Incident Report

Subject:                     FRC - A JOIFF Perspective

Date of Email report:   Sat 09/01/2010

Report Detail:

I read recently an item in the Safeteng Newsletter 'Is there a PROPER way to wear Flame Retardant Clothing (FRC)?'  which I thought would be beneficial for JOIFF Membership.  This is included for you in the last section and has some good advice.  However, there is a clear distinction which JOIFF would like to bring to your attention - that of the major difference between 'retardant' and 'resistant'  - something which can make a real difference to your personnel should they be unfortunate enough to be involved in a flash fire incident.  I would like to thank Alec Feldman (Fulcrum Consultants)  our resident expert on all aspects of PPE for writing the following piece as a reminder to our JOIFF Members of the importance of the JOIFF Standard and Specification which are freely available for download at the joiff website:    http://joiff.com/downloads.html

Over the past number of years JOIFF has developed robust policies on the use of flame resistant clothing and has demonstrated these publically through 2 of its documents which are available for free download from the public side of the JOIFF website, the JOIFF Handbook on PPE to protect against Heat and Flame and the recently published JOIFF Specification on multifunctional heat and flame protective work wear, and also in various articles in The Catalyst and in Shared Learning exchanges between Members. Whilst the article says that OSHA does not have a standard that “requires” persons to wear Flame resistant clothing, safe practice requires this. JOIFF states clearly on the Home Page of its website, that the JOIFF Standard is recognised as Best Industry Practice, which a step above recognised Industry practice as is  referred to in the article. There is no question for those operating under Best Industry Practice that when the risk assessment so dictates, flame resistant work wear and other suitable PPE MUST be worn.
“FRC” should be interpreted as “flame resistant clothing” not “flame retardant clothing” as is done in this notice. “Retardant” means that something will “slow down” or “delay” an action,  Resistant” means that it will “act against” or “oppose” an action. From a Safety perspective, as exposure to flame and heat are potentially mortal dangers, quite clearly the protection provided must be of resistance and acting against as opposed to slowing down or delaying. Whilst it is generally known that human pain is felt and injury begins at skin temperatures of around 44°C (111°F), it may not be fully understood that injury will continue for as long as the skin temperature remains above this temperature, removal of heat source notwithstanding. The rate of injury is roughly trebled for each °C increase above the threshold tissue temperature - for example, the damage rate at 50°C is in excess of 100 times that at 44° to 45°C. So resistance to and removal of the heat source and cooling as quickly as possible is critical to reduce burn injury.

Flame resistant clothing should not burn, melt or disintegrate on exposure to flame for its lifetime and it should provide the required level of thermal protection consistent with the potential risk to which the wearer might be exposed. This protection must remain at the same level as it began for the lifetime of the product. This is why in the JOIFF Specification, it is a requirement that clothing made to the specification must be manufactured from inherently flame resistant materials. With flame retarded materials, if the treatment used to render the material flame retardant is removed for whatever reason, the material is flammable and/or melts on exposure to flame.
Alec Feldman - Fulcrum Consultants http://www.fulcrum-consultants.com/

Additional Documentation:

Is there a PROPER way to wear Flame Retardant Clothing (FRC)?

The article provides very important bullet points that highlights some of the serious issues with regard to the correct wear and use of flame resistant work wear. Both the JOIFF PPE Handbook and the JOIFF Specification provide further information, explanation and guidelines on such use and wear.

One further point. This article specifically refers to protective clothing. Possible exposure to heat and flame usually involves the entire body so in your Risk Assessment, as well as the requirement for protective clothing you should ensure that you consider the necessity of protection to the head, face, respiratory system, hands and feet.
As we start off 2010, I am hoping that more and more facilities that have HAZLOC's will offer their employees the use of FRC.  Although OSHA does not have a specific standard requiring FRC, they have stated it is a "recognized industry practice" and will enforce the use of FRC where there exists a danger of flash fire/burns from accidental releases.  We visit many facilities each year that do not yet have an FRC policy or program when one is badly needed.  However, this article is about those of us who do use them, BUT are using them IMPROPERLY.  Too many workers do not wear their FRC's properly.  Yes the SAFTENG audit team will write findings against this unsafe practice and when management ask us what grounds or standards we are referencing in the finding...NFPA 2113, Chapter 5.  This is the NFPA standard that OSHA has referenced in several published documents, most notably in the recently published NEP for Combustible Dust and one of OSHA's best LOI's Requirement for flame-resistant clothing in petrochemical plant covered by PSM. Here is the condensed version of what NFPA 2113 requires when when FRC are determined to be needed:

  • The organization shall define those facilities and areas of the workplace and tasks that require personnel to wear flame-resistant garments.
  • Organizations shall provide users with the instructions provided by the manufacturer on the care, use, and maintenance of flame-resistant garments, including any warning provided by the manufacturer.
  • Organizations shall instruct workers in the limitations, use, care, and maintenance of flame-resistant garments, including the use of undergarments or overgarments.
  • For maximum protection, organizations shall require that flame-resistant garments be worn as described in the manufacturer's instructions.
  • Flame-resistant garment collars shall be worn closed.
  • Sleeves and cuffs shall be worn down and secured.
  • Organizations shall require that protective neck, head, hand, and foot coverings be worn if the occupational hazard warrants their use.
  • Other personal protective equipment (PPE) shall be worn if determined as necessary from a review of the potential hazards to which workers are exposed from the hazard assessment.
  • Organizations shall NOT permit workers to wear non–flame-resistant clothing over flame-resistant garments.
  • Flame-resistant or nonmelting undergarments (closest to the skin) shall be used. An incidental amount of elastic used on nonmelting fabric underwear or socks shall be permitted

Source: - Safeteng Newsletter