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OSHA 1910.269 Final Rule FAQs

1. What is OSHA 1910.269?
 OSHA 1910.269 is the standard for operation and maintenance of electric power generation, control, transformation, transmission, and distribution lines and equipment. The Final Rule, which was announced on April 1, 2014, implements significant changes to utilities’ requirements for protecting employees from electric arcs and using flame resistant clothing. Among other changes, the Final Ruling requires a complete hazard assessment and considers flame resistant (FR) clothing as PPE.


2. When is the enforcement date(s) for the new regulation?
    January 1, 2015: Employers must complete their hazard assessment.
    April 1, 2015: Employers must provide appropriate arc-flash PPE for employees.


3. How will the regulation affect my current FR program?
    It is now mandatory for employers to provide flame resistant and/or arc-rated clothing for all electrical workers that are or could be exposed to an electric arc.


4. What are employee FR clothing requirements?
    Employers are mandated to ensure that the outer layer of FR clothing worn by employees (excluding certain head, hands and feet PPE) is flame resistant under   any of the following conditions:
  • The employee is exposed to contact with energized circuit parts operating at more than 600 volts,
  • An electric arc could ignite flammable material in the work area that, in turn, could ignite the employee’s clothing,
  • Molten metal or electric arcs from faulted conductors in the work area could ignite the employee’s clothing, or
  • The incident heat energy estimate exceeds 2.0 cal/cm2 (p. 1469)

     

5. What are the requirements for feet protection?
   When the employee is wearing heavy-duty work shoes or boots, arc rated protection is not necessary (I)(8)(v)(B). As far as payment for work shoes and work boots, this is addressed in OSHA 1910.1329(h)(2) “The employer is not required to pay for non-specialty safety-toe protective footwear (including steel toe shoes and boots)… provided the employer permits such items to be worn off the job-site.” If the employer requires EH-Rated boots or dielectric overshoes, the employer could be responsible for payment as PPE.

6. What are the head protection requirements?
  • A face shield with a minimum arc rating of 8 cal/cm2 for single-phase open-air exposures greater than 9 cal/cm2 and three-phase exposures greater than 5 cal/cm2
  • An arc rated balaclava is required for single-phase exposures greater than 13 cal/cm2 and three-phase exposures greater than 9 cal/cm2
  • Balaclava arc rating must be a minimum of 4 cal/cm2 less than the exposure
  • No head protection is required for single-phase exposure of 8 cal/cm2 or less and three-phase exposure of 4 cal/cm2 or less (p. 1596)

7. Is there a requirement for hand protection?
    (I)(8)(v)(A) “Arc-rated protection is not necessary for the employee’s hand when the employee is wearing rubber insulating gloves with protectors or, if the estimated incident energy is no more than 14 cal/cm2, heavy-duty leather work gloves with a weight of or at least 407 gm/m2(12 oz/yd2).”

8. Is the employer responsible for paying for FR clothing?
    Yes, 1910.269 mandates employers pay for and provide FR/arc rated clothing for employees that are or could be exposed to an electric arc.

9. What are the costs to the employer?
    OSHA addresses the total estimated cost in the Final Rule in page 696. Based on eight sets, which is in the middle of the number of sets recommended by commenters, the Agency estimates a cost of $1,534.00 per employee (average cost of $191.75 per set) or an annualized cost of around $452.88 per employee to meet the new requirements.
   
A suggested approach to meeting the PPE requirements for the revised Final Rule is to issue each new hire an allowance of $1,534.00, and each employee an annual allowance of $455.00. Doing so ensures compliance with the Final Rule without cost to the employee, while still allowing the employee to purchase additional or specialized with their own funds when they wish.

10. Who is responsible for the inspection of FR Clothing? What if a uniform provider offers this service?
      The employer is solely responsible for inspecting and maintaining the integrity of FR and arc-rated clothing for all employees. If you have a uniform service, this “does not absolve employers” of these responsibilities. With or without a uniform service, the employer is ultimately responsible the proper inspection and maintenance of FR clothing for each employee.

11. Is washing FR clothing at home allowed under the new Final Rule?
      Yes. Even though FR clothing is designated as PPE and requires employer oversight, OSHA clearly does not prohibit home laundering of FR clothing. The Final Rule does not require employers to launder protective clothing for employees, and does not assume any additional cost in having employees launder their clothing at home. Page 1097 states that “there is generally no additional costs to employees over that of laundering normal (non-flame- resistant) clothing.”

Important note: Employees washing their FR may generally follow the manufacturers’ care instructions that come with the garment (Tr. 305-306, 1373-1374). However, “To comply with 1910.132 or 1926.95, employers cannot simply instruct their employees to follow manufacturers’ instructions.” The employer is responsible for training the employees on proper laundering procedures, and must periodically inspect the garments (page 709).
 
Your job is tough…. Managing your safety apparel purchases shouldn’t be. Contact us today, and find out how we may be able to help you comply with OSHA 1910.269 without the hassle.
Slate Rock Safety Outfitters
Call: 866-783-7977 x1
Email: [email protected]
Visit: www.SRSOutfitters.com
 
 

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