On our latest episode of the EHS on Tap podcast, an expert answered some big questions about the proper uses of flame resistant (FR) garments within a personal protective equipment (PPE) program. Read the transcript of our conversation with Derek Sang, Technical Training Manager for Bulwark FR.
This episode was released on December 17, 2019, and you can listen to the full audio here.
Justin Scace: Hello everyone, and welcome to EHS on Tap. I’m your host, Justin Scace, senior editor of the EHS Daily Advisor and Safety Decisions magazine. Now, for those performing tasks in high risk industries, personal protective equipment or PPE is their last line of defense. It’s important to be as informed as possible about all the PPE necessary to perform a job safely, but you may have some questions about the proper uses of flame resistant or FR garments within your PPE program. Fortunately, we have an expert on the podcast today that can provide you with the information that you’re looking for.
On today’s episode, we’re joined by Derek Sang, technical training manager for Bulwark FR. Derek has been involved in the flame-resistant clothing industry for over 20 years, taking on a variety of roles in the garment business from service to manufacturing to training. Over the course of his career, Derek has developed and conducted over 250 educational and informational seminars on FR technologies and the hazards of arc-flash and flash fire for a variety of organizations.
In his current role, Derek has developed over 40 hours of training curriculum for the Bulwark Institute, which focuses on non-commercial training for individuals and companies on thermal hazards, and how to properly design and implement an FR clothing program. Along with being a recognized subject matter expert, Derek is also a qualified safety sales professional, certified environmental health and safety professional and a certified safety health and environmental technician, making him the perfect expert to answer all of your burning FR questions. So thank you Derek for being here with us today on EHS on Tap.
Derek Sang: Justin, thank you for your kind introduction, sometimes I’m not sure how to take that. It makes me feel old sometimes, but I certainly enjoy talking to you today.
Justin Scace: All right, well, so let’s talk about FR or AR clothing meaning flame resistant or arc-rated. So, what protection does this clothing provide and what garments are out there?
Derek Sang: Well, first of all, let’s clear up acronyms. I mean we do a great job and I have to remember that many of our end users here, FR and AR, may not be entirely clear on what that means. So, first and foremost, it depends on your hazard, what terminology you’re going to want to focus on. All arc-rated clothing first and foremost has to be flame resistant, but not all flame-resistant clothing can be arc-rated. So, what does that mean to be flame resistant/arc-rated? Well, flame resistant means that it’s demonstrated through a variety of tests that it self-extinguishes, it puts itself out, it will not melt drip and add to the injury.
Arc-rated clothing or AR means that it has all those flame-resistant characteristics and it has gone through additional testing to protect you in an arc-flash hazard and it’s obtained thus an arc-rating. So, at the very basic, flame-resistant/arc-rated clothing eliminates clothing ignition, and mitigates burn injury by self-extinguishing.
Justin Scace: Okay. So what garments are out there? We’re talking shirts, pants?
Derek Sang: Anything that you can find in the retail space. Everything that you can find in the non-FR space. For the most part you can find replicated in the flame-resistant/arc-rated clothing world. So, if you’d like a particular style of jean, a particular style of outerwear jacket, et cetera, more than likely a flame-resistant/arc-rated clothing manufacturer replicated that.
Justin Scace: Okay. What about undergarments? Is it important for those to be flame resistant as well, just as much as outer layers?
Derek Sang: Yes and no. What I mean by that is first and foremost, everybody needs to be trained on what they can and cannot wear underneath their flame-resistant clothing, because it is important. The first thing we have to eliminate is any multiples, that includes all your blends, that includes your athletic performance gear that you wear in the gym that you may think, “Hey, it keeps me cool, it helps me in hot environments when I’m working out, I’m just going to wear it under my flame-resistant/arc-rated clothing.” No, don’t do it, absolute no fly zone.
But all the standards allow for natural fibers to be worn underneath flame-resistant/arc-rated clothing, and that is fine. Why? Because natural fibers do not melt or drip and thus don’t add to the injury. The caveat or the big asterix you need to see there is as long as that outer layer does not fail, meaning that there’s not enough thermal energy in that arc-flash or that flash fire to break open my outer layer because if I’m breaking [that] open then I’m exposing what’s underneath and that’s usually two things. That’s either me and my birthday suit or that’s my 100% lightweight cotton t-shirt a.k.a fuel, which is now exposed to thermal energy. So, I could technically be exposing fuel to energy by the outer layer breaking up.
So, if you look at good, better, best, wear your flame-resistant/arc-rated garment with just nothing underneath, better, look wear your flame-resistant/arc-rated garment with cotton or wool or silk underneath natural fibers, or best, have an additional layer of flame-resistant/arc-rated clothing underneath. There are lightweight base layers available today so that if that outer layer does fail in that thermal event, you have an additional layer protection. And at the very least, you’ve eliminated any chance of those lightweight cotton t-shirts igniting and causing injury that doesn’t need to happen.
Justin Scace: Great. What trades or occupations should be most concerned with using FR clothing on the job?
Derek Sang: Well, if you think about it historically, first and foremost, the first to really adopt flame resistant clothing, and it was primarily coveralls at the time, was our refineries. Then from refineries we moved into general industry, electricians, that was our arc-flash hazards. Then utilities all came on board even though there was mixed adoption voluntarily throughout the late-90s and into the early-2000s. In 2014, it became law that all our utilities had to wear flame-resistant/arc-rated clothing, and then most recently, you think of our oil and gas exploration, all the drilling that we hear about in our shale place, whether gas, it’s mandated that they have to wear clothing that has flame resistant properties.
One area today, if you were to ask me going “Is there any place that we’re missing?” I would say our combustible dust hazards is probably the biggest area that’s often overlooked. We talk about combustible dust, which believe it or not, there’s 30,000 businesses considered high risk for combustible dust by OSHA. OSHA doesn’t have a regulation for combustible dust yet, but the new combustible dust NFPA 652 standard, and when I say new, we were out in 2016, we’re now going into our first revision of that, requires a dust hazard analysis to get done.
If you have dust in a certain size particulate more than likely it’s going to be combustible. There is a vast array to dust that you wouldn’t think about. Obviously, all our organics people can think of, wood, anything to do with vegetable matter, protein powders. Anything in a fine size is going to be combustible. But you get into your metals like bronze and iron and aluminum. One of the biggest combustible dust incidents we had was in China, thankfully not here in the U S, but hundreds were killed because of these massive fireballs that came out of combustible dust chain reaction, flash fires occurring in facilities.
So, what we find in the U S, is we do a great job down to the admin level. We look at our hierarchy of safety controls, we get down to admin and we forget about, even though it’s the least effective, it is the last line of defense and that’s your PPE. If you have a combustible dust hazard, you should be implementing flame resistant clothing at some way, shape or form in those facilities. So, we have our historic core markets that we serve, that are discussed, and then probably one of the emerging markets that we’re looking at and keeping our fingers on the pulse off to see what’s going, would be our combustible dust hazard.
Justin Scace: Absolutely. Moving on to the nitty gritty of what’s in these garments, it’s like we hear a lot about the health dangers of some flame-retardant chemicals, things like a polybrominated diphenyl ethers or PBDEs. So, are there any similar concerns with FR garments, and are any chemicals used to treat the fibers and the clothing easily absorbed through the skin or are they otherwise hazardous?
Derek Sang: Great question, because there is a lot of misinformation in the marketplace. There’s use of terminology that are not entirely accurate today. For example, this question typically comes up two or three times a year. There’ll be a broadcast news element, something will come through someone’s feed. They’ll be talking about cancer causing agents in fire retardants or flame retardants. Typically, most of those when you drill down, are in textiles that are used in other areas other than clothing.
They’re used in equipment, they’re used to cover furniture, they’re used to slow down burn rates in your homes, in your walls, in construction, et cetera. Because they’re readily available, they’re relatively cheap and they are able to provide some basic flame resistance to these, otherwise elements that would be fuel. But when it comes to clothing, what’s going on your back, first and foremost, people always focus on what the term treated versus inherent. Let’s address that just for a second. Those terms in the 70s were very relevant. Why? Because you had cotton fiber a.k.a fuel that had a fire-retardant treatment put on it so that it would not burn.
Where do we see those garments used? Typically, in the steel industry, you had what was called inherent, which was your easily recognizable DuPont Nomex which dominated the refining environment and that was a molecular change of nylon into Nomex where it won’t support combustion in the fiber itself. You actually changed the molecular makeup of a known product and by changing that it will not be consumed. Then you will not have fire, where cotton is fuel and you are treating it hence the term to impart flame resistant properties, so it will not be consumed and cause injury.
The problem is today, those terms are obsolete. Why? We have something called, for example, FR modacrylics, well FR modacrylics and non-FR modacrylics both exist, how can it be inherent? Because what happens is, when that acrylic is a soup before we extrude it into being a fiber, we add a ton of fire-retardant chemistry. Then we extrude it, so now the fiber has flame resistant properties in it.
Well, isn’t it inherent? Well, no man had to make it. Well, was that Nomex fiber inherent? Well, technically no man had to, humans had to intervene and change the molecular formula. Well, what about that organic or that cellulosic a.k.a cotton, which we know as a fuel? Well, humans intervened and imparted fire-retardant chemistry into the fiber, so it now has flame resistant properties.
At the end of the day we engineer either at the fabric level, which is your cellulosics or what we call cotton rich for the most part. At the molecular level, like we talked about, our Nomexes, our Kermels, our Twarons and then the FR engineering occurs. It’s permanent, it does not carry with it any of these PBDEs. It’s never had the PBDEs as part of that fire-retardant chemistry.
So, when you talk about things to leak into skin, it’s a surface application. We can interact with the treatment itself. That is a misnomer when it comes to everything from quality manufacturers and quality sources here in North America, it does not occur. Both the CDC and NIOSH have recognized this, we did have a big study years ago on the antimony side, in our firefighting community for example, antimony is a known cancer-causing agent. It is a byproduct of FR modacrylics.
But what they were finding out is the exposure was not from their station wear, was not from their turnout gear, it was from them walking on the fire grounds post events and inhaling all the off-gassing from all these modern materials that are now in households. Think about how much antimony from the modacrylic fibers in your carpets, how much other agents are in the new building supplies that go into making a modern household. They’ve known that based on how quickly new homes are consumed versus the older building agents like we had in the 60s and 70s versus how we’re building today in the 2000s.
So, that’s a long winded answer to say that those discussions come up periodically when they’re in the construction industry, when you’re talking about consumer products like electronics, when you’re talking about new building materials, they are not in your flame-resistant/arc-rated clothing fabrics here in North America from quality supply chain partners.
Justin Scace: Okay, well that’s definitely good to know. So how are these garments tested to verify their protective capabilities?
Derek Sang: Good question, because again, at the end of the day, we have to have a barometer, a measuring tool, because when we say flame-resistant/arc-rated, flame resistant and arc-rated to what?
Justin Scace: Right.
Derek Sang: Then we look at our standards, our people, our committees of like-minded folks who are experts in the industry. They come from manufacturing side, the retail side, the fiber fabric side. There are good solid cross section of people who get together and say, “We have to have a bare minimum requirement of what we mean when we say flame-resistant/arc-rated properties.” So, for our arc-flash hazard, we basically look at two primary ones. That’s ASTM 1506. And within ASTM 1506, there’s ASTM 1959, that’s the actual test protocol to receive an arc-rating.
We actually take the three panels in the Faraday cage where we actually set off a controlled arc-flash in the Faraday cage. We expose it 21 different times to a certain fabric weight composition design all that, and it ends up coming out with arc-rating that’s either going to be an ATPV, an arc thermal performance value or is an EBT, energy break open threshold. They’re both the same, and whatever that occurs at, we run some really cool math and we come up with a 50% probability, the second-degree burn, that’s a blister underneath or at that fabric if it’s broken open.
So, there we know, when we say that 8.6 calories of protection or 9.6 or 5.6, I now know how insulated and protective my garment is. I can then take that information, compare it to my arc-flash hazard assessment, and I know that, that gray box on the wall, according to my engineers, if that faults, it’ll produce four calories of energy. So, if I know I have four calories of energy coming out, what do you think my response is on my PPE? I want to have more. So if I have a four calorie box and five calories protection, I’m going in the right area. I don’t want to be in front of an eight calorie box though with six calories of protection.
So, we always want to have more arc-rating versus incident energy. Then on our flash fireside, its different hazard, both thermal, but this we’re talking about a short duration thermal exposure, typically three seconds or less, and we want to design garments out of fabrics that have been exposed to this environment. So NFPA 2112 is your standard there. That’s the standard that tells us as manufacturers how to build garments. There’s a number of tests in there, which fabrics have to pass.
The big one everybody thinks about is ASTM 1930, that’s your mannequin test. That’s the full mannequin dressed in a coverall. We set off eight burners on four torches, two burners per torch for two-calories-per-cm2 for a total of three seconds, so it’s six calorie exposure, and we have to have less than 50% body burn so that we can now start building garments out of that fabric.
So, within that range, you’ll have different fabrics, different weights that have a different body burn compositions so that you can start building garments. Now, the caveat there is you don’t take the body burn graph as the sole predictor of your specification because it’s single layer, there’s no pocket, there’s no attribute, it’s not a commercially viable product. But that is a starting point for manufacturers. Once it passes that test, we can go through a number of other tests, then start building garments.
But what you know at the end of the day, whether it’s an arc-flash or a flash fire, if you have an arc-rating in the garment, it’s been tested to your hazard, and you know what it will insulate you to. In [NFPA] 2112, you know it’s a minimum of less than 50% body burn, and then they start building garments towards them. So, bottom line is they’ve been tested in the hazard that they’re supposed to be exposed to. Most of the garments are made out of fabrics today that are dual hazard. You’ll see both an arc-rating and independently certified. Typically, UL has certified that it meets the requirements of NFPA 2112.
So technically I can be on a refinery with a flash fire hazard as an electrician with an arc-flash hazard and I could be wearing the exact same garments and be protecting to both hazards.
Justin Scace: Oh, very cool. So, what’s the usual shelf life for these FR garments? They sound, obviously, the testing you’ve described is pretty intense. I would assume, are they very durable?
Derek Sang: Really good question because this is as you’re going through this evaluation process, first and foremost, it has to meet the standards, that’s your bare minimum. Then you want to look at how durable is it? What are the manufacturers saying I can expect this performance to last? What you want to look for is guarantee for the life of the garment.
Now, two things when you say that, one; that sounds pretty salesy because it sounds somewhat ambiguous. What do you mean by that? I’ll tell you that shortly. And then secondly, it does not correlate or have anything to do with the FR properties, assuming that it’s coming from a good quality manufacturer.
However, you rate that and you can think of all the manufacturers in the United States and North America here and you’re probably going to be pretty good picking one of them, so I’m not trying to be biased and point you to one. I’m saying there’s a number there, but you want to make sure it comes from quality manufacturers because life of the garment is what that real life is.
Meaning, if I’m on a refinery, if I’m working as a heavy-duty hydraulic mechanic, that garment may only last me eight months. Why? I just burn through clothes, the job that I do, the environment that I’m in, how I’m abrading that garment, what I’m rubbing up against on a daily basis and I can just be hard on clothes.
I can be in the same refinery and I can be in operations, sitting in a controlled environment, air conditioned behind glass and all I do is push a green button and a red button alternating throughout the day. That coverall could last me seven years, if it’s in good wearable, usable condition the FR properties are guaranteed for life, and that’s regardless of how that FR engineering was achieved.
Was it inherent, where we changed the molecular structure? Was it treated where we imparted FR chemistry into the fiber matrix? Or was it a hybrid where it’s an FR modacrylic with some aramid, with some para-aramid, with some Kevlar, with some lyocell, with some non-FR cotton for comfort… however we achieve that FR engineering is irrelevant if it’s going to last for the life of the garment, and that’s the guarantee that you want to see. Because then it’s durable, then you know that it’s going to perform day one, day 1001 and more importantly the day that you need it.
Justin Scace: Yeah, absolutely. Some jobs, they’re harder on these clothes than others. So, what if you’re wearing this clothing while you’re working with hazardous material? Like let’s say you’re removing asbestos or something like that. Are these garments washable or are they disposable? Like, what’s the deal with that?
Derek Sang: Well, I’m going to go answer that question backwards. First and foremost, there are disposable cover ups that you can get to protect that expensive flame-resistant/arc-rated clothing that you’ve got. Because on average today you’re looking at $125 to $150 for a shirt and pants and you definitely don’t want to be exposing it to something that could permanently damage it. So, there are disposable lightweight tie cam type products. The key there is if you’re using anything as a disposable over the top of your flame-resistant/arc-rated clothing in a thermal hazard, make sure that disposable has thermal properties, that it will protect you, it will not ignite, melt drip and add to the injury.
Basically, you want it in an arc-flash or a flash fire to be consumed rapidly, so it’s not there. Then what you’re wearing underneath, which is for that hazard, is going to do the bulk of the protection. So, you don’t want that outer layer melting, dripping or igniting. So, you do want it to have some flame-resistant properties. That’s number one.
In the name of your question, or in the bulk of your question there, you talked about something about asbestos. Well, asbestos obviously is nasty, I don’t want any of that getting on my garments. Can I be 100% sure that I’m washing it out? Probably the question there would be, in all honesty, if I get 99.9% of it out, how do I document that?
So if I was asking that specific question from an end user, I would say, remove the hazard, eliminate the hazard, go through your hierarchy of safety controls and don’t have to wear your expensive flame-resistant/arc-rated clothing while you’re removing asbestos. Get it to where it’s de-energized or the hazard is not available. Then you can just get into the primary PPE for that hazard.
You’re going to get into something that in a thermal event would be meltable, but as designed for that hazard, you’re going to have your breathing apparatus, your hood, you’re getting into a barrier that’s going to, that you just then dispose of through your proper safety practices, and the thermal is not a concern.
So, you wouldn’t be wearing that expensive gear in there. You wouldn’t be having to take it to that extra level of protection. So, if you do have to remove asbestos in an energized electrical environment or a flash fire threat environment, remove the hazard, and then you don’t have to wear your expensive flame-resistant/arc-rated clothing.
Justin Scace: Definitely. So, what happens if the garment gets wet in the course of working? Does that affect its protective qualities at all?
Derek Sang: Good question, because there’s two schools of thought here, in the lab and in the real world. We have seen in the lab when we get FR clothing wet, what it does is, arc-flash would flash steam that moisture, possibly transferring and they’ve seen transfer into the calorimeter that’s sitting behind that fabric where you’re registering 1.2 calories-per-cm2. That’s the onset of a second-degree burn. So, when that happens, typically has been lower than the advertised insulative ATPV or arc-rating that we talked about.
So, let’s say my arc-rating is 8.5, I saturate that garment, I do the test again and I’m down now at six. So, I’ve reduced my protection because the theory is that, that arc-flash is so intense, it flashes the moisture to steam, the steam transfers into my skin causing me to be injured. That’s in the laboratory.
The tough thing is, we don’t see that in the real world. We don’t have any evidence of really anybody being in an arc-flash event when they’re soaking wet and being more injured than they should be under the protective PPE. So, it’s one of those tough things to really answer. Bottom line is we’re going to have to do a lot more work on it.
The other side of the equation that I always call to is, how wet is too wet? We’re talking about sweat? Then, everybody sweats at a different rate. How are you going to manage and communicate that? If we’re in the rain, if we’re in the snow, if we’re in the sleet, there’s additional PPE that you should be wearing. For now, your primary hazard is the environment. Don your arc-rated rain gear, don your ASTM 2733 rain gear for flash fire protection. Go get your rain gear on, go get that additional layer because now you’re getting wet, you’re getting rained on, you’re going to potentially get cold, you’re going to get uncomfortable and you’re going to be at risk of causing or having an accident because you’re fighting the environment.
So, good question. We have some lab results that we’re still kicking around. We have some real-world empirical evidence that we see and know when we have incidents. Then the other thing is, don’t work wet. If you’re starting to get rained on or you see rain coming, get down out of the bucket, get off the yard, either get back to your tool room and check out your appropriate and approved rain gear or get down out of the bucket, go in the cab and put your rain gear on and then get back to work. So, take your time and don’t work wet if possible.
Justin Scace: Great. So, what about other wear and tear? You mentioned this a little bit before, if you get rips or holes in the clothing, is it okay to like patch those up yourself or do you need to get a new garment?
Derek Sang: This is one of those ones that turns into…[groan]…I’m going to answer what the standards say and then I’m going to tell you what Derek says.
This is your PPE, this is your last line of defense. Can you repair it? Yes. Here’s the rules, like material. So, have an old shirt, old pant that you can use for patching, and use flame-resistant threads. So, most people have access to the Google box, get on Google, type in Nomex or aramid thread. Hopefully it pops up on Amazon somewhere, which I believe it does. If you’re a Prime member, you can get it within two days and order yourself up some FR thread.
Now you’re going to make little patches and you’re going to sew them onto your clothing. It doesn’t tell you how often you can do that. It doesn’t tell you what size those rips and tears can be. So, what’s the rule of thumb coming from Bulwark’s technical people. If you make the okay sign with your thumb index finger, you’ve got three fingers standing up. That’s a tear of three inches. That’s our rule. If you reduce that thumb and index to the size of a nickel, that okay sign now tells you how big a hole and how long a rip you can repair.
Justin Scace: Okay.
Derek Sang: Now, Derek’s. This is your PPE, this is your last line of defense. You do not allow your safety harness, your fall harnesses to be ripped, frayed, cut, tear, and you wear it properly. Take the same mentality with your flame-resistant/arc-rated clothing. I talk to guys all the time who wear their fall harness on a regular basis and have never fallen, but they would not be allowed to climb, they would not be allowed to climb, they will not be allowed to be in it, working at height, if there was a cut, a fray or a tear on any of that gear. They’re not allowed to do it.
Why would you? I’ve never been in a flash fire, I’ve never been in an arc-flash, but I’m going to allow my clothing to become threadbare, torn, patched up. We just take a completely different mindset when it comes to our last line of defense in clothing, yet if you’re in a thermal event, that’s the only thing that you’ve got working in your advantage to how you’re going to come out of that, but you’ll jeopardize that by letting it get all torn up, secondary accelerants all over it, just gunked up and it’s not going to work as well as when you need it. Take the same mindset that you would with your fall harness and it’ll go a long way to wherever you need it to work, it’s going to work as best as it can.
Justin Scace: Yeah, that’s really good point. My next question, I think I got an idea of the answer because we touched on it before, but can you wear other clothing on top of your FR clothing? Like if you have to wear hi-vis vest or other forms of PPE and maybe some of these garments aren’t flame resistant, can you wear those, or will that render the FR clothes ineffective?
Derek Sang: Justin, you’ve went from one of my pet peeves to my biggest pet peeve. Let me explain what I mean by that. If you are wearing arc-rated or flame-resistant clothing to the hazard, do not put anything on top of that, that has not been equally tested to work and perform in your hazard, because why? It will nullify all that investment, and all the performance requirements of that flame-resistant/arc-rated clothing that it’s on top of. So you’ve invested tens of thousands of dollars on your team over the year and you put a $25 hi-vis vest that says it’s FR on the packaging, and you put that on top, you can nullify that whole investment in literally the blink of an eye.
There are vests and rain wear out there today that have and are being marketed as flame resistant. Why? They’re able to pass one test that allows them to market as FR. It is a grey area, a loophole, however you want to categorize it in what we do today. Now ANSI, because of the high visual requirements typically from vests and rain gear. ANSI 107-2015 drilled down and said, “Look, you can’t claim to be flame resistant and ANSI unless you meet one of these six standards.” ASTM 2302, ASTM 2733, ASTM 1891, NFPA, Oh my gosh, it’s slipping me now, I should have it right on top of my head.
The bottom line is there are six categories that you can’t, and if you’re not in those six standards, you can’t claim that you’re flame resistant. The one that we see the most of today is on the label. It’s ASTM 6413 and you’ll have the initials, SE meaning it self-extinguishes, that is meaningless in what we do in arc-flash and flash fire. In fact, it’s not a performance standard. All it said is it passed a vertical flame test. It’s demonstrated that it’s self-extinguished, it meets a certain char length.
Well, think about it. If I hold plastic over flame, the plastic runs away from the flame, hence I don’t ignite. Hence, I don’t have a char length. That doesn’t make you self-extinguishing by definition, it just says that you have kind of passed that test. Well, when you put that out there, people think, “Oh well, it’s the same as being ASTM 2733 which is for rain gear and flash fire. Or it’s the same as ASTM 1506 which is getting an arc-rating in an arc-flash.” It is not. The difference is, it’s about 25 bucks versus 75 bucks, which you should be paying, but you’re trying to save $50 and that $50 save could jeopardize the tens of thousands of dollars that you’re investing in your proper flame-resistant/arc-rated clothing.
So be very, very cautious. Be very cautious of people marketing that their vests meet NFPA 70E, and are Cat 2, that’s impossible. The fact that people have it on their marketing brochures is shameful. Why? Right in NFPA 70E 130.7 it says, arc-rated shirt, pant coverall, you must have sleeves and you must be able to button it up, show me a vest with sleeves and show me that you can button it up. Then it’s called a shirt, not a vest.
Justin Scace: Right, right.
Derek Sang: So, when you see these companies marketing and using our terminology to convince you that they’ve done the appropriate work, be very, very cautious. The easiest thing that I tell people, if your rain gear costs you a 100 bucks, you got the wrong rain gear. If your vest costs you 25 bucks, you got the wrong vests. It should be more like 400 to $500 for the proper rain gear that’s going to protect your people in the hazard and closer to 75 to a 100 bucks for the vests that are going to protect your people if there’s a hazard.
Justin Scace: Wow. Yeah, that’s very important for our audience to know. Yeah, thank you for that advice. Now, I’m going to shift gears here a little and we could talk a little bit about PPE compliance, that’s always a big deal. So, I imagine that a common complaint that workers may have when they’re wearing their FR garments like, sleeves rolled down, tucked in, is it that they’re too hot? Are there any heat stress risks with this type of PPE and how can they be managed?
Derek Sang: Awesome, because if there is one thing categorically, if you say ‘flame-resistant clothing,’ you may as well say ‘too hot’ at the same time. It’s that old psychology test, give me one word, when I say FR you say hot.
Justin Scace: Yep.
Derek Sang: Absolutely. So the answer is two-fold: First and foremost, when you say it’s hot, are you talking about actually something that is measurable, like heat stress or something that’s entirely subjective, like comfort. And let me address comfort first, and here is why. Next time that you have a company meeting and you’re sitting getting ready to address your team, take a look at your team.
Your team is sitting in a controlled environment, typically about, 68 to 72 degrees. As you look over your team of 20, 30, 40, 50, whatever the environment is, they’ll be wearing t-shirts, short-sleeve polos, long sleeve polos, long sleeve t-shirts, a t-shirt and a hoodie, a hoodie, sweatshirt, sweatshirt and a t-shirt, long sleeve button down, short sleeve button down, and they’re all going to be comfortable in that environment or they would dress differently.
That being said, comfort is subjective. It has nothing to do with a measurable disease such as heat stress. So, how does flame-resistant/arc-rated clothing fit into a heat stress? The short answer is both OSHA and NIOSH have stated single layer, and this is important, flame-resistant/arc-rating clothing does not trap heat or restrict heat removal any more than regular non-FR clothing. Why is that? Because heat is shed primarily by evaporation of sweat. And what causes heat stress is the restriction of evaporation.
Because once you get into ambient air temperatures greater than 98.6 degrees, the three cooling methods that you have, excuse me, the four cooling methods that you have, you’re only down to one and that is evaporation that is sweat. What restricts sweat is either physiological conditions like I’m dehydrated or my medication or my physical fitness level. Then the other thing is if I put a barrier on there, yes, when we put a barrier, like we talked about tie cam, we talked about rain gear, we haven’t talked about arc-flash suits but donning an arc-flash suits has to be monitored.
That can’t be an all-day environment. That is going to elevate our body temperature and we won’t be able to cool off, and that’s going to take us into heat stress conditions, and we’ll march through rash, and we’ll muck all the way through down to exhaustion where we’re calling 9-1-1. But the bottom line is that, when it comes to my basic all day, every day single layer, whether that’s a shirt, pant or coverall, there is no correlation between the FR properties that are there versus if you had non FR properties.
More than likely any heat stress is going to be caused by something that is a physiological or to where we’ve introduced a barrier or multiple layers, heavy layers to where we are impeding that ability to evaporate.
Justin Scace: Okay. So, with any form of PPE ensuring that your workers are being compliant, training is vastly important. So, how can employers frame and present their training on this topic to ensure FR garment compliance and proper usage among their workers?
Derek Sang: Well, so first, shameless promotion here, my team of Bulwark certified trainers will come out and we’ll take care of that OSHA 1910.132 component to where you have to record and demonstrate and do all those things as far as donning and doffing your PPE and understanding what it can’t do. And most important thing that we have to train our end users on is, what it can do. That all being said, having selected the proper flame-resistant/arc-rated garments for your hazard, that’s the first step.
All your standards and all your…and importantly, your regulation says that you have to train people on how to correctly wear, and how directly that impacts what they’re going to do on a day-to-day basis. They have to know to tuck them in, roll them down, button them up, and that’s how you implement your PPE on a daily basis. They have to be taught on what they can and cannot wear underneath their PPE.
Then as the employer, they get to document, “Hey, that training was done, that training was 45 minutes. Everybody that attended, boom, boom, boom. Now, it’s documented.” We can record that for [posterity]. So you can reuse it however you want to do it, but get what good subject matter experts, it should be a no-cost part of anybody’s program and it should be relatively easy to get that regulatory requirement met.
Justin Scace: Great. I’m sure that real world stories help drive home the importance of properly wearing FR clothing. Whether you tell them during training or maybe while on the job, during a toolbox talk or something like that. Now, do you have any story from the field about how FR garments have saved lives?
Derek Sang: It’s probably the single most rewarding part of what we do Justin. On a regular basis we typically have either the end users themselves, their safety manager sending us pictures via email. We’ve got some of them up in…what do you call those boxes? Those little boxes that…view boxes, I forgot the correct name for those. But we have those on display on our third floor of our facility. We see those on a timely manner.
Obviously, the garments have suffered the results of a violent short duration thermal event, whether that’s an arc-flash or a flash fire, they’re damaged severely but the last line of that email or the last line of that phone call always concludes with, “And they were okay.” Or “They weren’t hurt as bad as they could have been.” It’s got some slight burns, but nowhere near what could have happened. Those are always great to share with our folks, especially when sometimes if you’re on the front lines, if you’re in customer service, if you’re down on inside sales, if you’re supporting this vast network, sometimes you forget that.
I tell my team all the time, “Remember we do not make shirts, pants and coveralls.” That sounds humorous when you’re talking about the largest flame-resistant clothing manufacturer in the world. That’s not what we make, we make life saving pieces of equipment, and we want people to understand that. I hope you never have to use my shirt, pant or coverall for what we are building it for. We’re building it to ultimately to save your life. I want you to go through your whole career saying, “I never had to use your stuff for what you built it for.”
That being said though, it’s so important that all those bells and whistles are built into that garment and are there when you need it. Because when you find out if you’re going to cut some corners, if you’re looking to buy or invest in inexpensive garments, there has to be some things cut out. Unfortunately, you don’t know that until you need it. And that’s the downside. You’re basically investing in the hope that you never have to use it for what it’s built for in the first place.
Justin Scace: Absolutely. So what does the future look like for FR garments? Are we looking at any new developments on the horizon?
Derek Sang: Aren’t we always? Aren’t we always? Our goal right now and where the market is trending is we’re looking to create true performance work wear for that occupational athlete, we’re looking to take all that technology, all that kinesiology, all that science of movement that we’re seeing in our performance world, in our performance fabrics, and we’re looking to get that into the flame-resistant/arc-rated market, and ultimately to fit the comfort equation, or the comfort objection back to your “it’s too hot” objection.
We want PPE that’s going to aid our professionals and aid our safety people by driving compliance through comfort. How’s that going to look? Can we open up the weave? Think about it: garments are built to protect you against thermal energy. Thermal energy is going to find any window that it can get through. But, what if I had a fabric that stayed open and wide and allowed a lot of air permeability, but instantaneously fused shut as a barrier between you and that thermal event during when it happened.
Moisture wicking technology, that’s not a finish, it’s actually built into and is a core characteristic of that fiber. So, it lifts moisture from your body rapidly moving it to the outside where it can evaporate, if you’re dry, you’re comfortable. But there’s also other byproducts. When I start looking at thermal regulation, if I have big open spaces, those garments are easier to clean. If I move moisture rapidly, they’re easier to dry, so they become more economical to actually use.
You look at durability, utilizing fibers because why? Like I said earlier, a set is between $125 and $150. I don’t want it lasting six months; I would like it to last about three years. So, increasing superior resistance to embrace and improve your ROI. But at the end of the day, we say all those things and none of them matter if first and foremost, I can’t protect you. Protection comes first in what we do. Then, if I can be comfortable, great, if I can give you a great return on your investment, outstanding.
But first and foremost I have to protect. So, we’re looking at advancements in that FR engineering, looking at advancements in molecular fiber and fabric contents. That’s going to give you something that is supremely protective, ultimately a very, very comfortable wear. So, I increase compliance through comfort and at the end of the day you are comfortable making that payment on that lifesaving piece of equipment.
Justin Scace: Absolutely. That’s great. A lot of interesting stuff going on in this area of protective equipment. Thanks so much Derek for sitting down to chat with us today on EHS on Tap.
Derek Sang: Loved it Justin. I appreciate it and thank you for the time, and greatly thanks for the platform.
Justin Scace: Absolutely, you’re very welcome. Thanks also to our listeners for tuning in. Now be sure to keep an eye out for new episodes of our podcast and keep reading the EHS Daily Advisor to stay on top of your safety and environmental compliance obligations. Get the latest and best practices and keep your finger on the pulse of all things related to the EHS industry. Until next time, this is Justin Scace for EHS on Tap.
|When you conduct an average of 20 live trainings a year for over 500 people in seven different countries, most would consider you an FR expert. And that’s exactly how many refer to Derek Sang. Derek has been involved with the flame-resistant (FR) clothing industry in a variety of roles from the service, manufacturing and garment sides of the business for over 20 years.
The first 10 years of his career Derek worked directly with end users developing and implementing flame-resistant clothing programs specific to the customer’s hazards. Over the past 15 years, Derek has worked closely with fortune 1000 companies as they look to develop FR clothing programs, educating them on various fabrics and FR technologies as well as the dynamics of arc flash and flash fire hazards.
Over the course of his careers, Derek has developed and conducted over 250 educational and informational seminars on the hazards of arc flash and flash fire for a variety of companies, associations, and organizations including NSC, VPPPA, NJATC, NECA, and ASSP.
In his current position as a Technical Training Manager, Derek has developed over 40 hours of training curriculum for The Bulwark Institute. These training efforts cover all aspects of FR clothing and are delivered utilizing live class courses, online training, webinars, and in-person seminars. The Bulwark Institute focuses on noncommercial training for individuals and companies on the thermal hazards and how to properly design and implement an FR clothing program.
Along with being a recognized Subject Matter Expert (SME), Derek is also a Qualified Safety Sales Professional (QSSP), Certified Environmental, Health, Safety Professional (IASHEP), and Certified Safety Health and Environmental Technician (IASHEP).
EHS on Tap is an environmental, health, and safety podcast by BLR’s EHS Daily Advisor. On each episode of EHS on Tap, our host will discuss emerging legal, regulatory, and policy issues with industry experts and the impacts to everyday safety and environmental professionals. EHS on Tap topics run the gamut of contemporary issues facing EHS managers and professionals today.
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