Q. I have a question about OSHA 29 CFR 1910.269 Section (I)(6) “Apparel,” specifically (I)(8)(v) regarding the wearing and use of the safety vest.
(l)(8)(iv)(D):….for the employer to ensure that the outer layer of clothing worn by an employee is flame-resistant when the estimated incident heat energy exceeds 2.0 cal/cm2
We have always advocated the use of an arc rated, ASTM F1506-compliant material, thinking the employer can decide the level of protection to provide his workforce. One, he could write rules protecting the wearer from being exposed to an energized source and potential arc flash exposure and remain in compliance with OSHA and other best practices and with ANSI 107 traffic requirements. Or, two, he could prescribe the use of an F1506-compliant fabric and garment (no melt, no drip) for use in every situation regardless of exposure potential to arc flash, and provide the highest level of reasonable protection under any circumstances in which the worker may find himself.
So my question is: per the section cited above, does this mean now, for safety vests that may be exposed to arc flash, we must match the incident energy requirements just as we would for apparel such as shirts? That is, moving from 5 cal to 8+ cal fabrics in order to create that “blanket” coverage that has induced use of the F1506-compliant fabrics we have used to date?
A. That is not the intent. OSHA has differentiated between flame resistant (FR)-which is still non-melting but not necessarily AR-and Arc Rated (AR). The reasoning behind this is a little complex but makes sense.
The idea is that PPE has to be rated to the hazard (whether it is a single garment or a multilayered system). Other items worn for cold or rain or for other hazards (such as high visibility gear) do not have to be arc rated to the specific hazard, but they must be FR, non-melting and non-contributory. With those three qualifiers, OSHA functionally made them arc rated materials BUT left the employer free to choose an outer shell that isn’t rated with the underlying PPE system for arc protection. As long as the outer shell is FR, non-melting and non-contributory, the employer is not obligated to rate it as part of the system.
They MAY rate the outer shell (say a winter ensemble or rain suit) with the underlying PPE assembly, but they are not obligated to do so. This means that ASTM F1506 vests for ANSI 107 hazards are not required to be rated with the underlying ensemble, though they will be arc rated as a single layer and non-contributory as a garment. This allows compliance with the “FR” requirement without adding the cost of arc rating more systems than necessary to protect the worker.