Way back in 1994 when I was implementing my first FRC program there was a great debate on the options that would be made available to operators, maintenance, engineering, EHS, and QA/QC personnel who perform work within a HAZLOC. This debate was of course driven by costs vs. risks and luckily I was working for a Plant Manager that put safety above all else. But the battle was not fully won, as the debate raged on regarding those who would do “limited work” or just access the HAZLOC on an infrequent basis (less than 3 times per week for less than 15 minutes each time). For these persons, the dreaded “lab coat” was the preferred choice until…
A vendor showed us a test video of a flash fire with mannequins wearing lab coats. The fire flashed across the ground/floor and as the heat and flames rose, so did the lab coats on each mannequin. I have searched for weeks in all my hard drives and I can not find this video, but I know it exists. I have reached out to my insurance connections and FRC contacts in the hopes they have a copy I can share. But ever since I watched that video I have been dead set against lab coats being used in process areas.
At this same meeting, the FRC professional from one of the largest manufacturer of FRC also informed us a “limitation” of lab coats…
When a worker is performing work in a lab, i.e. bench work, the FRC needs to be effective from the waist up as the highest probability of a fire comes from the benchtop – NOT the floor. Hence why a lab coat can be open at the bottom and still be effective PPE in a laboratory setting.
That same year (1994) OSHA revised their PPE Standard (1910.132) to require a Hazard Assessment to establish the hazard controls and most notably the PPE needed for workers doing their jobs. This assessment had to consider the LIMITATIONS of the PPE when selecting the proper PPE. We must also cover the PPE’s limitations in our PPE training. Thus when doing our hazard assessments how does one come to the conclusion that a lab coat is an acceptable alternative to pants/shirts or coveralls?
(emphasis by me)
1910.132(d) Hazard assessment and equipment selection.
1910.132(d)(1) The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:
1910.132(d)(1)(i) Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
1910.132(d)(1)(ii) Communicate selection decisions to each affected employee; and,
1910.132(d)(1)(iii) Select PPE that properly fits each affected employee.
…
1910.132(f)(1) The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following:
1910.132(f)(1)(i) When PPE is necessary;
1910.132(f)(1)(ii) What PPE is necessary;
1910.132(f)(1)(iii) How to properly don, doff, adjust, and wear PPE;
1910.132(f)(1)(iv) The LIMITATIONS OF THE PPE; and,
1910.132(f)(1)(v) The proper care, maintenance, useful life and disposal of the PPE.