In mid-June, OSHA proposed updates to it existing standard for the construction of electric power transmission and distribution installations, along with changes to its general industry standard addressing the maintenance and repair of electric power generation, transmission, and distribution lines and equipment.

Both construction and general industry standards now include new provisions regarding flame-resistant clothing. The proposal also updates references to consensus standards in Sections 1910.137 and 1910.269. A new appendix (F) helps employers comply with the protective clothing requirements.

For the full text or PDF of the proposal, go to www.gpoaccess.gov, click on Federal Registers under Executive Resources, and browse the table of contents from back issues — 2005 — click Go — click Wednesday, June 15, 2005.

Significant risks

Risks addressed by OSHA’s proposal are significant. The 227,683 employees performing work involving electric power generation, transmission, and distribution are exposed to a variety of significant hazards, such as falls, electric shock, and burns. OSHA estimates 444 serious injuries and 74 fatalities occur annually among these workers.

Over a 45-year working lifetime, more than 14 of every 1,000 of these employees will die from risks such as electric shock, electrocution, electric arcs, fires, explosions, falls and being struck by, struck against, or caught between objects.

Burn injuries are very serious and costly. Eighty-four percent of reported burn injuries were fatalities or required hospitalization, according to OSHA research. Eighty-seven percent of the accidents for which the severity of the injury was noted involved third-degree burns — extremely painful and costly burns typically requiring skin grafts and leaving permanent scars.

FR clothing required

OSHA’s existing clothing requirement in Sec. 1910.269 does not require employers to protect employees from electric arcs through the use of flame-resistant (FR) clothing. It simply requires that an employee’s clothing do no greater harm.

Now OSHA believes the standard should be revised to require the use of flame-resistant clothing, under certain circumstances, to protect employees from the most severe burns.

OSHA reports the electric power industry is beginning to recognize this need — many employers now provide flame-resistant clothing to employees. Plus, ASTM is writing standards that provide for arc ratings of protective clothing, and the National Fire Protection Association also recognizes the need to protect employees working on energized equipment from the hazards posed by electric arcs.

Key provisions

Here are some key provisions regarding protective clothing in OSHA’s proposal:

Employers must assess their workplace to determine if each employee is exposed to hazards from flames or from electric arcs.

For each employee exposed to hazards from electric arcs, the employer must make a reasonable estimate of the maximum available heat energy to which the employee would be exposed.

Employers must ensure each employee who is exposed to hazards from electric arcs does not wear clothing that could melt onto his or her skin or that could ignite and continue to burn when exposed to the heat energy estimated.

Clothing made from the following types of fabrics, either alone or in blends, is prohibited, unless the employer can demonstrate that the fabric has been treated to withstand conditions that may be encountered or that the clothing is worn in such a manner as to eliminate the hazard involved: acetate, nylon, polyester, rayon.

Employers must ensure an employee wears clothing that is flame resistant under any of the following conditions:

• (A) The employee is subject to contact with energized circuit parts operating at more than 600 volts,
• (B) The employee’s clothing could be ignited by flammable material in the work area that could be ignited by an electric arc, or
• (C) The employee’s clothing could be ignited by molten metal or electric arcs from faulted conductors in the work area.

Employers must ensure that each employee who is exposed to hazards from electric arcs wears clothing with an arc rating greater than or equal to the heat energy estimated. This clothing will protect employees exposed to various levels of heat energy from sustaining severe burn injuries in areas covered by the clothing, according to OSHA. Appendix F to Subpart V contains information on the selection of appropriate clothing.

According to OSHA research, much of the flame-resistant clothing available today comes with an arc rating. An arc rating indicates that a fabric is not expected to transfer sufficient thermal energy to cause a second-degree burn when tested under standard laboratory conditions exposing the fabric to an electric arc that radiates an energy at or below the rating.

Unlike many OSHA standards, this proposal would not require that employers provide protective clothing at no cost to employees. But OSHA is considering including an employer-payment requirement in the final rule and is seeking comments on the issue.

Specifically, OSHA wants to know:

Are there types or weights of protective clothing that employees typically wear outside of work? Do employers restrict the types or weights of protective clothing that employees are allowed to wear outside of work?

Do employers typically provide the types of protective clothing required by the proposal at no cost to employees? Do some employers provide certain types or weights of protective clothing at no cost to employees, while requiring other types or weights of protective clothing to be paid for by employees? Should OSHA include an employer-payment requirement for heavier weights or particular types of protective clothing, but not lighter weights or other types?

If so, what weights or types of protective clothing should be exempt from an employer-payment requirement?