for the hazard, in order to reduce their risk of serious injury or death caused by an arc flash.
Building a PPE program that meets all safety requirements and meets your personal needs is no easy task. You must select the right garments based on the unique hazards of your industry, in addition to important factors like comfort, durability and laundering. But even the best PPE program in the world is ineffective without the proper implementation and training. Below, we’ll provide you with a step-by-step process for designing, implementing and maintaining your PPE program.
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. Using the Hazard Assessment Checklist, you will conduct a walk-through survey of the workplace to identify potential hazards. These include impacts, combustible dust, fire/heat, and chemical hazards, among others. When conducting your assessment, be sure to consider workplace, procedural, and environmental hazards.
Selecting the Right PPE
Once you’ve established the need for PPE, it’s time to determine the degree of protection required based on your particular hazards. We do this by matching the hazard to the regulations, which inform what, if any, PPE is required. Industry consensus standards may be used to guide selection decisions, and the best way to cite these standards is by industry. For the main industries Bulwark serves, the hazards and standards are as follows:
Oil & Gas, which includes exploration, drilling, field services, refinement, and chemical, faces the known hazard of flash fire, a rapidly moving flame front that expands through diffuse fuel without creating blast pressure.
NFPA® 2112 and NFPA® 2113 are the “go-to” industry consensus standards that address flash fire. NFPA® 2113 focuses on how organizations and employers—as well as individual wearers—should choose the correct garment based on certain criteria.
Electric Utility workers, including those working in the transmission, distribution, generation, and metering of power utilities, are exposed to hazards associated with electrical energy, primarily electrical arcs or arc flashes.
General Industry: Wherever workers may be exposed to hazards associated with electrical energy, employers must make sure they are protected. This includes electricians, maintenance workers, and operators.
NFPA 70E® requires AR (or arc-rated) clothing for any potential exposure above 1.2 cal/cm2, which equals the onset of a second-degree burn. The level of protection must be based on the task at hand, and most general industry tasks will require CAT2 or higher. It’s necessary to carefully consider the actual risk associated with a job and to match the protection category accordingly.
NOTE: NFPA 70E® applies only to general industry electrical safety. To address specific circumstances for utility, OSHA published 1910.269 & 1926.960, which state that power utilities are required to wear arc-rated clothing which matches the potential threat as determined by a proper hazard analysis.
Employers implementing a PPE program are required by OSHA 1910.132(f)(1) and all industry consensus standards to provide training to each employee. According to OSHA, each employee who is required to wear PPE should at least know when it is necessary, what exactly is necessary, the do’s and don’ts of proper wear, what its limitations are, and how to properly care for it.
NFPA® 2112 A.5.1.1 offers specific requirements about the information employers must provide to their employees.
Proper care and maintenance of FR/AR clothing is essential to the effectiveness of your PPE program. While most industry standards recommend following the instructions provided by compliant garment manufacturers, some standards offer specific guidance, and there are a few basic rules that apply across all relevant standards.
1. Do not use any kind of bleach or peroxide
2. Do not use any additive that could build up and impede FR performance
3. Wash FR/AR garments separately
4. Turn FR/AR garments inside out to help color retention and preserve appearance
5. Use liquid detergent for best results
6. Avoid the hottest temperature to reduce the impact of shrinkage
7. For tough stains, apply liquid detergent or stain remover and soak garment
8. For even tougher stains, Bulwark® FR garments can be dry cleaned
9. Tumble dry on low setting and do not over dry
10. Rewash garments with lingering odor
11. Never use DEET or any other flammable substances on FR/AR clothing.
12. Any repairs must be made with fabric and findings that match the protection level of the original garment.
More specific regulations about PPE maintenance are defined in NFPA® 2113 and NFPA 70E®.
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:
• Teeth chattering
• 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.
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.
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 is the formation of holes in the fabric during arc rating testing. This is the point of failure of FR protective garments.
Energy Break-Open Threshold is an alternative measure to ATPV when that measure cannot be used due to breakopen.
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.
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.
HRC 2 rated garments have an arc rating between 8 cal/cm² and 25 cal/cm² and are often referred to as “daily wear.”
HRC 3 rated garments have an arc rating between 25 cal/cm² and 40 cal/cm².
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.
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.
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.
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.
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.
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.
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 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 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.
Depending on the line of work you’re in, there are any number of dangers you may encounter on the job. From slip-and-fall hazards to those due to working at height, there’s PPE to help keep you protected. When it comes to thermal hazards, your FR clothing protects you against two main hazards: Flash Fire and Arc Flash.
A flash fire is 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. In the Oil & Gas industry, which includes exploration, drilling, field services and refining, flash fires are the primary hazard FR protects against.
NFPA® 2112 and NFPA® 2113 are the “go-to” industry consensus standards that address flash fire. Once safety managers have identified they have a flash fire hazard, FR is necessary. Selecting the appropriate FR garments for your safety program should be based on a number of factors such as protection, comfort and durability.
An arc flash is a powerful and dangerous occurrence where an electric current leaves its anticipated path and travels from phase to phase, or phase to ground. The resulting explosion produces extremely high temperatures, acoustic energy and concussive force. When a person is in close proximity to the arc flash, serious burn injury and even death can occur.
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. As employers, it is your responsibility to ensure that all employees exposed to the hazard are protected with arc-rated flame-resistant clothing.
No matter which hazard your FR clothing is designed to address, the success of any program is dependent upon the proper selection, use, care and maintenance of your FR program. For more information on how to select the right FR for your needs and tips on implementing a FR clothing program, get in touch with a Bulwark FR expert.
When you think about establishing a successful FR clothing program, what “check list” items immediately spring to mind? Generally speaking, the first two mental steps people in this industry take are: 1.) Evaluating the thermal hazard you are providing protection for; and 2.) Selecting the appropriate FR garments for that hazard.
But for your FR program to be fully effective, you need to look beyond just choosing the right gear for the environment you and your crew are working in. You need to examine every layer closely, beginning with your base layers.
Fact is, an FR clothing program is not fully defined if it does not place restrictions or set guidelines on clothing to be worn under the FR uniform. In the worst circumstances, lack of guidance on base layer clothing can leave an employee at risk for injuries. Consider, for a moment, the extent of an injury that could be sustained by someone wearing a t-shirt made of synthetic fibers under their FR clothing. Sure, the outermost FR layer will self-extinguish in a thermal event. But enough thermal energy could transfer to the t-shirt underneath, causing it to melt to the wearer’s skin.
One simple way to manage this issue is to mandate that all undergarments be made of 100% cotton or other natural fiber. However, this option places the responsibility of choosing compliant clothing squarely on the employee. And, it will require additional “policing” on your behalf.
In our opinion, the most comprehensive approach is for the employer to specify and issue the appropriate FR base layers to be worn under the company’s FR uniforms. By doing so, not only are you taking the choice of undergarments out of the hands of your employees, and the questions of whether or not they have the right fiber content against their skin out of the equation. You will also be providing a second layer of FR protection should they inadvertently leave a shirt unbuttoned or untucked in a moment of complacency. (A layer that, believe it or not, can also provide greater comfort; most FR undergarments pull sweat away from the body to help keep workers cool and dry.)
In the case of protection against electric arc exposure, only FR layers can contribute to a composite ATPV rating, so issuing an FR base layer to be worn under an FR shirt may increase ATPV and possibly increase protection.
So, there you have it. Your base layer basics, compliments of the world’s #1 FR brand. Next time you’re evaluating your FR program, please keep these tips top of mind. And don’t let your undergarments become an oversight.
Shop our base layers.