How does OSHA Rule 1910.269 impact your company

The 2014 revision to OSHA Rule 1910.269 implements significant changes to requirements for protecting workers from electric Arcs and for using of Arc Rated Uniforms. OSHA estimates the revised ruling will save more than 20 lives and prevent 118 serious injuries each year.

OSHA’s revised ruling will require companies to provide more Arc Rated Uniforms to their employees.

In general, an employer must:

Assess the workplace to identify employees exposed to hazards from flames or from electric Arcs.
Make reasonable estimates of the incident heat energy of any electric Arc hazard to which an employee would be exposed.
Ensure that employees exposed to hazards from flames or electric Arcs do not wear Uniforms that could melt onto their skin or could ignite and continue to burn when exposed to flames or estimated heat energy.
Ensure that the outer layer of Uniforms worn by an employee is Arc Rated and Flame Retardant.
With certain exceptions, ensure that employees exposed to hazards from electric Arcs wear protective Uniforms and other protective equipment with an Arc Rating greater than or equal to the estimated heat energy.

It is now up to employers to comply with the following requirements as they relate to Arc Rated and Flame Retardant Uniforms:

New Minimum Protection
Among the changes incorporated into the revised ruling, employers are to provide head-to-toe Arc Rated FR Uniforms for all hazards greater than 2 cal/cm2 or for work above 600 volts. This requirement for full body protection means that workers will now be required to wear Arc Rated pants, in addition to Arc Rated long sleeve shirts or coveralls.

Arc Rated and FR Uniforms is now treated as PPE
OSHA now believes that it is reasonable and appropriate to treat Arc Rated FR Uniforms required by the revised ruling as personal protective equipment (PPE). This will be reflected as an increase to allowances and/or by adding additional items to approved Uniform selections for employees.

OSHA Supports Home Laundering
While the designation of Arc Rated FR Uniforms as PPE requires additional employer oversight, it is clear OSHA allows home laundering of the Uniforms. The final Rule does not require employers to launder protective Uniforms for employees.

Employer Responsibility for Care & Maintenance of FR and Arc Rated Uniforms
OSHA explains that if employers rely on home laundering of Arc Rated FR Uniforms, they must educate their employees in proper laundering procedures and techniques, and that employers must inspect the Uniforms on a regular basis to ensure that it is not in need of repair or replacement. Regardless of whether or not a laundry service provider is utilized, the responsibility for maintaining PPE rests squarely with the employer under existing OSHA standards.

Cost of Changes to Employers
OSHA specifically addresses the total estimated cost for Arc Rated FR Uniforms in the final Rule, and OSHA is basing its estimates on a cost of $1,534 per employee for eight sets of Arc Rated FR Uniforms (using the estimated cost of $191.75 per set). The agency believes this final estimate is reasonable and captures the average cost of all Arc Rated Uniforms required by the new provisions of the final standard.