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Workplace Solutions | Personal protective equipment

Personal protective equipment

How will recent revisions of certain OSHA rules affect my existing PPE program?

June 23, 2014

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Responding is Dennis K. Neitzel, CPE, director emeritus of AVO Training Institute Inc., Dallas.

The personal protective equipment program requirements previously based on 1910.269, as well as those contained in the previous 1910 Subpart I, Personal Protective Equipment, are still valid. However, the April 1, 2014, final rule revisions of OSHA 1910.136, 1910.137, 1910.269 and 1926 Subpart V, as well as the new 1926.97, include requirements that must be incorporated into PPE programs.

OSHA 1926 Subpart V was extensively revised to be consistent with the revised 1910.269 and contains the same requirements for construction and general industry. OSHA 1926.97, Electrical Protective Equipment, is new and consistent with the revised 1910.137. All construction PPE programs will require revision to incorporate the new requirements.

Below, revised requirements are underlined for clarity:

1910.136 Foot Protection
(a) General requirements. The employer shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, or when the use of protective footwear will protect the affected employee from an electrical hazard, such as a static-discharge or electric shock hazard, that remains after the employer takes other necessary protective measures.

1910.137 Electrical Protective Equipment
The main revision to 1910.137 was the addition of Class 00 gloves. The following paragraph and note were added for Class 00 gloves.

(c) In-service care and use of electrical protective equipment. (vii) Protector gloves shall be worn over insulating gloves, except as follows: (B) If the voltage does not exceed 250 volts, ac, or 375 volts, dc, protector gloves need not be used with Class 00 gloves, under limited-use conditions, when small equipment and parts manipulation necessitate unusually high finger dexterity.
Note to paragraph (c)(2)(vii)(B): Persons inspecting rubber insulating gloves used under these conditions need to take extra care in visually examining them. Employees using rubber insulating gloves under these conditions need to take extra care to avoid handling sharp objects.

The revisions to 1910.137 also include AC and DC test and use requirements. The AC test voltage is 2,500 VAC with a use voltage of 500 VAC; the DC test voltage is 10,000 VAC but does not provide a DC use voltage.

1910.269 Electric Power Generation, Transmission and Distribution
1910.269(g) Personal protective equipment. (1) General. Personal protective equipment shall meet the requirements of Subpart I of this part.

The revisions to Subpart I were noted above.

1910.269(l) Working on or near exposed energized parts. This paragraph applies to work on exposed live parts, or near enough to them to expose the employee to any hazard they present. This paragraph was expanded to provide additional detailed requirements for the use of rubber insulating PPE when working on or near exposed energized parts. No specific incorporation dates were provided, so the requirement is assumed to be immediate.

1910.269(l)(8) Protection from flames and electric arcs. (i) The employer shall assess the workplace to identify employees exposed to hazards from flames or from electric arcs. (ii) For each employee exposed to hazards from electric arcs, the employer shall make a reasonable estimate of the incident heat energy to which the employee would be exposed. Note 1 to paragraph (l)(8)(ii): Appendix E to this section provides guidance on estimating available heat energy.

OSHA made extensive revisions and provides specific dates when the requirements of 1910.269(l)(8) are to be incorporated into PPE programs:
(vi) Dates. (A) The obligation in paragraph (l)(8)(ii) of this section for the employer to make reasonable estimates of incident energy commences January 1, 2015.

(B) The obligation in paragraph (l)(8)(iv)(D) of this section for the employer to ensure that the outer layer of clothing worn by an employee is flame-resistant when the estimated incident heat energy exceeds 2.0 cal/cm2 commences April 1, 2015. (C) The obligation in paragraph (l)(8)(v) of this section for the employer to ensure that each employee exposed to hazards from electric arcs wears the required arc-rated protective equipment commences April 1, 2015.

Because the requirements for estimating incident energy of an arc flash and providing arc-rated clothing and PPE have been required by NFPA 70E, “Standard for Electrical Safety in the Workplace,” since the 2000 edition and required by ANSI/IEEE C2, “National Electrical Safety Code,” since 2007, it is advisable to perform an arc flash hazard analysis as soon as possible to adequately protect employees in all segments of electric utilities, construction and general industry.

Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.

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