In 2023, I began taking issue with the condition of Flame Retardant Clothing (FRC) being used in REQUIRED areas and tasks. We see garments that in no way would pass a “routine inspection” per NFPA limitations. My go to RAGAGEP for this is NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Short-Duration Thermal Exposures from Fire. This NFPA standard (specifically A.7.1.8, criteria used for determining when to retire or repair flame-resistant garments) is quite clear in what a pass/fail criteria must be. The standard also sets the frequency for these “end-user” inspections. BOTH requirements MUST be part of the facility’s written PPE Program and training materials. But in most cases, the host is quick to throw the “contractor” who provides the garments and launders the garment under the proverbial bus, opening the pandora box of who is a PSM/RMP contractor.
Usually, “uniform contractors” would fall into the “incidental contractor” bucket; however, I make the argument that when that uniform is a piece of actual PPE that is REQUIRED by the employer, then that contractor providing the FRC uniform and, more importantly, has the care and maintenance contract for the FRC garments, that contractor becomes a PSM/RMP contractor.
So when a management group’s response to FRC issues is to blame the contractor they selected and hired to provide the FRC, launder it, and repair it, it is pretty easy to connect the dots.
NOTE: I have written articles about FRC and its care/maintenance needs. These are critical aspects of an FRC program and are usually ripe with issues. One of our more significant issues from a PSM/RMP audit in 2023 was the ERT members had their logo silk-screened onto their everyday FRC coveralls. This was a 12″ x 16″ emblem on the back of the coverall, which exceeds what NFPA 2113 permits in non-FR attachments such as the company logo or name patch.