
When is flame resistant clothing required for employees?
Someone posed this question to me the other day, and it honestly stumped me. Is FR clothing only required for employees working in electric panels (over 600 volts)? Thats what I found in 1910.269 - https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.269 - but I know when I worked in a gas plant, they required ALL employees to wear FR clothing regardless of whether or not that employee was working with electricity.
Wondering if anyone can offer some insight.
Comments (2)

After working in the oil and gas industry for 29 years, FR is my business suit. What we followed for our program was if you were in a process area (non-control room or administrative building) you had FR clothing on. Also important, FR is outermost layer of clothing and only natural fibers like cotton or wool under the FR. NO synthetic materials (Polyester, Rayon, etc.) as they will melt into the burn and worsen the injury. In Class 1, Division 1 your are in an environment where you can have flammable vapor under normal operations, so any ignition source (either brought in or generated by task) you are only 1 spark away from a flash fire, fire or explosion. In Class 1, Division 2 you are also required to wear FR as you could have a flammable environment as a result of an abnormal operation, relief valve lifts to atmosphere or abnormal operation, bleeding down a valve body. REMEMBER, STATIC ELECTRICITY CAN BE YOUR SOURCE OF SPARK. Your PPE hazard assessment under 1910.132(d) should address FR PPE. 1910.137 will also address electrical PPE.
Good catch on the electrical hazards, but FR is required any time a person is working on, or exposed to 50 volts AC live or greater. Also applies to DC, but I do not recall exact voltage. See NFPA 70e for arc FLASH protective clothing. FR comes in several categories (Category 1, 2, 3, 4) depending upon the incident energy of the hazard source. Look at the tables in 70e for the task performed and the equipment being worked on in a live condition. Tables are only worst case scenario. For newer equipment, should have an arc flash hazard sticker with the required PPE category, incident energy, approach distance and shock distance already displayed. For older equipment, an arc flash study should be completed and equipment labeled. Sometimes a good electrician can determine this, but it is generally an electrical engineer. Remember to look at 29 CFR 1910.300 Subpart S for general industry electrical hazards as well as NFPA 70e. 1910.269 only applies to power transmission industry specifically. OSHA also has some good letters of interpretation on FR.