OSHA Revises 1910.269 Compliance Dates
In April of 2014, OSHA revised CFR 1910.269 mandating that certain employers must provide their employees with protective clothing that will not melt, drip, or ignite and that will not contribute to injury. Given the challenges the market is having adapting to this sizable regulatory shift, OSHA has released new 2015 compliance milestones.
Even though OSHA is being sensitive to the challenge the market is experiencing by extending the compliance dates, we at Bulwark are still fielding a number of questions from our customers. Please reach out to your Bulwark representative with any questions you may have. In the meantime, here are answers to our most common 1910.269 inquiries
Will I be able to comply with the new law by layering FR garments? Yes, layering is allowed and is one way to achieve an arc rating greater than or equal to the incident energy that a worker could possibly be exposed to.
NOTE: The total arc rating of a layered clothing system must be arc tested as a composite; simply adding the arc ratings of separate clothing layers is not enough. Bulwark has one of the largest databases of outer layers over base layers. Click here to view our Layering Summary
How do I know I am specifying the right clothing for my employees? If clothing is labeled as meeting the requirements of ASTM F1506-10a (or ASTM F 1891 for rainwear) and has an arc rating sufficient to protect against the incident energies identified in your hazard/risk assessment, you can feel confident about your selection.
Do the changes in OSHA 1910.269 include jackets and rainwear? Yes. The final rule requires that the outermost layer of clothing be flame resistant/arc rated. Compliant jackets/outerwear must meet the requirements of ASTM F1506-10a; compliant rainwear must meet the requirements of ASTM F1891.
Do the changes in the regulation affect my contractors? All requirements mandated by the revised OSHA 1910.269 regulation apply to contractors who must wear PPE that meets the level of performance indicated by the results of the host employer’s hazard/risk assessment.
My linemen are in FR shirts and non-FR jeans now. What do we need to do to comply with the new law? Non-flame resistant/non-arc rated pants are no longer acceptable under the new regulation, even if they are made of heavy weight natural (non-melting) fibers. Workers are now required to wear flame resistant/arc-rated clothing – which should cover the entire body.
Is it possible that I won’t have to make any changes in my FR clothing program? Yes, if an organization has already completed a hazard/risk assessment and has outfitted its employees in flame resistant clothing with an arc rating greater than or equal to the incident energy identified in your assessment, you may not need to make any changes.