The 1910.269 standard is commonly referred to as the “maintenance standard” in the electric utility work space, and subpart V in the corresponding construction 1926 standards. These two standards, covering the majority of work in the industry, were “harmonized” during revision of the standards in 2014. This was OSHA’s attempt to eliminate any confusion concerning the delineation between maintenance and construction; these standards now are virtually identical.
Organizations seek clarification from either OSHA or industry experts on many sections of these standards because of the specific nature of the work in this industry. All organizations should focus on paragraphs 1910.269(l) (8) and 1926.960 (g) covering protection from flames and electric arcs. These sections outline the requirements to follow when determining the necessary types of protective clothing to protect employees from the hazards associated with flames and electric arcs.
Determine clothing type
After completing the initial assessment and estimating the incident heat energy potential of the exposure to electric arcs, you will need to determine what type of clothing is necessary for protection that is equal to or greater than the potential heat energy. Once the type of clothing is determined, it is the employer’s responsibility to provide that protection to employees. Many organizations offer stipends for employees to select approved items from preferred vendor catalogs, while others have in-house distribution of clothing to keep the “look” uniform. Either way is acceptable, as long as the clothing protects to the level of exposure.
Many employers make the mistake of assuming that once they have performed the hazard analysis and determined what level of protection is needed that their job is complete. While they have met the intent of the rule’s requirement, they still have more to do. Specifically, they have to provide education on the clothing’s proper wear, use and care. The use and care information is usually handled by the vendor providing the clothing. There are specific instructions for laundering, if there is no company-sponsored service, and for when to change out the clothing because it is damaged or soiled to an extent that the protection factor is compromised.
What does compliant wear look like? When it’s 90°F outside and your workers are sweating and thirsty, do they unbutton their shirts at the collar? Roll up their sleeves? Untuck their shirt? These actions are all noncompliant, and basically make all of the clothing’s protections a moot point.
Enforce proper wear
Enforcing its proper wear is one of the most difficult and overlooked aspects of compliance with protective clothing. Yes, I know it sounds mundane. But let’s look at it from a protection perspective. A shirt with an open collar provides an avenue for an arc to get to the employee’s body and cause that second degree burn or greater that we are trying to prevent. Likewise, sleeves rolled up and shirts untucked create the same issue. You may not want to be the clothing police, but in the interest of compliance and, more important, employee protection, you need to take that step and reinforce the rule. It will only take one burn to convince the crew that what you are preaching is the right way to do it. Do you really want to provide that real-life example of why it is necessary? I think not!
A simple way to assist with compliance is to eliminate the option for noncompliance. Buy long-sleeved pullover shirts that are lightweight and protective. These can also be purchased in hi-vis style so the outside vest can be eliminated. This takes away an outer layer, and while it may not add much to comfort, it removes a potential hazard: the vest getting caught on objects. You should also ensure that keys and other objects are not hung from belt loops and that water is available during hot and humid days.
The first step is understanding protective clothing requirements. Proper wear is where the protection comes from.