Responding is Scott Margolin, international technical director, Westex Inc., Chicago.
Compliance and worker safety can be achieved by both task-based and daily-wear approaches, and the risk/reward calculus is fairly straightforward. A task-based program has the benefit of lower initial cost by virtue of providing a single coverall instead of multiple sets (usually five) per employee, but adds significant risk and longer-term costs in the form of liability, monitoring, undergarments and productivity, among others. As a result, the majority of companies currently in compliance with NFPA 70E choose not to rely on task-based systems, instead specifying arc-rated (AR) flame-resistant clothing as the only acceptable work uniform for employees and contractors working on energized electrical equipment.
A task-based system burdens the individual worker with deciding when to don AR clothing, when it is safe to remove it, and who else in the vicinity may need to be excluded from the flash protection boundary or required to don AR to enter it. Training each employee to this degree is time-consuming and expensive, documentation is required, and the potential for inconsistent and inaccurate application of the rules is enormous. Some workers who are asked to take this responsibility work much more slowly, while others cut corners; one approach is inefficient and the other is unsafe.
Clothing worn under the AR outer layer also can be unsafe if it is meltable. Standards require non-AR garments worn underneath to be made of all-natural, non-meltable fibers. This is much more difficult to mandate and monitor when workers are wearing “street clothing” in a task-based program. A second layer of clothing under the AR also has much more potential to cause heat stress than a single layer of AR.
When an incident occurs, the company will be held liable even if it can prove the hazard was analyzed, the appropriate personal protective equipment was provided and the worker was trained, because OSHA requires the employer to monitor appropriate use of PPE. Thus, despite doing everything else right, in a task-based situation where a worker fails to don the appropriate FR clothing, takes it off too soon, or wears it improperly, the company still will face fines, potential legal action and the extreme expense of a burn injury. Therefore, most safety managers will not allow each worker to make dozens of decisions every week, out of sight or reach of supervision, any one of which could result in catastrophic injury or death and the attendant costs and issues.
The average worker will tackle many tasks in any given day, each with different hazard levels. If he or she is required to retrieve, don and doff FR coveralls each time a given task demands it, the cost of these delays quickly can exceed the supplemental cost of daily-wear AR over the three- to four-year service life of the clothing. This situation is exacerbated when a worker faces tasks that can range across three or more hazard risk categories.
Safety managers generally are not gamblers; they prefer a known to an unknown and want to remove as many human error variables as possible. The simplest solution, with the least possibility for error and injury, is to specify AR clothing as daily wear and require all employees working on or near energized electrical equipment to report to work in AR. This best-practice approach ensures productivity stays high, liability is dramatically reduced and monitoring is almost automatic.
Editor’s Note: This article represents the independent views of the author and should not be construed as National Safety Council endorsements.