Personal Protective Equipment
More than likely the old cliché of “Dress for Success” is a familiar phrase but one could argue that it takes on an entire new meaning when used in reference to an electrical worker. Appropriate dress can make a difference for electrical workers. Professionals working with electricity, including installers and inspectors, need to understand that appropriate personal protective equipment (PPE) for the job is important if not critical to a better chance of a trip home and not to some other less desirable destination. It also just happens to be something OSHA finds very important. Personal protective equipment is not just something you buy and put on like other clothing, this equipment is life safety related and should be handled, treated, and understood as such.
Personal Protective Equipment (PPE)
PPE is equipment that is worn to minimize exposure to hazards that may result in serious workplace injuries. PPE can offer protection from contact with chemical, physical, electrical, mechanical, or other workplace hazards. This equipment includes such protective clothing and accessories as gloves, glasses, shoes, earplugs, hard hats, respirators, coveralls, and vests as just a start. There are many other examples of PPE that are utilized to ensure a job is done while minimizing exposure to the hazards faced. PPE may vary for different trades and professions as the letters and acronym “PPE” is familiar to more than just those in the electrical industry.
Having the proper equipment for the job is only the first step for proper protection. Proper use and donning of protective equipment is a critical aspect to provide more assurance that the equipment performs as expected and desired. Equipment that is comfortable to wear removes some excuses of not wearing it. Equipment that is properly sized helps ensure proper protection is provided as well as removes excuses to not wear it. Having safety equipment and properly utilizing safety equipment are two separate subjects. An understanding of what equipment is required for the job is the first step. Understanding the proper way to put on and maintain this protective equipment is the next. Protective equipment must be of a safe design construction and maintained in a clean and reliable fashion.
Some of the main reasons why people do not wear their protective equipment even when it is available include comfort, training, suitability, and appearance. Equipment has to fit properly, be comfortable, and those who use it must know when it is needed, what is needed, and the proper ways to put on, take off, adjust, and wear it. There are many organizations that offer PPE for the electrical contractor. Ensure that the equipment purchased has the appropriate arc ratings and tested to proper ASTM standards. The world of personal protective equipment is growing as we speak. This equipment is becoming more readily available and in many different styles. Throwing a bag of equipment in your truck that includes safety gear you have never worn and of which you have no knowledge may not produce the intended/expected results. Studies confirm that equipment not used properly will not provide intended results.
It is amazing that when equipment is properly applied, it will properly perform. Incorrect donning of PPE, or putting on the wrong PPE for the event, can have devastating results. A study conducted in 2009 and then expanded upon in 2010 reviewed data from real life arc flash events with the goal to evaluate the performance of PPE in these real life situations. This information was presented at the Institute of Electrical and Electronic Engineers (IEEE) Electrical Safety Workshop, an annual event where the subject of electrical safety is discussed at great length and in great detail. This study analyzed a total of 40 events that impacted 54 workers. The authors of this research sought to determine how well PPE performs in real-world incidents as compared to results of PPE lab testing. What they learned and shared in their report was revealing and very educational.
Their findings showed that in general, arc rated clothing and equipment performed as expected. What was very interesting was that of the 54 workers, 31 received burn injuries that ranged from minor to severe and even life changing even though they wore personal protective equipment.
A good number of the injuries (45 percent) were due to the individual wearing insufficient PPE for the task at hand. There were ignitions of natural fiber clothing, instances where the PPE worn had ratings below the hazard exposure level encountered, and instances of burns on skin where there was an insufficient overlap between sleeve and gloves.
In addition, there were an almost equal number of the injuries (42 percent) due to not wearing all of the PPE elements that should have been worn for the work performed. Injuries included instances of hands being burned because no gloves were used, faces being burned because no face mask was used, and arms burned because long sleeves were not worn. In one instance an individual donned flammable jeans instead of the proper pants. Yet another example was found where the individual’s hard hat was not clipped to the hood properly. These examples illustrate that a lackadaisical approach to PPE, thinking that a properly rated shirt is enough or wearing “some” of the appropriate PPE, is just not the right approach.
It was the next 7 percent of individuals that proved to be very revealing illustrating that it’s not only the outer clothes you wear for protection but also those clothes close to the skin that can make a difference as well. There were two instances of where the individual’s bra melted and/or ignited. In one instance high-voltage arc tracking was found inside of the flame resistant jacket that ignited cotton under layers, and finally one instance of where the flammable clothes that were worn burned up the torso under the rated jacket that was worn.
This study found that those individuals who received injuries, even though they were wearing PPE, were either not wearing all of the elements of PPE needed for the work being performed, wearing insufficient rated PPE for the hazard, or experienced melting/ignition of flammable under layers, or as in some cases, individuals experienced more than one of these issues. This team concluded that arc rated protective clothing and equipment performed as expected when matched to the exposure and work in accordance with NFPA 70E. They noted that even when hazard analysis are performed, workers frequently wear inappropriate PPE elements for the activity.
An interesting conclusion noted that flammable under layers such as cotton T-shirts, nylon or spandex bras, cotton work shirts, and other similar clothing worn under arc rated clothing can ignite and/or melt. It was found that the fabrics on externally worn rated clothing can break open and expose the under garments to the event. They noticed that such materials as nylon and spandex when worn under Arc Resistant (AR) clothing can melt even when not exposed directly to the event due to AR clothing breaking open. There was a clear need for rated T-shirts, bras, and briefs demonstrated and wearing such proper PPE can reduce the risk of injury.
Codes and Standards
To help understand when and where PPE needs to be worn, we can reference some key documents in our industry including NFPA 70E, “Electrical Safety in the Workplace” (www.nfpa.org/70E) and OSHA requirements (https://www.osha.gov/law-regs.html). OSHA has a great PPE reference at https://www. osha.gov/Publications/osha3151.html. These documents provide requirements and guidance around the topic of PPE. There is a wealth of information at both the NFPA and OSHA web sites.
In addition to other sections in NFPA 70E, Section 130.7 “Personal and Other Protective Equipment,” speaks directly to requirements around PPE. Through an informational note, this document acknowledges an important fact that PPE and the requirements around PPE intended to protect a person from arc flash and shock hazards could result in burns to the skin, even with proper protection selected. The burns experienced while wearing PPE are intended to be reduced and survivable. Many people think just the opposite about the protective equipment they wear. Such events like arc flash are very violent with heat, light, sound, and even flying debris. Your protective equipment will help increase the likelihood that you will survive that event. Section 130.7 of NFPA 70E addresses head, face, foot, neck, and chin (head area) protection, eye, hearing, body, hand, and arm protection as well as shock and arc flash protection. In addition other important PPE aspects are addressed that include its maintenance and use, movement, and visibility, and the factors that are involved when selecting protective clothing. The resource available in NFPA 70E is very helpful when it comes to personal protective equipment selection and application.
OSHA too assumes an important role in this discussion of PPE. OSHA as an organization has its origins as far back as December 1970 when the Occupational Safety and Health (OSH) Act was signed into law by President Richard M. Nixon. Shortly thereafter, April 1971, OSHA was established. The first standard that this organization issued was related to asbestos. It was in 1972 that construction safety standards entered the market to protect construction workers operating electric power transmission and distribution equipment, aerial lifts, and helicopters. A notable PPE event occurred in January 1981 when the Hearing Conservation Standard was released that required that workers exposed to noise levels above 85 decibels are to be provided with hearing protection. It also requires employers to perform hearing tests on workers to monitor how these protection measures were working.
It is in 29 CFR 1910, “Occupational Safety and Health Standards,” that you will find Subpart I, “Personal Protective Equipment.” Subpart I includes 1910.132 through 1910.138 which all focus on PPE. 1910.132, “General Requirements” includes requirements for training of employees that must use PPE. As we noted above, protective equipment must be treated as safety equipment and not just another piece of clothing. OSHA requires that the employee be trained to know when PPE is necessary; what PPE is necessary; how to properly put on, take off, adjust, and wear PPE; the limitation of PPE; and the proper care, maintenance, useful life, and disposal of PPE.
OSHA has issued many hefty fines to organizations that do not adhere to the requirements around PPE. Understanding what OSHA requires as well as following the guidance of NFPA 70E when it comes to PPE is important for safety sake.
As always, keep safety at the top of your list and ensure you and those around you live to see another day.
Thomas Domitrovich, P.E., is a National Application Engineer with IEC Platinum Industry Partner Eaton Corporation in Pittsburgh, Pennsylvania. He has more than 20 years of experience as an electrical engineer and is a LEED Accredited Professional. He is active in various trade organizations on various levels with IEC, the International Association of Electrical Inspectors, the Institute of Electrical and Electronic Engineers (IEEE), the National Electrical Manufacturer’s Association (NEMA), and the National Fire Protection Association (NFPA). Domitrovich is involved with and chairs various committees for NEMA and IEEE and is an alternate member on NFPA 73. He is very active in the state-by-state adoption process of NFPA 70, working closely with review committees and other key organizations in this effort.