Report

Subject:                     When is Flame Resistant Clothing (FRC) Really required?

Date of Email report:   Fri 27/02/2009

Report Detail:

Have you conducted a 'risk assessment' ? 

Are your staff operating in areas where FRC should be worn?

OSHA answered this question in 2006 in the LOI, Requirement for flame-resistant clothing in petrochemical plant covered by PSM.  Although, OSHA states in the LOI that they will cite the employer for 1910.132(a), 1910.132(d), 1910.119(f)(1)(iii)(B) and/or 1910.119(j)(2).  OSHA makes reference to NFPA 2113, Standard on Selection, Care, Use and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire as an acceptable tool to use when conducting your "Hazard Assessment" as it relates to the use of FRC. 

PLEASE KNOW THIS...you do not have to be in the chemical industry for OSHA to cite your facility for the failure to provide FRC.  There is a lot of attention right now on NFPA 70E and this too requires electrical folks to be using FRC when doing certain tasks.  If you have electrical workers exposed to Arc Flash hazards and/or you have Class I, II, or III Hazardous Locations in your facility and employees are assigned to work in those areas I feel the employer should be providing FRC to personnel assigned to work in those Hazardous Locations.  Additionally, if contractors are utilized at your facility, OSHA would expect contract employees to wear flame-resistant clothing in your facility when they conduct work activities for which they are exposed to flash fire hazards. One key for determining if contract employees need flame-resistant clothing would be to examine the requirements for the your (host employer's) employees — if the host employer requires flame-resistant clothing for its employees for various locations and work activities throughout their facility, then contract employees would also be required to wear flame-resistant clothing for the same activities. Depending on the degree of their involvement with the covered process and their specific work activities, if contract employees do not wear flame-resistant clothing when required, contract employers may be subject to violations of 1910.119(f), 1910.119(j), and/or 1910.119(h)(3). Additionally, you (host employer) may be cited for violations of 1910.119(h)(2)(iv) and 1910.119(h)(2)(v) for not assuring contract employees wear flame-resistant clothing in your facility when they are exposed to flash fire hazards when working on or near a PSM-covered process.

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