It is difficult to deal with this subject seriously. But beyond your Mother's concern about always wearing clean underwear (since you could be in an accident and the doctor should only see you in fresh fruit of the looms), some cringe-worthy questions are worth asking in the workplace.
Many organizations are just now implementing or revising their electrical safety programs to address arc-flash concerns and use of appropriate arc-rated clothing. Flash fires are a concern in refineries and just about anywhere flammable gases could accumulate. The American Petroleum Institute (API) has been leading a process for developing the model risk assessment of upstream oil and gas jobs. API's Recommended Practice 99 (RP 99), although still a draft, essentially agrees that work near natural gas wells, tanks, compressors, and pipelines needs flame-retardant clothing (FRC). So what does all this have to do with underwear? First you have to understand the various NFPA standards that oversee FRC and arc-rating.
NFPA 70E, 2112, and 2113
NFPA 70E, "Standard for Electrical Safety in the Workplace," provides essential guidance on assessing electrical hazards and implementing controls. In 2012, NFPA 70E changed a number of personal protective equipment (PPE) requirements, including the expectation that arc-flash protective clothing and equipment meet required testing for exposure to an electrical arc flash and not just an open flame.1
Unless you're in the business of supplying FRC, you probably don't need to know much about NFPA 2112, the standard for manufacturing and testing FRC. Included in the standard are rigorous methodologies for testing FRC on mannequins covered with sensors to calculate a percentage of body burn and, based on that percentage, the flame-retardant and arc-rating protection factors. NFPA methodology specifies that FRC be put on the mannequin overtop of natural fiber undergarments (most suppliers use cotton). Because the testing requires the use of natural fiber undergarments and the extra insulating quality of the undergarments contributes to FRC meeting NFPA's flame and arc-rating, the manufacturers' instructions state that FRC is to be used over natural fiber undergarments.
The more familiar NFPA 2113, "Standard on Selection, Care, Use, and Maintenance of FRC," describes care concerns like laundering (no bleaching, etc.) and limits the application of badges, labels, and logos on FRC unless they, too, are made from flame-retardant material. NFPA 2113 also reminds users of the dangers of synthetic fabric because it normally melts before burning and can result in a much more serious injury. It recommends that FRC should be worn over cotton clothing and non-melting undergarments (while making certain allowances for waistbands, etc.).
In fact, the Navy first identified the problems with synthetic fabrics in the 1960s. They noticed that officers were experiencing more serious injuries from flash fires than enlisted men and blamed the synthetic materials used in officers' uniforms (most enlisted men wore cotton). The issue has resurfaced in all the armed forces over the past few years with the increased use of synthetic fabrics that wick moisture away from the skin, particularly in the hot environments of Iraq and Afghanistan.
So, Is Underwear PPE or Not?
A recent Greater Houston STEPS2 meeting focused on FRC, API RP 99, and the NFPA standards. Amongst the serious discussion, I asked, "If NFPA 2113 and most manufacturers say that natural fiber undergarments need to be worn under FRC and that the certification testing protocol for FRC is conducted with the mannequin wearing undergarments, do undergarments have to be dealt with as any other required PPE?" After a few guffaws and light laughter from the audience, an OSHA representative who has been involved in the RP 99 review answered, "Probably not."
Knowing that "probably not" is not likely to satisfy my clients, I looked a little deeper at OSHA's PPE requirements.
OSHA's General Requirements for PPE are contained in 29 CFR 1910.132, with paragraph (h) addressing when PPE must be paid for by the employer. It can reasonably be argued that employers don't need to pay for undergarments considering that they are similar to
- "non-specialty footwear and eyewear" that the employee could wear off site (1910.132(h)(2));
- "everyday clothing" such as long-sleeve shirts and pants (1910.132(h)(4)(ii)); and
- "ordinary clothing" used solely for the protection from weather (1910.132(h)(4)(iii)).
If undergarments are employee-owned equipment, however, under 29 CFR 1910.132(b), employers are responsible for assuring the adequacy of such protective equipment. Then how should an employer deal with the fact that ensuring adequacy of employee-owned PPE includes ensuring proper maintenance and sanitation? Imagine the Human Resources and Legal departments' reactions if proper donning, doffing, adjusting, and wearing of underwear is added to PPE training to meet the requirements of 29 CFR 1910.132(f). And I don't want to think about someone verifying that the employees are actually using the right underwear or that it fits properly as specified under 29 CFR 1910.132(d)!
So What's a Mother to Do?
I am confident that during a general PPE inspection, OSHA will not cite someone for not providing undergarments. If there were a serious injury or accident with synthetic underwear as a contributing factor, however, I assume that OSHA's "Probably not" concerning whether underwear is PPE could be morphed into a "Yes" during enforcement.
While most employees are likely thinking, "Stay away from my underwear!" an employee or union could demand that an employer supply appropriate underwear for FRC-wearing employees. Whether an employer decides to supply underwear or reimburse employees would then come down to a business decision considering cost and employee relations. At a minimum, a responsible risk manager will make certain that employees required to wear FRC know and understand the problem of wearing undergarments that could melt and confirm employee understanding by way of a quiz or signed acknowledgement.
Jokes and cringes aside, there are two sobering messages to remember regarding underwear:
- FRC and arc-rating protection factors expect natural fiber underwear to be worn under FRC, so it's not OK to go "commando" under FRC overalls (said to be a popular option in the summer).
- Synthetic fabrics are more likely to melt before burning, resulting in more serious and harder to treat injuries, so stick with cotton or some other natural non-melting fiber.
As employers address arc-flash and fire concerns, considering appropriate FRC and the underwear that goes with it will improve employees' safety--and ensure Mother's happiness.
Curt Johnson, CPEA and STC Senior Program Director, lives and works from Texas' Gulf Coast and Hill Country areas. Curt's consulting practice focuses on implementation and auditing of management systems, agency negotiations, and facility change management. Recent projects include conformance assessment of EHS management systems with respect to the US Federal Sentencing Guidelines; development of the management system and its documentation for a major food producer; coordination of EHS issues during facility closings; EHS and fire code auditing of energy, manufacturing, pharmaceutical, food, waste, and transportation facilities for a variety of clients; and developing compliance programs for an electronics manufacturer. He is the author of the Upstream Oil and Gas Operations Auditing Guide published by Specialty Technical Publishers of Vancouver, B.C., as well as a contributing author for the Pipeline Safety Auditing: Federal Compliance Guide and the ISO 14001 Environmental Management Systems: A Complete Implementation Guide. He is a Certified Professional Environmental Auditor (CPEA) in both compliance and two management systems disciplines. Curt was chair of the 2010 and 2011 Environmental Challenges and Innovations Conference for the Texas Association of Environmental Professionals, is a past member of the Auditing Roundtable Board of Directors, has served on the Ethics Committee of the Board of Environmental Auditor Certifications (BEAC) since its inception and is the 2005 recipient of the BEAC Chairman's Leadership Award.
Despite more than 30 years' experience in developing and implementing effective environmental, health and safety (EHS) management systems solutions, he has never before dealt with the issue of underwear in the workplace.
To discuss this article or for more information about STC's consulting services, contact Curt at (281) 341-8289 or cjohnson@stcenv.com.
1 STC's Summer 2012 issue of this newsletter contains a more detailed article addressing the changes to NFPA 70E.
2 A collaboration between companies in the oil and gas exploration and production industry and OSHA, the National Service Transmission Exploration and Production Safety (STEPS) Network promotes safety, health, and environmental improvement (see http://www.nationalstepsnetwork.org/). The Greater Houston network (see http://greaterhoustonsteps.com/home) is one of about 20 local networks.
