Nomex FR Apparel Newsletter Volume 2

Update on Standards Activity Affecting Thermal Industrial PPE

Thermal Industrial PPEStaying up to date about revisions to existing standards, as well as knowing the status of new rulemaking activity, is very important when you are responsible for selecting thermal industrial personal protective equipment (PPE). To help you stay informed, here are concise overviews of what's happening with National Fire Protection Association (NFPA®) 70E, NFPA® 2112, National Electrical Safety Code (NESC®, ANSI C2) and the proposed U.S. Occupational Safety and Health Administration (OSHA) combustible dust regulatory standard. For your convenience, we've also included links for each topic so you can obtain additional information.

The 2018 edition of NFPA® 70E is scheduled for issuance in August 2017. A number of changes have been incorporated that address risk assessment; equipment features (e.g., clearing times, condition, etc.); approach and work distances; and numerous clarifications for DC systems.

For thermal apparel PPE, a greater emphasis on performing risk and hazard assessments has been included in order to facilitate appropriate selection of protective equipment. This aligns with the recent OSHA changes associated with regulatory standards Title 29 CFR 1910.132 (hazard assessment); 29 CFR 1910.137 (electrical safety); and 29 CFR 1910 Subpart S (electrical design safety, work practices, maintenance requirements and special equipment).

Unfortunately, due to a directive by the National Electrical Code (NEC®) Technical Correlating Committee (NFPA® 70), all normative uses of ASTM standards have been removed from the revision. This has created a number of specification, testing and performance issues that may lead to problematic PPE issues in the future (e.g., adoption by manufacturers of alternative standards).

To address this change, a new section on PPE Conformity Assessments,130.7(C)(14)(b), has been added, along with a marking requirement, 130.7(C)(14)(c). The marking requirement had previously been incorporated in the arc specification standard ASTM F1506, which is now informative only.

NFPA® 2112
The 2018 edition of NFPA® 2112, scheduled for issuance in August 2017, has undergone a title change and a significant expansion of what is addressed by the standard.

The title, "Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire" is changing to "Standard on Flame-Resistant Clothing for Protection of Industrial Personnel Against Short-Duration Thermal Exposures from Fire." This change is designed to maintain consistency with the primary selection standard, NFPA® 2113 (2015 Edition - Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Short-Duration Thermal Exposures) and addresses clothing items that are added to the scope of the document. The revised NFPA® 2112 document remains a minimum specification for flame-resistant (FR) PPE and is not intended to drive clothing selection.

As noted above, several new clothing items have been added to the scope with appropriate minimum performance requirements. Shrouds, hoods, balaclavas, gloves and multilayer systems (including the cold weather outerwear systems that were added as amendments to the previous edition) have been included with appropriate minimum performance testing and specification requirements. One feature to note is the lack of burn injury performance criteria for most of these items, which is due to the fact that consensus models for evaluating their performance are still in development. This is expected to be resolved prior to the next edition of the standard.

Thermal Industrial PPE

The NFPA® 2112 revision also includes clarifications and a technical committee consensus on appropriate emblem and heraldry performance (if specified FR) with maximum non-FR size recommendations. Guidance on the non-FR heraldry and emblem size is now included as an annex item. Essentially, if non-FR emblems are attached to the exterior of a garment, the maximum recommended number is five with no individual emblem covering an area greater than 103 cm2 (16.0 in.2). A total maximum recommended area for all non-FR emblems is not more than 258 cm2 (40 in.2).

The 2017 edition of NESC®, ANSI C2 for Utilities, issued on schedule in August 2016. The Part 4 Rules, where PPE is identified, have changed to now include protection for the head, face, hands and feet.

This brings the NESC® in compliance with the regulatory changes made by OSHA in 2014 to the Title 29 CFR 1910.269 and 29 CFR 1926 standards, which made whole-body protection required.

New training materials for the changes in the 2017 edition of the NESC®, as well as that found in Part 4, have been developed as two NESC® handbooks—one a premier and the other a regular edition. These handbooks provide additional explanatory and technical information related to each section of the standard.

OSHA Combustible Dust Rulemaking Activity
In 2009, OSHA announced its intent to develop a new regulatory standard agenda designed to comprehensively address the fire and explosion hazards of combustible dust. This decision reportedly arose from a recognition that existing regulatory standards have not adequately addressed all the elements needed to protect workers from that hazard.

This need for a new regulatory standard was apparently accentuated by a series of high-profile industrial accidents that had large economic impacts and loss of worker lives, all directly attributable to combustible dust explosions and fire. Examples of those industrial accidents include the Imperial Sugar Company dust explosion and fire in 2008 and the Hayes Lemmerz aluminum dust explosions and fire in 2003, to name a few.

How do dust explosions occur

Unfortunately, all rulemaking activity has been reportedly put on hold. This is due in part to multiple postponements of the required regulatory draft generation and review by a Small Business Regulatory Enforcement Fairness Act (SBREFA) panel, and to President Trump’s recent Executive Order 13771 – “Reducing Regulation and Controlling Regulatory Costs,” which requires repeal of two existing regulations for each new regulation.

An OSHA resource at ASTM has communicated that removing safety-related OSHA standards is extremely difficult (if not relatively impossible) and that we should not expect any new OSHA regulatory standards activities for the near future.

OSHA plans to continue enforcement activity following the general industry housekeeping standard, 29 CFR 1910.22(a)(1) addressing accumulations of dust; the general industry electrical standard, 29 CFR 1910, subpart S addressing electrical ignition hazards; and the General Duty Clause specified by Section 5(a)(1) of the Occupational Safety and Health Act of 1970 (OSH Act; see 29 U.S.C. 654).

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