Although the Occupational Safety and Health Administration doesn't have specific standards for cold weather winter wear, OSHA does require the employer to protect the employee from the hazards present in the workplace. Every workplace must assess the needs of the workplace according to OSHA standards. In this assessment, winter wear and rainwear commonly are overlooked. In some climates this is more critical than others. On April 11, 2014, OSHA issued a final ruling on the OSHA 1910.269 standard, bringing rainwear and cold weather winter wear into the spotlight for electrical service personnel, especially at utilities and large industrials.
OSHA Redefines Non-Melting Winter Wear
The new standard for electric power generation, transmission and generation (commonly called a "utility standard") now clearly requires "flame-resistant" winter wear and rainwear that does not melt onto a worker in arc flash events. Flame resistant (FR) winter wear and rainwear is something many utilities have provided for some time, while others only have provided FR shirts and pants. As a result, OSHA has dealt with incidents at several utilities resulting from a worker wearing melting rainwear or winter wear and suffering burns after the outer shell ignited and melted to the skin in an arc event. OSHA addressed this issue directly in the new standard by prohibiting non-FR winter wear and rainwear and requiring that all clothing worn by those exposed to arc flashes in the covered industries be made of non-melting materials.
OSHA has long prohibited the use of melting materials (both alone and in blends) in exposures to flash fire and electric arc, unless testing shows that the material meets an applicable specification (such as ASTM F1506, NFPA 2112 or ASTM F1891). Polyester, nylon, acetate and polypropylene specifically are listed as examples of melting materials in OSHA 1910.269 but any melting material is prohibited. OSHA also prohibited rayon, a non-melting cellulosic material that is relatively easy to ignite unless treated. The only way for a company to prove their compliance is to show test results that prove the flame resistance of the material to be worn by the worker exposed to arc flash or flash fire hazards.
The electric power, generation and transmission standard clearly requires flame-resistant winter wear and rainwear.
The updated OSHA ruling required that companies provide their employees with clothing that has an FR outer layer when the estimated incident heat energy exceeds 2 cal/cm² by October 2014 and to provide proper PPE for the calculated hazard by April for all exposures.
All arc-rated materials are considered flame-resistant, yet until recently, many of the materials used in winter wear wouldn't pass the standard requirements of NFPA 2112, which represents another occupational hazard: flash fires. This standard had thermal shrinkage requirements required for coveralls, shirts and pants that are not necessary in a batting material for insulation. The committee worked to eliminate this issue so that arc-rated winter wear more easily could be dual rated.
As a result of this gap in the FR industry and the need for FR winter wear that safely could meet the requirements of NFPA 2112, the Technical Committee and Standards Council of NFPA 2112 released two tentative, interim amendments in 2013 to adjust for cold weather insulation in the PPE industry as it relates to flash fire hazards.
These amendments, in addition to the final ruling issued by OSHA, have allowed for a shift in the marketplace in regards to flame-resistant winter wear. As a result of the OSHA requirement, end users will want to specify winter wear garments that are compliant with both NFPA 70E and NFPA 2112 in order to comply with the OSHA standard. Some companies have committed to provide dual hazard winter wear for workers with both exposures, but this is above and beyond most in the industry. However, there already are cold-weather PPE products available on the market that have been dually certified to NFPA 70E and NFPA 2112.
Dually certified products allow employers to provide the same clothing for a variety of hazards such as flash fire, arc flash and even molten metal exposures, while also keeping them warm in winter wear.
Three Things to Look for in Winter Wear for Workers Exposed to Flames and Arc Flash:
1. Be certain the winter wear meets standards for the hazards your workers are exposed to.
a. ASTM F1506 for arc flash (will include ASTM F1959 arc testing, but an arc rating is not enough. Some imported products will have an arc rating, but have not been subjected to complete full testing to the ASTM F1506 specification. Beware and ask for reports).
b. ASTM F1891 for arc flash rainwear (also includes ASTM F1959 arc testing, but has additional requirements. Some winter wear is dual purpose for rain and cold; these garments may meet ASTM F1891).
c. ASTM F2733 is the flash fire standard for rainwear.
d. NFPA 2112 is the flash fire standard for industrial garments, including winter wear. Most of the winter wear on the market for arc flash has not been dually certified to NFPA 2112. This standard requires full third-party certification and has small-scale testing that excludes some batting materials.
e. ASTM F2621: This guide frequently is used to evaluate a garment for compliance to NFPA 70E and exposes the fully constructed garment to one or more arc flash exposures at the fabric's rating level. Performing ASTM F2621 allows you to evaluate a finished garment's response to an arc, while satisfying the clause in NFPA 70E requiring garments to be doffable following an arc event. This reporting should only be provided by a third-party lab.
2. Ask for third-party test data or full lab reports. If a company cannot produce them in a reasonable time, they may not be giving due diligence to their FR program. The not-for-profit Safety Equipment Institute (SEI) and the for-profit Underwriter's Laboratories (UL) both serve the industry as third-party certification bodies. There are several excellent third party labs that do testing; always ask for test reports. If the manufacturer provides an ISO 17025 accredited lab report, this is a good sign. Additionally, many labs will offer to evaluate (for a fee) the fabric against their retained sample to assure it is genuine.
3. Evaluate the insulating properties of the garment. A standard Clo value can be helpful, but this only is a single data point for consideration. Wear trials in the working conditions are the best way to evaluate a garment, as design can contribute both positively and negatively in winter wear garments. Loft maintenance of the batting, proper quilting and good garment design will be apparent in wearing in a cold environment. If the trial is during a warm time of year, check with a local cold storage company. They have shown willingness to allow workers to spend time in cold storage to evaluate garments and clothing systems. Using an infrared camera also can show poor design, especially around the zipper.
4. Evaluate the durability of the garment by washing. Some will lose loft quite quickly in laundering and allow a good Clo figure to "go bad" after just a few washes.
5. Evaluate the water repellency of the outer-shell fabric in snow or rain. This can mean the difference between comfortable workers or freezing ones.
Tom Kiddle is the director of specialized sales at Carhartt Inc. He is responsible for managing Carhartt's nontraditional sales channels, including industrial sales, discount sales, Wholesale.com and inside sales. He holds a Bachelor of Arts degree in business administration Gettysburg College (Pa.) and a master's degree in business administration from the College of William & Mary (Va.).