Call me crazy, but this just blew me away. And once again we find ourselves faced with an “industry practice” vs. “RAGAGEP”. We were at a facility several years ago where pieces of equipment are painted and this painting is a huge pride of the manufacturing sector and hence they have some very tight QA controls around the painting process. This industry uses 99% Polyester and 1% carbon fiber garments to control static generation by the workers in the painting process. These 99% Polyester and 1% Carbon Fiber garments are used worldwide in “clean room” applications, but there is just one small difference (sarcasm)… the clean rooms where they are used are NOT a hazardous location (e.g. flammable atmospheres). So let’s look at the concerns from using the garment made of 99% Polyester and 1% Carbon Fiber in a Hazardous Location (HAZLOC)…
These suits are designed for controlling electrostatic discharges around equipment that is impacted by such charges. They are NOT, should not be, used in a Hazardous Location such as a Class I, Div 1, or 2 classified area/HAZLOC.
Let’s start with a basic compliance requirement. We have workers who are assigned to work their entire shift in Class I, Div 1, and 2 classified areas. This exposes them to a recognized hazard (i.e. flash fire). When we do our certified PPE Hazard Assessment for these jobs how do we justify placing these workers in a garment that is 99% polyester? 1910.132(d)(2)
The suit may be a means to control static the worker generates (much more on this below), but there are dozens of other static generators that we must control, and when we have a failure of this PRVENETION layer, we have to turn to our PROTECTION and MITIGATION layers which is where the Flame Retardant Clothing (FRC) comes into play. Now OSHA has said that if a process was covered by the PSM standard because the HHC was flammable, they would cite using 1910.132(d)(2) if the personnel working in/on the process were not afforded FRC protections.
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OSHA Requirements: Based on the large quantity of flammable materials (liquids, solids, and gasses) and reactive chemicals that are handled/processed with associated on-site movement activities at your facility, we believe any worksite assessment required by OSHA or NFPA 2113 would conclude that: 1) flash fire hazards do exist on a continuous basis in various areas (including but not limited to operating, storage, loading/off-loading, etc.) at your facility; and 2) when employees such as operators and maintenance personnel are in the areas where flash fire hazards exist, your employees must wear flame-resistant garments/flame-resistant clothing to protect against the flash fire hazards. It is possible, then, that if an employer has such flash fire hazards present and fails to address them, OSHA could issue a citation for a violation §1910.132(a), the general requirement to provide protective equipment, including protective clothing (emphasis added), when necessitated by a hazard. A citation could be issued whether or not there had been an accident that precipitated the inspection. Additionally, since your facility is covered under the PSM standard, and you have determined that a flash fire hazard exists to a degree that you decided to institute a plant wide flame-resistant clothing program, you are required by §1910.119(f)(1)(iii)(B) to include in your operating procedures any “precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment” (emphasis added). This necessary PPE includes, in your case, flame-resistant clothing for your employees. Further, OSHA would expect that your mechanical integrity procedures [1910.119(j)(2)] utilized by your maintenance workers would include your requirement to wear flame-resistant clothing in and/or near covered processes which have flash fire hazards. If your operating or mechanical integrity procedures include requirements for employees to wear flame-resistant clothing in or near PSM-covered processes which include flash fires and it is determined by OSHA that employees are not wearing the specified PPE, the employer may be cited for failing to implement their operating or mechanical integrity procedures [§1910.119(f)(1) or §1910.119(j)(2), respectively]. https://www.osha.gov/laws-regs/standardinterpretations/2006-03-07 |
Let’s now look at some limitations these suits present.
The garments have 1-2% carbon fiber which acts at the conductive path for the static. But as with all electrical charges, we have to provide a path to ground in order to control the charges; without this path to ground, the garment will accumulate the charge and discharge it when it does find that path to ground, usually via a grounded conductor like a vessel, pipe, handrail, etc. This means we may be putting the charge through an uncontrolled release point which could be within a flammable atmosphere.
SAFTENG personnel is assigned BOTH “EH” rated and “ESD” rated footwear. We wear our EH-rated footwear as our “every day” safety footwear, but we can don our ESD footwear when we are working in HAZLOCs. When we were at this manufacturer we had on our EH footwear but were required to wear these garments for QA/QC requirements. As I explained how this was a push-pull scenario and that I need to go back to my PPE bag to get my ESD footwear I was told “it’s ok”. Wearing EH-rated footwear while wearing a static controlling garment is a WASTE OF TIME, as my EH-rated footwear INSULATES me from the path to ground and thus my 99% Polyester and 1% Carbon Fiber garment becomes an accumulator! It will hold those charges until the charges find a path to ground such as a workbench that I walk up to. The charge will then “jump” across the gap from my garment to the ground table and if there is a flammable atmosphere present in that space I can very well have ignition, all while wearing a garment intended to control static!
All of this means that when using an anti-static garment, the worker must be grounded at ALL TIMES. This means that as soon as the static is generated, it has a path to ground, one that has a VERY LOW resistance, so that the energy generated does NOT build up to a dangerous level. Remember, most of our solvents and alcohols have MIE’s less than 1 mJ so we are talking about very low energy levels. In order for the worker(s) to be grounded 100% of the time, this means we specify ESD-rated footwear, which I have written about numerous times. But to remind those who may not recall, this ESD rated footwear should be tested regularly, workers need to be PROHIBITED from using any type if inserts as most of these inserts will be insulators, and the flooring upon which they walk/work MUST have a resistance to ground of no more than 10 ohms. All of this comes into play when providing that path to the ground! Painting/Coating of floors has become very popular in recent years and this can become very problematic if it is not done properly AND its resistance verified afterward. The same goes with ergonomic floor mats – these are also insulators, although we can buy mats that are designed for these flammable atmospheres, most businesses are not aware of this.
For more on this, please read my 2011 article: Flammable Liquids… Static Generation and the floor we walk on!
https://www.safteng.net/index.php/free-section/safety-info-posts/flammable-liquids/1295-flammable-liquids-transfer-static-generation-and-misunderstandings
Keep in mind, these suits are used “industry-wide”, this is close to hundreds of locations in the USA where this 99 % Polyester and 1% Carbon Fiber garment is used in HAZLOCs. Heck, it is so prevalent, the retailers actually have a class of garment called “paint room” and will then specify the manufacturer’s by name as each manufacturer will have different style requirements for their business – the one common thread (pun intended) is that they are 99% Polyester and 1% Carbon Fiber.
In the semiconductor industry, we had many of the same QA/QC and safety concerns for static and lint in our cleanrooms. We also had major challenges with electrical PPE that would protect against the hazards, AS WELL AS meet the QA/QC requirements. It is NOT cheap, but there are garments available that will be BOTH “anti-static” and FR rated – including garments that will provide low-level Arc-Flash protection.
Bottom line… a 99% Polyester and 1% Carbon Fiber garment has NO business being worn in a Class I HAZLOC. It is the absolute worst garment to be worn in this location. And to make matters worse, the electrical workers who would be called to do electrical work in this area will be donning the same garment with their EH footwear!
Here are a few more of my articles on static and flammables that you may find helpful….