By Scott Margolin, Co-Chairman, The Partnership for Electrical Safety
If you’ve ever asked the question, or even just wondered “Does my company need arc-rated clothing?” chances are very high the answer is yes, even if the answer you got at the time was no. That’s because many people misunderstand one or more of four major factors: the hazard, the standard, OSHA’s position, or mitigation strategies. If you have any facilities which use electricity at 50 volts or greater, or work on them (and aren’t an electric utility) NFPA 70E applies to you. That’s pretty much everyone in the U.S.
Arc flashes can occur in essentially any energized equipment, including low voltage; the number one for injuries and fatalities is “only” 480V. There’s no such thing as a small arc flash when you’re the person in its path…3 cals is smaller than 6 cals, but they all produce extraordinary temperatures (30,000°F, four times hotter than the surface of the sun) and significant quantities of molten metal. Molten copper is >1900°F and can burn exposed skin and ignite flammable clothing. The vast majority of catastrophic injuries and fatalities are caused by the arc igniting flammable clothing, not by the arc itself. The remedy for this is simple – don’t work energized if you don’t have to, and don’t wear fuel. All non-AR/FR clothing, including 100% cotton, is fuel. Too many people have emerged from hazard analysis specifying 100% cotton; this is worse, both with regard to safety and legally, than doing nothing. Cotton is NOT PPE – it ignites easily, burns hotter, spreads quickly, and is harder to extinguish. When someone specifies cotton, they are acknowledging a thermal hazard (by banning meltable fibers), but cotton is not protective, and is not compliant with OSHA or NFPA 70E as the outer layer.
You may be able to engineer the hazard down in frequency and down in incident energy, but it cannot be eliminated during energized work. Despite the best training, gear, and behavioral safety in the world, arc flashes continue to occur frequently. The only remedy given this fact set is arc-rated clothing and associated PPE. That’s why OSHA and 70E both require it.
NFPA 70E addressed arc flash over twenty years ago, in 2000; the standard makes it clear that anyone working on or near energized electrical gear at 50V or above must be provided with AR clothing and other PPE. 70E provides excellent hazard analysis tools, incident energy estimation tables, and risk mitigation procedures. One of those tools helps determine if an arc flash hazard exists; if the answer is yes (hint: it’s almost always yes), all the appropriate PPE must be worn. 70E encourages de-energization whenever possible and allows for hot work only when de-energizing is infeasible.
During the first several years after arc flash was added to 70E, many companies brought their electrical programs into compliance, protecting over a million workers in the process. However, in the U.S. today about 500,000 industrial electrical workers still are not being provided AR clothing, despite a clear standard and OSHA statements, enforcement, and fines. The standard has dramatically reduced serious injuries and fatalities among the protected population, but unprotected workers continue to suffer unnecessarily.
OSHA prohibits any clothing which could increase the extent or severity of injury in an arc flash; this prohibits any and all flammable clothing, including 100% cotton. They also classify AR clothing as PPE, meaning the employer is required to provide the garments, and they require that the AR garments have an arc rating greater than the predicted incident energy exposure.
OSHA’s relationship with 70E is relatively simple: OSHA tells us what we SHALL do, but not how to do it. NFPA standards (including 70E) tell us how to accomplish what OSHA requires – they gather experts in the relevant industries and create standards that instruct the industry how to protect their workers and comply with OSHA. In other words, OSHA tells us we shall provide a workplace free of recognized hazards, and where we cannot engineer the hazard out, we shall provide appropriate PPE. NFPA 70E picks up where OSHA leaves off and tells us how to conduct hazard analysis and how to protect workers. Thus, OSHA and NFPA 70E work in tandem, and have since the beginning. OSHA encouraged the NFPA 70E committee to include the arc flash hazard in the late 90s; OSHA’s top electrical expert was on the 70E committee during the writing and many revision cycles since; and OSHA cites 70E regularly. OSHA has also made it quite clear that one cannot sell liability; that is, the host employer is responsible for providing incident energy information to any contractors they may employ.
There are several common pitfalls here:
Some companies claim they do not work energized. However, there are energized work steps in every de-energization process: de-energize, confirm absence of voltage, re-energize, and confirm presence of voltage. PPE is still required. The only truly “never energized” work is pulling wire in a building not yet connected to the grid or a generator.
Some companies claim incident energies are too low to require PPE. This is wrong on many levels. Those calculations generally assume the worker is 18 in and that the breaker will clear as designed. However, people are often closer, and breakers often stick (require more cycles than when new). Both of these variables will cause significant increases in incident energy. Molten metal, as noted earlier, is a significant ignition hazard and is created by virtually all arcs.
Some companies continue to believe the myth that cotton is protective or compliant. It is neither.
Some companies provide a few kit bags of 25 or 40 cal suits, to be shared among dozens or hundreds of workers who are wearing flammable clothing such as 100% cotton, and then claim compliance has been achieved. This may be true in theory, but it is almost never true in reality. Kits get left at the office, in the truck, or are borrowed by someone at another job site. Workers refuse to wear shared gear due to hygiene issues, won’t take the time to find and don them, or take them off too soon. The majority of serious injuries among workers who have been issued AR clothing occur in these types of task-based programs, because the injured worker was not wearing the PPE.
Some companies simply refuse to provide AR clothing based on long-outdated ideas around comfort, cost or heat stress. But today’s AR pants and shirts look, feel, weigh, wash, and wear just like regular street clothing, including many of the same brands and styles, and most cost only a little more. And note that no single layer, breathable apparel is a contributor to heat stress, whether it is FR, AR, or flammable, short sleeve or long sleeve, light or normal weight; Heat stress is caused by poor hydration, lack of shade, lack of rest breaks, and some illnesses or medications. Clothing helps cause heat stress when it is non-breathable (rainwear, Tyvek, etc.) or multiple layer (40 cal suits, etc.) …not when it’s breathable single layer AR or FR clothing.
Does your company need arc-rated clothing? OSHA and NFPA 70E agree – If you work on or near energized electrical gear above 50 volts, the answer is almost certainly yes. Arc flash doesn’t occur as often as slips/trips/falls, but the results without PPE when it does are almost always catastrophic. Unlike many hazards, the remedy is amazingly simple: don’t work energized and don’t wear fuel. ESW