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 Post subject: When and when not to wear your PPE?
PostPosted: Tue Jul 23, 2013 3:35 am 
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I work for undisclosed thermoform and injection plastic molding corp. It's Berry well known! We have 4 different dept's. of maintenance here. All 4 are subject to working on or testing live equipment, panels, switch gear, ect.
Once completion of a certified "Herzig" Arc Flash certification... We are then supplied with a uniform HRC-2 rated.
Now mind you I live in Kansas... This is our uniform to wear at all times! Regardless of working on de-energized equipment, temps, or humidity... Our mechanical rooms can reach over 120 deg. F. On a cool day.Also blend stations with mezzanines where you are crawling "at ceiling height" to repair or troubleshoot issues,NON ELECTRICAL. Also... Going up on roof tops, silos, and water towers in extreme heat, w/o having to deal with anything energized, while keeping on the PPE! It is our "uniform" . Now recently, with in the last 2 1/2 weeks 2 men from my dept."NOT WORKING ON ANYTHING EVEN REMOTELY INVOLVED WITH ELECTRICITY" have ended up being taken by ambulance to the hospital for cardiac arrest!. Yet my supervisor "who sits in an air conditioned office all day" Has enforced this policy... Which is NOT company policy... It's his policy! Nothing has changed! Seriously!!!!!!!!! Can someone PLEASE give me info or something as to whether or not this is negligence, poor management, or a third world company?


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PostPosted: Tue Jul 23, 2013 3:57 am 
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Supposedly, we are required to abide to this policy because we have 3 separate buildings on site. So if we need to enter a panel, cabinet, ect. we have our "gear".... YET the rest of the equipment ie: gloves, face shield, balaclava, jumpsuit, ect. are located either in our shop or tool chests! So no matter where we are... We still have to get the rest of the gear to be properly protected and work safely!!! Now the real KICKER!!!!!!!!!!!! Polypropylene dusts from material systems is being embedded into our PPE, throughout our shift. It's unavoidable! Then, being drenched in sweat as well. So... 2 out of 3 electrical hazards for which the PPE is designed for are being nullified, COMPLETELY! The poly. dust are flammable and being soaked from head to toe makes you a conductor! Someone tell me WTF is wrong with this picture?!!


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PostPosted: Tue Jul 23, 2013 4:02 am 
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I need help! INFO! Before I'm the next in the meat wagon... OR WORSE!


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PostPosted: Tue Jul 23, 2013 5:54 am 
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I think that the minimum required workwear should be PPE for HRC-0. That way if you are required to work on live equipment that is a higher HRC, you can don the appropriate PPE over what you normally wear (As long as what you normally wear are natural fibers that do not melt into your skin).


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PostPosted: Tue Jul 23, 2013 7:19 am 
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An emotive argument is unlikely to win over your boss as he probably believes he is doing the right thing in protecting his workers, and generally speaking having the outer layer as FR is a positive move. Convincing people to reduce levels of PPE protection is always an uphill battle. I would suggest an equipment/task based risk assessment approach. For each type of higher energy switchgear (Distribution switchboards - MCC's - Drive Suites etc) you have on site list what tasks do you do that require any FR PPE (operation, testing and fault finding, maintenance), and how often. Where the equipment and task requires PPE consider if their are other controls higher up the hierarchy of hazard controls that could eliminate the need for the PPE (remote switching, installation of Low fault level test points for isolation verification and fault finding etc). If the review finds that the PPE is rarely required, or mostly restricted to swithrooms where PPE can be stored then you will have a recommendation with some thought out reasoning behind it. Unfortunately for you there are plenty of electrical people around the globe in hot environments who are managing in arc rated clothing all of the time. From an employers point of view with compliance to standards the reality is that if you can get all your sparkies in arc rated gear all of the time then that is a good result. Its also fair to say that comfort is a key factor in PPE take up and compliance. I have personally trialed on site at a steel mill with its fair share of hot areas a range of PPE and heat wise the better treated cotton garments were only marginally warmer than heavy duty cotton drill. I cant really comment on your contamination issues. With respect to surviving until any change is made (if ever) take regular breaks, drink plenty of water, request cool rooms at various locations, continue to look after yourself and your mates and for what its worth, good luck.


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PostPosted: Tue Jul 23, 2013 2:45 pm 
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I agree with Brett. An emotional response is unlikely to be helpful. Reading your post, I am concerned about the contamination of the arc rated clothing specifically as it relates to the polypropylene. After all, polypropylene and other synthetic material is what we're trying to AVOID in an arc flash event.

I would refer you to NFPA 70E 2012 130.7(13)(a), (b), & (c) and maybe 130.7(7)(c) as well. If in the course of daily wear your PPE is contaminated sufficiently enough to degrade the protective ability of the PPE... well, that wouldn't be in alignment with the standard.

I would also question whether or not your supervisor fully understands the electrical hazards you are exposed to. As is common knowledge, in a 480V system for example, available incident energy could run the gamut from 4 calories to just under 40 calories. In other words, it's not enough to hand you HRC-2 and send you off to work.

Another thing that's jumping out at me... you said you have to go back and get your other gear (face shield, balaclava, etc). You also mentioned "jumpsuit" - what's the jumpsuit? Are you layering arc rated clothing to increase protection? If so, I would refer you to NFPA 70E 2012 Informative Annex M which describes the methods of testing to achieve layered ratings (M.3.2). Hint: it's not enough to add them up - the layered clothing system must be tested!

As to the heat/sweat... I have guys working in petrochemical facilities who are required to wear 8 calorie coveralls over their street clothing during hot summer months outdoors. I sympathize, but heat exhaustion must be dealt with as an entirely separate issue (water, rest, training, education, etc.).


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PostPosted: Wed Jul 24, 2013 9:32 am 
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All of our electricians wear HRC 2 uniforms daily. We may spend part of the day working on breakdowns, projects, and who knows what else. We also have high temps in the plant but it is too much hassle to stop and put on your ppe to troubleshoot a problem then take it off until needed again. We carry our gloves, helmet and face shield, and hood with us to the job and don as needed. It gets very hot in here in July and August but I guess I would rather be hot and uncomfortable than laying on a bed in a burn ward somewhere.


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PostPosted: Thu Jul 25, 2013 2:11 am 
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What is totally unacceptable is that you are doing Energized work as a matter of course, requiring PPE.
Except where the "Greater Hazard" clause, Art 130.2 (A)(1), is invoked, you should always be able to find a way to make safe and do the work remotely or out of harms way.
"Infeasibility" Art 130.2 (A)(2) for most equipment just isn't the case.
Look at the specific cases where you have to work on energized equipment, and then ask what you need to do to only use dead working.


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PostPosted: Thu Jul 25, 2013 10:14 am 
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Goldenspark wrote:
What is totally unacceptable is that you are doing Energized work as a matter of course, requiring PPE.
Except where the "Greater Hazard" clause, Art 130.2 (A)(1), is invoked, you should always be able to find a way to make safe and do the work remotely or out of harms way.
"Infeasibility" Art 130.2 (A)(2) for most equipment just isn't the case.
Look at the specific cases where you have to work on energized equipment, and then ask what you need to do to only use dead working.


I also work in a large manufacturing facility. Often times we’re performing troubleshooting which I classify as infeasible to be done with the equipment de-energized; this includes checking voltage, load current, LED indicators, etc.

After the problem has been diagnosed, then the equipment is de-energized so that work can be performed; we define work as anything not diagnostic in nature such as installing, removing or replacing components or conductors.


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PostPosted: Sat Jul 27, 2013 9:44 pm 
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If I was the engineer or boss at your site, I wouldn't want to make FR PPE mandatory unless I had a good technical reason for it. Here are some good reasons for it:
1. You have to make nonmeltable clothing for electricians mandatory anyways. Setting the bar at FR PPE makes this easy to do without having to get personal with them on what they are wearing. It's either that or explain the rules but recognize that it can be hard to enforce this one.
2. Depending on the plant, you might have a lot of equipment that is in the range of 1.2 to 4 cal/cm^2 or can easily be made that way, so making 4 cal/cm^2 FR PPE mandatory makes it considerably easier to manage arc flash hazards.
3. If FR PPE was previously required such as in the casting/smelting industries or oil refineries, then the transition is to simply get the PPE with the arc flash label on it.

Good reasons against it:
1. The risk (and number of incidents) of dehydration and heat exhaustion will increase.
2. FR PPE is very expensive. A $10 T-shirt costs $30. And if you want to avoid someone making a mistake while laundering it (never use bleach of fabric softener), then it's better to pay for commercial laundry service. The maintenance costs long term (replacement, repairs) are much more expensive. And it will get used that much more so that much more money has to be spent maintaining it.
3. It's only moving the bar from 1.2 to 4 cal/cm^2. Depending on the operation this may be only a small number of situations. Plus it is potentially only a smaller number of tasks.
4. Lots of problems addressing handling of outside guests into the plant.
5. Lowers employee morale in summer months because the stuff is hot.
6. Potential (increase) in issues with skin reactions if the commercial laundry doesn't get the stuff clean.
7. Increased costs associated with training, sick leave, and resources (issuing electrolyte powder mixes or popsicles) to deal with the side effects of heat exhaustion and dehydration.
8. Increased risk of PPE being soiled/damaged when it actually needs to be used.
9. It can cause issues of temporary impotence and low sperm count in men.

OK, that being said, I've worked around thermal processes for years. I've worked in places (for short periods of exposure) where the temperature was 140 F. At that point even a hand rail or ladder rung can give unprotected skin a second degree burn in 1 second. It routinely gets up to 120 F sometimes in the operating areas in some of the plants here in North Carolina. All of the oil operations in the gulf have mandatory FR PPE requirements because fire is so common in refineries. They manage it. Some hints on managing it:

1. If you are exposed to temperature extremes every day for 2-3 hours per day, you will gradually acclimate to it after about 7-10 days to the point where you can work in it without difficulty up to around 120 F. The first 2-3 days are the worst.
2. Drink not only lots of fluids but electrolytes, too. Learn which flavors of the electrolyte stuff out there don't taste terrible or like licking salt. A few Gatorade flavors are acceptable ("frost" stuff). Squincher is better.
3. Eat at least one or two pieces of high potassium fruit (cantelope or banana) every day.
4. Even if you feel sick/cramp up in the evening, at least eat the fruit. If you don't, you will get a lot worse. You might find yourself going into shock and puking your guts out and spending 2-3 days at the hospital or at home on sick leave.
5. Do not drink beer to "cool off/refresh". Beer dehydrates you and makes it worse.
6. When you go to the bathroom, watch your urine color. Don't wait until you are "thirsty". Your urine color is the best indicator you have of whether you are hydrated enough or not. It should be very light yellow, never dark yellow or brown.
7. Take breaks frequently if possible.
8. Don't sit in front of an air conditioner and/or crank it way down. It's better to leave it a little warmer than 68 (in the 70's) so that it is not as much of a shock to your body when you move in and out of the air conditioning.
9. We didn't have air conditioning in the South until a couple decades ago. Our ancesters didn't keel over dead. In fact many of them wore heavy cotton overalls and shirts partly for sun protection and partly because it increases the surface area for evaporation and helps your body stay cooler even if it's a heavier fabric.

I have done this both ways. At my previously employer, it was a foundry. All the things you are describing, plus humidity levels at 90%+ due to some plant design decisions and being right on a major waterway. We required FR (greens) in the casting and melt shop areas up to that point. When we implemented 70E, we went to mandatory FR PPE for all electricians, electrical supervisors, maintenance superintendent, manager, and engineers. Almost all equipment was below 4 cal/cm^2 but not much below 1.2 cal/cm^2. We made ourselves wear it because we felt that we needed to lead by example and not just push people around. Also the management standard uniforms were bright white shirts which was utterly stupid in a foundry if you ask me so I was all too happy to get rid of the white shirts.

At my current employer we have 2 divisions. One division (which includes headquarters) did a knee jerk reaction and made FR clothing mandatory due to some miscommunication. By the time the dust settled if they tried to go backwards, the union would have revolted claiming that they were lowering safety standards. In my division we were pressured strongly to follow suit but when we explained that it would cost around $1 MM just to do the initial roll out and also a significant maintenance cost annually after that, along with every one of the technical reasons for not doing it, management backed off and currently FR PPE is required only when needed.

I still wear only 100% cotton polos or button down shirts. I wear cotton duck pants, underwear, and undershirts. In the winter time I wear a bulwark FR jacket with a winter liner left over from the days at the foundry along with the "old fashioned" all cotton waffle style long johns. And I wear the same standard PPE as every one of the hourly employees. If we're doing a job where there will be someone stuck in a 40 cal suit for a long time (more than 5-10 minutes), I always volunteer to do it to relieve the electricians from having to do it all the time. I do this stuff because I prefer to set an example and not just ram policies down their throats. And because I consider them all my friends, coworkers, and I have more respect for them as people than to go around making rules that I'm not going to follow myself.


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PostPosted: Tue Aug 06, 2013 3:36 am 
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I agree with Paul Engr. There are some facilities that are "hotter than the hubs of hell" and it wouldn't matter if you wore Bermuda shorts and a Hawaiian shirt. The work practices in these plants have to take the heat factor into consideration. But there are a few points that I would like to add:

Contaminated PPE is unacceptable. I frequently encounter this when maintenance multi-craft wear arc rated PPE while performing mechanical repairs, which are often the majority of their assigned tasks. The apparel gets contaminated with grease/oil and is more subject to physical damage e.g. tears and rips.

Over the last decade, I have performed hundreds of arc flash hazard studies. While every plant is different, they usually have similar results... the vast majority (often >90%) of the utilization equipment on the plant floor is <1.2 cal/cm^2 and doesn't require arc rated PPE. There will also be 3-5% between 1.2 and 8cal/cm^2, 3-5% between 8 and 40cal/cm^2, and the remainder >40Cal/cm^2. With those numbers in mind, what should the "just & prudent" employer do? My interpretation of OSHA's expectations regarding PPE is that the employer should provide APPROPRIATE PPE to protect the employee from the hazard. Is PPE Level #2 apparel appropriate for working on equipment <1.2 cal/cm^2? If it was, then the faceshield and balaclava should also be worn. Is a flash suit appropriate for working on buses <1.2 cal/cm^2? I believe everyone would agree that the arc flash suit would not be appropriate. There are only 3 reasons that I can think of that would dictate Cat #2 apparel be worn as daily wear:

1 - The majority of the buses are between 1.2 and 8 cal/cm^2.
2 - Productivity suffers because of the time it takes to round up, and don, the PPE.
3 - The responsible person (EHS manager, maintenance manager, etc) is simply enacting a CYA strategy. I've had several outright admit that was their strategy.

Many, if not most, of my clients opted for the Cat #2 kit that includes 8 cal/cm^2 coveralls, faceshield, balaclava, 00 gloves (all in a bag or backpack) and require qualified employees wear 100% cotton as daily wear. The employees take the kit with them anytime there is a chance that they will be required to work on buses up to Cat #2.

In closing:

All this being said, arc rated PPE is not designed to prevent injury; it is designed to limit the injury to the onset of a 2nd degree burn.

Mitigation, or "engineering out the hazard" should be a priority. In the case of the stated adverse environment, the best approach is to keep the polypropylene dust out of the air. If it's airborne, then breathing the polypropylene dust must pose a respiratory hazard. From the arc flash hazard standpoint, it's often economically feasible to reduce the incident energy to < 1.2 cal/cm^2.

Sorry... I ran out of time... will post more thoughts later.


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