Complying with updated regulations on FR vests
Workers are within 50 feet of a roadway and are wearing CAT 2 FR garments. What else do they need to be wearing to be OSHA 1910.269-compliant?
Responding is Gary Zumstein, Glen Raven technical fabric’s vice president of development/technical and international sales for GlenGuard, Glen Raven Inc., Glen Raven, NC.
Recent updates to safety regulations have addressed the importance of a long-overlooked piece of safety equipment – the hi-vis vest. ANSI 107 and OSHA 1910.269 together address what was previously a gap in safety regulations regarding FR protection. A hi-vis vest is classified as “primary protection or job specific” in high-hazard risk situations, and is the first layer of protection for your workers. Because your workers are wearing FR workwear to meet OSHA 1910.269, it should follow that the first layer guarding them from danger is flame resistant as well.
ANSI 107 now makes this a requirement. If your workers are required to wear FR workwear within 50 feet of a road or highway, their hi-vis vest must be flame resistant. Workers can comply with these standards by wearing FR daily wear that complies with ANSI 107 visibility requirements, but because compliance is an ongoing issue facing safety managers, worker comfort must be taken into consideration.
Daily FR workwear shirts that are fully compliant with ANSI 107 limit workers’ options on what product they wish to wear daily. Additionally, wearing a heavy vest that meets higher FR standards could be problematic on a hot day. This makes a lighter-weight FR hi-vis mesh vest the ideal choice for worker comfort.
Lightweight vests are not difficult to find, but before you specify, understand that OSHA 1910.269 and ANSI 107 require that the vest meets specific safety standards. Hi-vis vests made of FR-treated nylons and polyesters are no longer considered compliant because these fabrics can contribute to the hazard.
Polyester and nylon continue to burn after ignition and will melt and drip hot, molten plastic that can cause second- and third-degree burns even if the worker is wearing FR gear underneath. To be compliant with the updated standards of OSHA 1910.269 and ANSI 107, the fabric of the vest must be truly flame resistant. It must be arc rated – meaning it will not ignite when exposed to an arc or flash fire. It must never melt or drip, and it must have a rating of 2.0 cal/cm2.
The Fire Protection Research Foundation reported that two-thirds of the workers involved in arc flash incidents were injured when employers failed to conduct an arc flash analysis for selecting personal protective equipment. OSHA now believes that it is reasonable and appropriate to treat required FR and arc-rated clothing as PPE.
Layering a vest on top of FR daily wear should not create an additional hazard to the wearer. The FR vest is a critical piece of today’s PPE for both worker protection and compliance. OSHA 1910.269 specifically states it is the employers’ responsibility to ensure their employees’ or contractors’ outer layer of protection conforms to these standards. Because it is your responsibility to keep your workers compliant, it is important that your perspective on FR hi-vis vests mirrors the changes in these two standards.
Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.