Flame Resistance Clothing (FRC) program needs

In the past 20 years or so we have seen Flame Resistant Clothing (FRC) come a long way in its design, ability, and costs that is VERY MUCH in favor of the end user and businesses. However, we still see the use of FRC as a much-overlooked layer of protection in many facilities and in those facilities where it is utilized it is often times not managed properly. In fact, the vast majority of facilities we have worked at/with during our careers may have lacked formal hazard assessments, missed the inclusion of the FRC in formal written PPE programs, no FRC inspection program, and even some did not have training programs on the use, care, and limitations of their FRC. You will have to search high and low to find a bigger advocate of FRC than I and even though this layer of protection is our LAST LAYER, it is without a doubt worthy of our time and attention to ensure we are using and maintaining our FRC properly. This article is meant to provide some suggestions on what our FRC program should include. I use NFPA 2113, Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire as my guide as it is without a doubt the best guidance available! (PLEASE NOTE that when I discuss the use of FRC I am ALWAYS talking in terms of Flammable Vapor/Gas FLASH FIRE and NEVER in terms of “Arc Flash”. This is an IMPORTANT DISTINCT and one must understand the differences.)  Here are some items to consider:

Hazard Assessment

Just like 1910.132(d) that requires us to perform and certify our PPE Hazard Assessment(s), NFPA 2113 also requires a SPECIFIC Hazard Assessment to the need and use of FRC. I would recommend that ONLY a select group of personnel be permitted to conduct this type of Hazard Assessment, as you will see it requires a bit more knowledge of the use and limitations of FRC than many workers will have. NFPA suggest the Hazard Assessment include:

• A determination of the type of fire hazards present and the potential magnitude and duration of the fire hazard
• A determination of whether other control options (elimination/substitution, engineering, and administrative) can be used instead of FRC
• A determination of FRC performance needed for protection
• A determination of the need for garment decontamination where applicable

The specific Hazard Assessment used to determine the requirement for the wearing of FRC should be based on the potential hazards that workers are exposed to as part of their work duties. Factors in determining if flame-resistant garments should include:

• Proximity of the work to be performed to a fire hazard
• Presence of flammable materials during process operations
• Potential for the task being performed to increase the possibility of a flammable release, which could result from a mechanical failure such as a line breaking
• Operating conditions of the process, for example, the potential for flammable fumes or vapors
• Presence of engineering controls designed to reduce exposure to flammable materials present during normal operations (e.g. ventilation)
• Means and duration of egress within potential exposure zone (e.g., location and distance to exits, potential congestion, elevated or restricted areas, connections to lifelines/fall protection, capability of workers to escape)

NFPA suggest that these hazard assessments be revalidated every 5-years. I would also add that if your facility falls under PSM/RMP because of the flammables, any CHANGES to the use of FRC or to the PPE program regarding the FRC that this change undergoes a Management of Change (MOC) review.

Once we have established the need for FRC then comes a more difficult part of implementing and managing the FRC program. Many safety professionals have learned the hard way that FRC is a bit different than managing safety glasses within a PPE program. There are a lot of factors that drive these differences, but trust me when I say that implementing and managing an FRC program is an entirely different time and dollar eating machine! I will dare to say that a safety department will spend as much, if not more, time managing FRC issues than all the other PPE combined (including all the types of respiratory protection). This will hold true for the first several years, and as the facility becomes more experienced in their use and care of their FRC, the demands will begin to lessen over time. Also, PLEASE KEEP IN MIND that FRC is NEVER a popular program with management and workers. Even after a flash fire event where co-workers have been severely injured and even killed, the resistance to the use of FRC can be immense. And the further south you go (i.e. the hotter and more humid environments) the more resistance you may experience. But as safety professionals, we can NOT lose sight of the vital safety that FRC can add to our worker’s protection!

The determination for the need of FRC is often times straightforward; although many can be blinded by the sheer cost associated with the program and thus the decision is not so “straightforward” anymore! We do see facilities trying to “piece-meal” their FRC program and in my professional opinion, this is just IMPOSSIBLE to safely manage. What I mean by “piece-meal” is that they try to make FRC a “task specific” piece of PPE. For example, personnel opening a flammable liquid line (via line-break permit) would be required to don FRC for this specific task. I think we can all agree on this need. However, what gets missed is the workers that are doing other tasks in the area. We have seen time and time again where the workers doing the “line break” are donned in FRC, yet the workers only 10’ away working under a different work permit are not donned in FRC and yet they were clearly exposed to the same potential hazard as those making the break.

FRC should be required based on the environment/location and the potential for a vapor cloud to be present and NOT SOLELY on the task. NFPA 2113 states:

5.2* Specific Requirements for Wearing Flame-Resistant Garments. The organization shall define those facilities and areas of the workplace and tasks that require personnel to wear flame-resistant garments.

NFPA 2113 provides us with some sound logic as to how we can define the areas where FRC should be required:

1. Materials having a FLAMMABILITY degree of hazard of 4 when ranked in accordance with NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response, where flammable vapors are present in normal operations (i.e. Class I, Div. 1)
2. Materials having a FLAMMABILITY degree of hazard of 3 when ranked in accordance with NFPA 704, at temperatures above their flash points where flammable vapors are present in normal operations(i.e. Class I, Div. 1)
3. Materials having a FLAMMABILITY degree of hazard of 2 or 1 when ranked in accordance with NFPA 704 when heated above their boiling points where flammable vapors are present in normal operations (i.e. Class I, Div. 1)
4. Combustible dust (components present in the material where particle size is less than 75 microns, required ignition energy is less than 100 mJ, and moisture content is less than 10 percent), where such dust is present in normal operation (i.e. Class II, Div. 1)

NFPA 2113 also provides us with some sound logic as to how we can define SPECIFIC TASK when FRC should be required.  FRC should be required for specific tasks for employees working in areas meeting any of the following process hazards and performing a task where the assessment indicates that the work increases the possibility of loss of containment of the material:

1. Processes involving materials having a FLAMMABILITY degree of hazard of 4 when ranked in accordance with NFPA 704, where flammable vapors will be present only if loss of containment occurs (i.e. Class I, Div. 2)
2. Processes involving materials having a FLAMMABILITY degree of hazard of 3 when ranked in accordance with NFPA 704, at temperatures above their flash points where flammable vapors will be present only if loss of containment occurs (i.e. Class I, Div. 2)
3. Processes involving materials having a FLAMMABILITY degree of hazard of 2 or 1 when heated above their boiling points when ranked in accordance with NFPA 704, where flammable vapors will be present only if loss of containment occurs and experience indicates a frequency of incidents due to equipment design or arrangement (i.e. Class I, Div. 2)
4. Processes involving combustible dust [components present in the material where particle size is less than 75 microns, required ignition energy is less than 100 mJ (1 micron (μ) = 10−6 m), and moisture content is less than 10 percent], where such dust is present in enclosed systems and loss of containment is required to generate a dust cloud (i.e. Class II, Div. 2)

Examples of combustible dust environments include locations of operations where charging equipment is used with dusty materials, locations where dust is present on equipment or structural members, and areas where filter bags in dust collectors are changed.

NOTE: Engineering controls designed to reduce exposure to materials present in normal operation and experience should be considered in the evaluation of areas or tasks requiring the wearing of flame-resistant garments. Where multiple tasks require the wearing of flame-resistant garments, consideration should be given to standardization of the garment as normal work wear for the area.

 

Misuse of FRC

Without a doubt, the number one issue we see with regards to FRC is the improper use! Sleeves rolled up and the “Elvis mode” (i.e. buttons undone down to belly button!) are the most common. For those at PSM/RMP facilities remember that we need an RAGAGEP in relation to our FRC usage – NFPA 2113 is a great choice! In 2113, NFPA states the following in regards to donning practices of FRC: (emphasis added by me)

5.1.3 For maximum protection, organizations shall require that flame-resistant garments be worn as described in the manufacturer’s instructions.

5.1.4 Flame-resistant garment collars shall be worn closed.(i.e. NO Elvis mode!)

5.1.5 Sleeves and cuffs shall be worn down and secured.

…
…

5.1.8* Organizations shall not permit workers to wear non–flame-resistant clothing over flame-resistant garments.

5.1.9 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.

Users should be cautioned that wearing overgarments or other PPE that are not flame-resistant over FRC can compromise the performance of their FRC. Clothing or items worn over flame-resistant garments that are not flame-resistant, such as jackets, rainwear, and high-visibility vests, can ignite and transfer significant heat through the flame-resistant garment and to the exposed body areas such as the head and face, causing severe burn injuries.

As I have stated before, it is common to find “fire watch” personnel in FRC areas that are using non-FR high visibility vests. This personnel is working in proximity of many ignition sources and such they need to have on FR rated vests over their FRC. The same would go for CS Attendants if they are required to wear a high vis vest, working in units requiring FRC. Another area that we see abuse is “truck unloading/loading” activities. Personnel working in FRC areas, but are unloading corrosives can oftentimes be found wearing rain slickers suits over their FRC clothing. This is a MAJOR NO-NO for FRC. We also see the use of non-FRC winter coats being worn over FRC. Bottom line, our FRC program should contain a CLEAR REQUIREMENT that the FRC be the outermost garment in ALL PPE ensembles – NO EXCEPTIONS!

Another area we see and mention during audits/assessments is the use of improper undergarments. The most common error we see are the ever-popular shirts made with the stretchy nylon material. As you can imagine it does not go over well when a facility’s safety award shirt is written up as a safety finding during an audit/assessment because it is a “synthetic or synthetic blend” material and violates their own RAGAGEP (NFPA 2113). Much like what our electrical workers have been following for years under NFPA 70E, now to our operators and mechanics using FRC MUST also now ensure their undergarments are melt-resistant. Certain synthetics or synthetic blends wore as undergarments can be inappropriate for use under flame-resistant garments since the transferred heat could cause them to melt. Undergarments with melt-resistant properties are recommended (e.g., cotton, aramid, wool).

Another form if “misuse” is using FRC that is DAMAGED and man have we seen some “damage”. I would say the worst we have seen was a contractor wearing a set of coveralls that were Medium in size and he without a doubt needed an XL-XXL. However, the garment was in such disrepair that he could actually get into them. And I am not exaggerating! Sadly this contractor was the team supervisor, meaning the facility issued the contractor work permit directly to this gentleman as he stood before them in these FRCs. Needless to say, we addressed their permitting deficiency! NFPA 2113 provides us with some great parameters that we should implement inout PASS/FAIL inspection protocols.

1. Missing components (pockets, linings, reflective striping)
2. Areas of fabric that show a significant reduction of fabric thickness (by more than 25%) as compared to new garment fabric material when measured using an appropriate fabric thickness gauge
3. Discoloration of fabric over more than 10% of the garment that cannot be accounted for
4. Holes in or abraded areas of the outer fabric layer that are greater than 645 mm² (1 in.²)
5. Individual rips, tears, or punctures in the garment fabric that are longer than 25 mm (1 in.) in length
6. Individual seams showing separation or thread loss for a distance greater than 25 mm (1 in.) in length
7. Missing, corroded, or nonfunctional hardware

Although numbers 2 and 3 are somewhat subjective, it not such that we cannot measure/quantify the deficiency. I love the quantification of the size of the hole(s) and tears. Basically, any hole that is larger than 1 square inch and any rip/tear that is longer than 1” FAILS the inspection and the garment must be removed from service for repair or discarding. The last item is also one that would fail a large portion of FRC in use at many facilities… “missing, corroded, or nonfunctional hardware”. This means that if the sleeves will NOT fasten closed at the wrist because the button/snap is damaged/missing the garment FAILS its inspection. Yes, I am aware that some will claim this is just too picky and is not “realistic”; however, when the need arises that we need our FRC to perform, it is usually a life/death situation and we need EVERY ASSURANCE we can get that it will perform as designed. Using underperforming FRC is merely providing a FALSE SENSE of safety in some very high-risk areas/activities.

Lastly, the most sensitive matter to deal with… size and fit. Depending on the type of FRC your business uses, your FRC may suffer “shrinkage” through its laundering and believe it or not this is an issue for the FRC performance. In other words, tight-fitting FRC does NOT perform as well as proper fitting FRC. We also lose effectiveness when the FRC is too loose.  Have you ever been conducting an audit interview and you state the person’s name as it appears on their name tag, only to find out that it is not their uniform? Take a look at the fit of the FRC and ensure that it is NOT too tight or loose. I am not against personnel sharing FRC, as long as we do not compromise the performance of the FRC because of improper fit.  NFPA 2113 states:

4.3.5* For optimum protection, garments shall be selected that are not tight fitting.

A.4.3.5 Flame-resistant garments should fit for maximum protection and comfort on the job. Users should be aware that the fit of the garment (i.e., too tight or too loose) can have a direct influence on how much protection can be provided by a particular garment or garment system.

 

Testing of FRC

Probably my favorite requirement of NFPA 2113 is section 7.18 in which the code requires a sampling of FRC be removed from service to be inspected and tested to the performance requirements of NFPA 2112, Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire. Those of you that have managed an FRC PPE program have most likely wondered to yourself… “how long do these garments provide protection?” I know it was always a concern I had, especially when the business used cotton-treated FRC! Yes, there are pro’s and con’s to each type of FRC. Some are cheaper than others, yet those that are cheaper usually have a shorter service life. I have written about and posted several safety alerts regarding FRC that was found to have been laundered/treated improperly and thus lost much of its effectiveness! I have also warned time and time again, against the practice of allowing workers to take home their FRC and launder it at home.

But now we have a requirement in our RAGAGEP (if we have adopted NFPA 2113 at our facility) that we are to remove a sampling of pieces at established timeframes in order to have them tested to verify the garment still provides the intended level of protection. For those in PSM/RMP flammable processes, we can just consider our FRC as a piece of “covered equipment” that needs to be in the MI inspection/testing program. Unfortunately, NFPA does not provide a sampling strategy for how many garments need to be tested and at what frequency. But it is clear that some form of testing is necessary to validate that the overall FRC program is providing a level of protection. I would personally treat this “sampling” the same as my IH sampling, which ensures I have an ample number of samples from a cross-functional group to provide me with enough VALID data that I can be somewhat ensured that my workers are being protected. In my sampling, I would seek out those groups that I know, or believe, to be the ones that have the harshest work environments and therefore their FRC is seeing more damaging exposures. I would also review chemical exposures and if I had a chemical that the FRC manufacturer warned against having their garment exposed to then I would, of course, test these garments and quite possibly at a higher frequency than others. Of course, it should go without saying that if we have this type of arrangement, we should be seeking out other FRC that would not be susceptible to the chemical of concern. Bottom line, we do not want to fool ourselves by merely testing a couple of the engineer’s FRC garments that are in pristine condition and base our actions on these limited results. We want to sample the worst case and work backward!

And please do not forget about the contractors! They too should have these programs and address these concerns. There is a large faction of contractors that use the “disposable” style FRC and this is fine, but trust me when I say these disposable garments are TRULY disposable and often times a worker will go through multiple sets of FRC in a single work day; especially those working in dirty-harsh environments.

I strongly encourage everyone to get both NFPA 2112 and 2113, but without a doubt safety professionals and process safety professionals working with flammable atmospheres and processes “must have” 2113. I am not even sure of their costs, as I get my codes via the NFPA.org on-line database, but this is a MUST HAVE for us to have in our toolbox when considering FRC use and implementing an FRC program.