OHS Public Consultation 2014: Part 18 Personal Protective Equipment
By Terry Becker, P.Eng., and Dean Dietrich
In 2014, Alberta Occupational Health and Safety (OHS) held public consultation on a number of issues that pertain to worker safety and updates to Alberta’s OHS Regulations. One of the items brought up related to electrical hazards; specifically clarification related to arc flash in Part 18 Personal Protective Equipment (PPE).
In 2009, Alberta’s OHS Code stated:
Flame Resistant Clothing
Use of flame resistant clothing
232(1) If a worker may be exposed to a flash fire or electrical equipment flashover, an employer must ensure that the worker wears flame resistant outerwear and uses other protective equipment appropriate to the hazard.
This rule will remain in effect but there will be additional clauses added to it, including:
232(1.1) If a worker may be exposed to a flash fire, the employer must ensure that the worker wears clothing that meets the requirements of NFPA 2112 Standard on Flame Resistant Garments for Protection of Industrial Personnel Against Flash Fire.
232(1.2) If a worker may be exposed to electrical arc flash, an employer must ensure that the worker wears clothing that meets the requirements of
(a) ASTM F1506-10a Standard Performance Specification for Flame Resistant and Arc Rated Textile Materials for Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and Related Thermal Hazards and
As well, CSA Z462-12, sections 126.96.36.199.11 and 188.8.131.52.12, state:
184.108.40.206.11 Clothing material characteristics
Arc-rated clothing shall meet the requirements of this Clause and Clause 220.127.116.11.12.
(1) Arc-rated materials such as flame-retardant treated cotton, meta-aramid, para-aramid, and poly-benzimidazole (PBI) fibers provide thermal protection. These materials can ignite but will not continue to burn after the ignition source is removed. Arc-rated fabrics can reduce burn injuries during an arc flash exposure by providing a thermal barrier between the arc flash and the wearer.
(2) Non arc-rated cotton, polyester-cotton blends, nylon, nylon-cotton blends, silk, rayon, and wool fabrics are flammable. Fabrics, zipper tapes, and findings made of these materials can ignite and continue to burn on the body, resulting in serious burn injuries.
(3) Rayon is a cellulose-based (wood pulp) synthetic fibre that is a flammable but non-melting material. Clothing consisting of fabrics, zipper tapes, and findings made from flammable synthetic materials that melt at temperatures below 315 °C (600°F), e.g., acetate, acrylic, nylon, polyester, polyethylene, polypropylene, and spandex, shall not be used alone or in blends.
Note: These materials melt as a result of arc flash exposure conditions, form intimate contact with the skin, and aggravate the burn injury.
However, fibre blends that contain materials that melt, e.g., acetate, acrylic, nylon, polyester, polyethylene, polypropylene, and spandex, may be used if such blends in fabrics meet the requirements of ASTM F1506 and do not exhibit evidence of a melting and sticking hazard during arc testing in accordance with ASTM F1959/F1959M (see Clause 18.104.22.168.12).
22.214.171.124.12 Prohibited clothing and other apparel
Clothing and other apparel (e.g., hard hat liners and hairnets) made from materials that do not meet the requirements of Clause 126.96.36.199.11 shall not be worn.
Note: Some flame-resistant fabrics, e.g., non arc-rated modacrylic and non-durable flame-retardant treatments of cotton, should not be used for electrical applications.
However, non-melting, flammable (non arc-rated) materials may be used as underlayers to arc-rated clothing, as specified in Clause 188.8.131.52.11, and also may be used for hazard/risk category 0 as specified in Table 5. In addition, where the work to be performed inside the arc flash boundary exposes the worker to multiple hazards (e.g., airborne contaminants), non arc-rated personnel protective equipment may be used under special permission from the authority having jurisdiction where it can be shown that the level of protection is adequate to address the arc flash hazard.
So what does this mean to electrical workers? Existing Flame Resistant (FR) clothing technology is inherently arc-rated. When tested to the applicable standard (i.e., ASTM F1959) to confirm the FR clothing’s arc rating, this technology can produce garments that provide protection capable of reducing potential injury from exposure to an arc flash to a 50% probability of the onset of a second degree burn. This development also helps eliminate the probability of death related to a third degree burn from exposure to an arc flash hazard.
But Qualified Electrical Workers cannot just put on arc-rated PPE and assume they are protected. Today’s Qualified Electrical Worker needs to be able to determine the arc flash incident energy level they may be exposed to and wear the appropriate arc-rated PPE that for adequate protection. They also need to know how to properly care for and maintain their arc flash PPE. They need to be able to determine when the incident energy level is too high and be able to defer the work until a shutdown is possible. The CSA Z462 Workplace electrical safety standard provides guidelines needed to work safely on energized electrical equipment when required. Alberta OHS is considering adopting these two clauses from CSA Z462 into law in Alberta. In order to comply, Qualified Electrical Workers will need training on CSA Z462 and subsequently be able to implement the requirements to properly assess risk and mitigate that risk.
How can employers help protect their employees from the hazards of arc flash? They need to develop and incorporate an Electrical Safety Program in their workplace that provides a management system approach to implementing the requirements of CSA Z462 Workplace electrical safety. The employer needs to make sure that proper PPE is available when it is needed and they have to train their Qualified Electrical Workers to properly assess the risk a work task involves, and how to reduce that risk to as low as reasonably practicable.
It is anticipated that Alberta OHS would bring the Part 18 PPE amendments related to arc flash into law by October 2015, but this could possibly be delayed. It is anticipated that the Part 18 PPE amendments related to arc flash will be adopted.
Terry Becker, P.Eng., is the Owner and Senior Management Consultant at Electrical Safety Program Solutions Inc. (ESPS). To connect with Terry, check out the ESPS website, visit his profile on LinkedIn, or email firstname.lastname@example.org.