A union representative e-mailed OSHA to ask who is responsible, under that standard, for laundering fire-retardant (FR) clothing.
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On June 1, 2015, OSHA issued a letter of interpretation in response to the question.
Who Does the FR Laundry?
OSHA’s reply covers employer responsibilities under both the general industry PPE standard (29 CFR 1910.132) and the construction standard (29 CFR 1926.95). OSHA replied that the standard “does not prohibit home laundering of FR and arc-rated clothing if the employer permits it.” But, that doesn’t mean that employers can simply send FR clothing home with workers and tell them, “follow the manufacturer’s instruction.”
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Instead, employers have a responsibility to ensure that protective clothing, including FR clothing, is “adequately maintained in a reliable condition.” According to OSHA, that means that the garment must be maintained in such a way that it would perform as designed if it were challenged in a flash fire. In other words, the employer is responsible for ensuring that the FR garment is laundered such that contaminants, including dirt, oils, and other materials will not affect the performance of the garment when it is in use.
If employers rely on home laundering of FR clothing, they must train their employees in proper laundering procedures and techniques and inspect the clothing on a regular basis to ensure that it is not in need of repair or replacement. If an employer cannot meet these conditions, then the employer is responsible for laundering the FR and arc-rated clothing.
Home Laundering Hazards
Some common home laundering conditions and techniques can damage the protective properties of FR clothing. In general, employers and employees should beware of:
- Hard water. Mineral salts in hard water can accumulate on fabrics, making the clothes less flame-resistant and possibly fueling a fire.
- Natural soaps (nonionic or tallow soaps). Like minerals in hard water, residue from these soaps can build up on fabrics, damaging FR properties and serving as fuel for a fire.
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- Laundry additives. Additives like fabric softener, bleach, nonchlorine bleach, or starch can coat the fibers of FR clothing, can damage the bond between the fabric and the FR treatment, or can otherwise reduce FR properties of the clothes. However, some stain-removing pretreatments are okay to use.
- Insect repellents. Diethyltoluamide, or DEET, and other insect repellents can be flammable, and should not be added to FR clothing. Powdered permethrin can be laundered into the garments safely, and water-based permethrin can be sprayed on the garments, but all other forms of insect repellents should be avoided.
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The information on permethrin was extremely helpful. We have been promoting its use, we purchase after market spray bottles to treat FR uniforms and the question came up as to whether it would affect the FR properties. Can you share with me where you got this information from, what tests were doen to verify the results? We also hvae DEET bug spray that our guys often spray on their clothes in the field so I want to stop that practice is if will reduce the FR properties.