OSH Magazine

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HAZMAT: Head-to-Toe Protection 28

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MARCH 2015 VOL. 84 NO. 3 | www.ohsonline.comBREAKTHROUGH STRATEGIES: ATTENTIONALLY AVOIDING TRAPS – AND TRIPS

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FROM THE EDITOR

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VOLUME 84 NUMBER 3

EDITORIAL STAFF

EDITOR Jerry Laws

E-NEWS EDITOR Brent Dirks

SENIOR EDITOR Lindsay Page

CONTENT DEVELOPMENT Matthew Holden

ART STAFF

ART DIRECTOR Dale Chinn

PRODUCTION STAFF

DIRECTOR, PRINT AND ONLINE PRODUCTION David Seymour

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INTEGRATED MEDIA REPRESENTATIVE-WEST Barbara Blake 972-687-6718

INTEGRATED MEDIA REPRESENTATIVE-EAST Jenna Conwell 610-436-4372

SECURITY, SAFETY, AND HEALTH GROUP

PRESIDENT & GROUP PUBLISHER Kevin O’Grady

GROUP CIRCULATION DIRECTOR Margaret Perry

GROUP MARKETING DIRECTOR Susan May

GROUP WEBSITE MANAGER Scott Newhouse

GROUP WEBINAR ADMINISTRATOR Tammy Renne

GROUP SOCIAL MEDIA EDITOR Ginger Hill

CHIEF EXECUTIVE OFFICER Rajeev Kapur

SENIOR VICE PRESIDENT & Richard Vitale CHIEF FINANCIAL OFFICER

CHIEF OPERATING OFFICER Henry Allain

EXECUTIVE VICE PRESIDENT Michael J. Valenti

VICE PRESIDENT, INFORMATION TECHNOLOGY & Erik A. Lindgren APPLICATION DEVELOPMENT

VICE PRESIDENT, EVENT OPERATIONS David F. Myers

CHAIRMAN OF THE BOARD Jeffrey S. Klein

REACHING THE STAFFEditors can be reached via e-mail, fax, telephone, or mail. A list of editors and contact information is at www.ohsonline.com.

Email: To e-mail any member of the staff please use the following form: [email protected].

Dallas Office: (weekdays, 8:30 a.m. – 5:30 p.m. CT) Telephone: 972-687-6700; Fax: 972-687-6799 14901 Quorum Drive, Suite 425, Dallas, TX 75254

Corporate Office: (weekdays, 8:30 a.m. – 5:30 p.m. PT) Telephone: 818-814-5200; Fax: 818-734-1522 9201 Oakdale Avenue, Suite 101, Chatsworth, CA 91311

Occupational Health & Safety (ISSN 0362-4064) is published monthly by 1105 Media, Inc., 9201 Oakdale Avenue, Ste. 101, Chatsworth, CA 91311. Periodicals postage paid at Chatsworth, CA 91311-9998, and at additional mailing offices. Complimentary subscriptions are sent to qualifying subscribers. Annual subscription rates payable in U.S. funds for non-qualified subscribers are: U.S. $79.00, International $149.00. Subscription inqui-ries, back issue requests, and address changes: Mail to: Occupational Health & Safety, P.O. Box 2166, Skok-ie, IL 60076-7866, email [email protected] or call 847-763-9688. POSTMASTER: Send address changes to Occupational Health & Safety, P.O. Box 2166, Skokie, IL 60076-7866. Canada Publications Mail Agreement No: 40612608. Return Undeliverable Canadian Addresses to Circulation Dept. or XPO Returns: P.O. Box 201, Richmond Hill, ON L4B 4R5, Canada.

© Copyright 2015 by 1105 Media, Inc. All rights re-served. Printed in the U.S.A. Reproductions in whole or part prohibited except by written permission. Mail requests to “Permissions Editor,” c/o Occupational Health & Safety, 14901 Quorum Dr., Ste. 425, Dallas, TX 75254.

The information in this magazine has not undergone any formal testing by 1105 Media, Inc. and is dis-tributed without any warranty expressed or implied. Implementation or use of any information contained herein is the reader’s sole responsibility. While the information has been reviewed for accuracy, there is no guarantee that the same or similar results may be achieved in all environments. Technical inaccuracies may result from printing errors and/or new develop-ments in the industry.

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4 Occupational Health & Safety | MARCH 2015 www.ohsonline.com

Recognizing Real Progress

Joe Main, head of the Mine Safety and Health Adminis-tration, gave a speech in late January in which he sum-marized how much mine safety in the United States has improved during the past five years. Speaking at the

West Virginia Coal Association’s 42nd Annual Mining Sym-posium in Charleston, W.Va., he said mining deaths fell from an average of 96 to 45 per year during the first half of this decade, and that 16 coal miners died on the job during 2014, which was the lowest number ever recorded for the industry in the United States.

Main said compliance also has improved, with total cita-tions and orders issued to coal mine operators falling from more than 96,000 in 2010 to 62,828 in 2014. Levels of respirable coal mine dust in un-derground coal mines have fallen to new lows since 2009, when MSHA launched its End Black Lung—Act Now campaign, he said, and he touted the benefits of recently enacted rules to prevent coal dust explosions and require proximity detection devices on continu-ous mining machines in underground coal mines.

He said the backlog of contested violations by mine operators has plunged, from 89,000 in 2010 to 27,500 in November 2014.

One area of concern he cited is fatalities at metal and nonmetal mines, which rose to 25 last year. On Jan. 30, MSHA posted a PDF document summarizing its 37 fatality investigations at metal and nonmetal mines from October 2013 to January 2015. In basic charts, it showed the highest number of fatalities involved mine employees who had more than 15 years’ experience at their mine. MSHA’s list of root causes in these fatal injuries will sound familiar to every safety professional: failing to provide training, to de-energize and lock out machinery, to conduct pre-operational checks, to maintain mobile equip-ment, and to provide and wear PPE.

JERRY [email protected]

U.S. mining deaths fell from an average of 96 to 45 per year during the first half of this decade, MSHA chief Joe Main said.

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TABLE OF CONTENTSMARCH 2015 | Volume 84, Number 3 | www.ohsonline.com


featuresHEAT STRESS & THIRST QUENCHERS

10 Reducing Heat Stress with HVLS FansHigh-volume, low-speed fans help cool off employees and improve efficiency. by Dan Anderson

16 Maintaining Body Temperature in Extreme Conditions with FR GarmentsBy selecting FR garments with THL measures and layering in mind, safety managers can take steps to ensure employees will be able to maintain a safe and comfortable temperature in the workplace. by Cortlandt Minnich

HEARING PROTECTION

19 Addressing Noise in the WorkplaceOne of the most important things for a successful program is to get employees to feel like they are being included in the decision process of developing the program. by Larry Birkner

HEAD & FACE PROTECTION

24 Preventing Occupation and Non-Occupational Head InjuriesPreventing occupational head injuries starts by following the hierarchy of controls. by Jerry Laws

HAZMAT

28 Hazmat Protection from Head to ToeTrue hazmat gear must provide protection to the entire body. The iconic yellow suit is only one component in providing complete safety for the wearer. by Jim Towey

PROTECTIVE APPAREL

32 Disposable Secondary FR Garments: What Really Matters When Selecting a GarmentClearly, the addition of a flash fire or flame hazard to a scenario involving dry or liquid chemicals can significantly complicate protection. by Charles D. Roberson

40 The Evolution of FR DenimToday’s workers are looking for the fits, features, and finishes of retail-ready denim but with proven flame-resistant protec-tion. by Craig Tutterow and John Strickland

44 Durable Flame Resistance: Comfort and QualityReal-world applications have brought on an increasing demand for garments that are suitable for use in environments with multiple hazards. by Thomas Kiddle

FIRE SAFETY

48 Implementing a Fire Protection Inspection, Testing, & Maintenance Program for Water-Based Fire Protection EquipmentHistory has shown that some of the largest industrial fires have occurred when systems were out of service, or impaired. by Walter S. Beattie

LOCKOUT/TAGOUT

51 Technology to the RescueLOTO technology can create a safer workplace and make compliance more efficient. by Darcie DaSilva and Steve Burgess

TRANSPORTATION SAFETY

54 DOT’s Lithium Battery Final Rule Takes EffectNow, packages of any size that contain lithium batteries must be properly sealed and labeled, which could present a challenge to smaller businesses. by Matthew Holden

LOCKOUT/TAGOUT

56 Machinery Safety Survey Results: Safety Interlocks and Used EquipmentIt is apparent that those responding generally knew that used industrial production equipment may not have all of the safety whistles and bells. by Gary M. Hutter

departments4 From the Editor8 Newsline60 New Products61 Practical Excellence by Shawn Galloway62 Product Spotlights64 Product Literature64 Classifieds65 Advertiser Index66 Breakthrough Strategies by Robert Pater

Find OHS on: Twitter http://twitter.com/OccHealthSafetyFacebook http://facebook.com/ohsmagSafety Community http://www.safetycommunity.com/ profile/OHSMagazine

JUSTIN KRAL/SHUTTERSTOCK.COM

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NEWSLINE

www.ohsonline.com


ADVISORY BOARD

Leo J. DeBobes, MA (OH&S), CSP, CHCM, CPEA, CSC, EMT

Stony Brook University Medical CenterStony Brook, NY

Scott LawsonThe Scott Lawson Companies

Concord, N.H.

Angelo Pinheiro, CSP, CRSP, CPEASenior HES ProfessionalMarathon Oil Company

Houston, Texas

William H. Weems, DrPH, CIHDirector, Environmental & Industrial Programs

University of Alabama College of Continuing StudiesTuscaloosa, Ala.

Barry R. Weissman, MBAPrincipal

Weissman ConsultantsPiscataway, N.J.

Henry Wright, MBA, CFPSSenior Vice President & Director — Risk Solutions

BB&T Insurance Services Inc.Charlotte, N.C.

On the MoveHaws Corporation announced four new team members and four internal promo-tions in December 2013: Per Lindvall joined as managing di-rector-Asia Pacific, Lynda Murdock as human re-sources manager, Bran-don Siri as digital market-ing manager, and Arthur Salas as Haws Integrated production supervisor. Those promoted include Michael Joyer to research & development manager, Theresa Auld to director of human re-sources, Stephanie Kil-roy to human resources program manager, and Daniel Page to assistant production supervisor. . . .SHOWA has named Shuji Kondo as its Ameri-cas president and COO, the company an-nounced Jan. 5. He replaces Bill Alico, who remains on the company’s board of direc-tors and serves as a strategic adviser. Also, Charles Miller has been appointed Ameri-cas vice president of sales and marketing af-ter serving for 11 years as Americas central regional manager. Tom Eggleston, former Americas VP of sales and marketing, also joined the board of directors and continues to support strategic sales and marketing initiatives. “After more than 30 years in the industry, the time is right to transition to an advisory role and support our next genera-tion of visionary leaders,” Alico said. “Kon-do’s vast experience will help us to facilitate regional connectivity and strengthen our position as a global powerhouse in hand protection.” . . . . . . . Ronald J. Ebelhar, P.E., D.GE, senior principal with Terracon in Cincinnati, Ohio, is serving as chairman of the 2015 ASTM International board of di-rectors. He is a registered professional en-gineer in eight states who joined ASTM in 1980. An ASTM fellow and 2003 Award of Merit recipient, Ebelhar has served on the ASTM board of directors since 2010. . . The Railroad Commission of Texas recently appointed Lori Wrotenbery director of its Oil and Gas Division. She previously was director of administration for the Okla-homa Corporation Commission (OCC) and had been deputy director and assistant

director for environmental services in the Oil and Gas Division of the Railroad Com-mission of Texas prior to that. . . . Health Conservation, Inc., which is based in Rockford, Ill., and provides mobile audio-metric testing, named David M. Gladson its national sales director. He has more than 20 years of professional sales, marketing, and client development expertise spanning consumer package goods, retail consulting, employee recognition and wellness, and brand marketing industries. . . . The Sys-tems Group (www.tsg.bz), which is based in El Dorado, Ark., has added Lee Morgan as president. TSG is a group of companies engaged in fabrication, plant maintenance, and construction for steel mills, foundries, metal processing plants, petrochemical plants, and manufacturing facilities. Mor-gan will oversee all three companies that comprise the privately held group: Systems Contracting Corporation, American Steel Company, and Systems Spray-Cooled Inc. He previously was GM and later presi-dent of Camfil Air Pollution Control, which announced it has promoted Thomas “Tomm” Frungillo to the position of vice president, Camfil APC Americas. Camfil Air Pollution Control also promoted four members of its sales management team to new positions: John Dauber to Handte product manager for the Americas; Matt Caulfield to director of sales–USA/Cana-da; Rick Kreczmer to director, aftermar-ket sales and corporate training; and Greg Schreier to director, OEM accounts/metal and thermal spray market manager. All four report to Frungillo. . . . The Lincoln Electric Company has promoted Steven B. Hedlund to senior vice president and president, Global Automation. He previ-ously was senior vice president, Strategy and Business Development.

Business Moves■ Bloomfield, Conn.-based Kaman Cor-poration announced it has sold its Mexico business unit Delamac de Mexico, S.A. de C.V. to Rodamientos y Accesorios S.A. de C.V (RYASA) of Mexico. “We did not have sufficient scale in Mexico to achieve our long-term targeted profitability goals and believe the operation will be better aligned with RYASA. We are grateful to the em-ployees of Delamac for their commitment and service to Kaman and believe the new

ownership will be beneficial for all parties,” said Kaman Executive Vice President and distribution segment President Steven J. Smidler. Delamac distributes bearings, power transmission products, lubrication systems, and related parts and accessories from 12 branch locations in Mexico.

■ The Bachelors of Science in Environ-mental Health and Safety from Missouri Southern State University in Joplin, Mo., recently joined the Institute for Safety and Health Management’s Board Approved De-gree Programs. To be approved for BS-level credit, the major must have a minimum of 36 semester hours of safety-specific courses and must include a minimum of nine se-mester hours of management-exclusive safety courses. A student earning a BS in EHS from Missouri Southern is automati-cally qualified for the institute’s Associate Safety and Health Manager (ASHM), and if application is made within six months of graduation, the application fee is waived. In addition, it fast-tracks the student toward becoming a Certified Safety and Health Manager (CSHM).

The institute recognizes degree pro-grams from 12 other higher education in-stitutions in Alabama, West Virginia, Ken-tucky, Pennsylvania, Wisconsin, Michigan, and Texas. For more, visit www.ishm.org.

PER LINDVALL

MICHAEL JOYER

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HEAT STRESS & THIRST QUENCHERS


E xtremely hot weather has always presented problems for industrial facilities, but never more so than today. Excessive heat issues can directly affect an organization’s bottom line,

causing legal, insurance, and regulatory headaches, not to mention lowering employee productivity and morale. With online commerce driving an ever-faster pace of shipping and receiving, monthly average tem-peratures on the rise, and several high-profile lawsuits in the public’s consciousness (and case law books), facility managers are facing a perfect storm of heat-related issues this summer. Fortunately, there are sev-eral ways to address this issue.

Types and Causes of Heat StressHeat stress can manifest itself in a variety of forms. While some are less severe than others, all are poten-tially dangerous. The mildest form are heat fatigue, in which workers begin to lose concentration and per-form erratically, and heat rash, which occurs when sweat ducts get plugged and skin becomes agitated and painful. People who’ve had previous heat rash or extreme sunburns can become more prone to this. Heat stress may also cause heat cramps, typically in the larger muscles used during work, including the

back, arms, legs, and abdomen. Dehydration and electrolyte imbalance caused by prolonged sweating are typically its causes.

Heat exhaustion, heat syncope (fainting), and heat stroke are among the most serious types of heat stress disorders. Heat syncope usually happens because of a pooling of blood in the lower extremities and dilated vessels of the skin, leading to low blood pressure and sudden unconsciousness. Heat exhaustion can oc-cur on its own or as a prelude to fainting. Common symptoms are similar to heat fatigue but more severe, including diarrhea, nausea, and disorientation. Heat stroke is the most serious heat stress disorder and can be life-threatening. It occurs when the body’s systems of temperature regulation fail and body temperatures rise to critical levels. It can be marked by an absence of sweating, as well as confusion, fainting, and/or convul-sions. Hospitalization is a must for anyone who suffers a heat stroke.

Certain types of people are more prone to heat stress than others, including older people, smaller people, and people who exceed standard weight by 15 percent or more. Interestingly, men tend to do better than women in hot, dry heat, but women fare better in extreme humidity. In all cases, fitness is a benefit,

Reducing Heat Stress with HVLS FansHigh-volume, low-speed fans help cool off employees and improve efficiency.BY DAN ANDERSON R

ITE-HITE FAN

S

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12 www.ohsonline.com

while drug and alcohol abuse, high blood pressure, and chronic heart problems or other chronic diseases are a disadvantage. The pace of work is a factor across all cat-egories, as well, because the more energy any worker expends, the more at risk he or she is of a heat stress-related episode.

Factors Affecting Heat Stress ControlWarehouses and loading docks are inher-ently dangerous and fast-paced environ-ments, so it is particularly important for distribution center managers to be aware of potential heat stress disorders. Unfortu-

nately, most loading docks are not air-con-ditioned, while most dock staging areas are expansive spaces with tall ceilings, making them hard to cool even if they are air-con-ditioned. The frequent opening and closing of doors is another added challenge to heat moderation.

Long-term weather patterns and the growth of online retailing are two other factors that exacerbate this problem. Most U.S. states have seen have seen their an-nual average summer temperatures rise in the last decade, and scientists expect the uptick to continue. The ongoing expansion

of online retailing and overnight shipping is another relevant trend because it forces companies such as Amazon to push fulfill-ment employees to work faster than ever. The fast pace of online retailer operations has had a ripple effect on consumer expec-tations and shipping norms throughout the logistics industry, causing even non e-tail operations to increase the speed of their operation. Though several of the largest online retailers have faced employee push-back, complaints, and high-profile lawsuits in recent years, there is no reason to think this trend will change.

Higher Temperatures = More Mistakes, Legal ExposureAn uncomfortably hot warehouse and loading dock not only lowers the morale of employees, it can make them less efficient. It’s not hard to understand why. As more blood pumps to the skin in an attempt to cool off the body, less blood is available for vital organs including the brain, leading to mental errors. In fact, a study done by NASA concluded that when in-plant tem-peratures rise to 85 degrees F, worker out-put drops by 18 percent and errors increase by 40 percent.

While OSHA does not have specific regulations for indoor workplace tem-peratures, the agency recommends a tem-perature range between 68 and 76 degrees. Twenty-five states have adopted OSHA-ap-proved plans for compliance with and en-forcement of heat illness prevention plans. Failure to comply with these regulations can result in a lawsuit if workers become injured as a result of heat illness.

Addressing Heat StrokeThere are a number of ways facilities man-agers can address heat stroke issues. From a physical standpoint, water breaks should be encouraged, along with consumption of electrolyte-enhanced sports drinks. Work-ers moving from a cooler part of the plant or coming back to work after time off should be given time to acclimate to their condi-tions with unit-output requirements gradu-ally worked back up. Obviously, workers should be moved to a cooler area as soon as they show symptoms of heat stress, and anyone suffering a heat stroke should be taken to the nearest hospital immediately.

From an infrastructure standpoint, a number of facility upgrades have an imme-

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diate impact, such as using fabric curtain walls to create new, specific air-conditioned areas within a facility without having to cool the entire place. Curtain walls also can be used to enclose heat-generating produc-tion equipment. Insulated curtain walls provide up to 40 degrees of temperature separation and can be installed in custom configurations and moved when build-ing needs, or seasons, change. High-speed doors, which can operate at up to 100 inch-es per second, also will help to keep cooled air in and warm air out. Some even snap back onto their tracks after forklift impact, decreasing energy-wasting downtime due to repair or replacement.

How HVLS Fans Help to Control HeatWhile adding air-conditioning to a distri-bution center is the best-case scenario, it isn’t always practical due to cost consider-ations and building configurations. With or without air-conditioning, though, most heat stress-prone warehouses can benefit immensely from high-volume, low-speed (HVLS) fans.

Although smaller, floor-mounted fans can be helpful in a small area, their high wind speed can cause problems and their noisy operating level introduces another other stress-inducing factor. They also use a relatively high amount of electricity. HVLS fans, on the other hand, use relatively little energy and provide a gentle, quiet breeze that is very comforting to workers. Accord-ing to the U.S. Department of Health and Human Services paper “Workers in Hot Environments,” a 2-3 mph air speed creates a cooling sensation of 7-11 degrees F. Air moving faster than 5 mph can be disrup-tive and provides little, if any, added cool-ing benefit.

The advantage of HVLS fans is their ability to move large volumes of air and cre-ate a steady, light breeze. When the breeze reaches people during the warm months, it creates an evaporative cooling effect and re-duces the effective temperature by 10-12 de-grees F. To put this in perspective, the effec-tive temperature of an 84-degree warehouse environment can be dropped to 73 degrees by adding a fan moving air at 3 mph. This 11-degree cooling sensation can make workers up to 35 percent more productive.

Technically advanced HVLS fans can move large volumes of air over an area up to 22,000 square feet. A single HVLS fan

can replace as many as 10 to 20 floor fans, reducing clutter on the ground and lower-ing the chances of an accident. By mixing air, HVLS fans also help air-conditioning systems work more efficiently, allowing them to be operated at a lower set point. The breeze from an HVLS fan typically al-lows up to a 5 degree F increase in the AC system’s thermostat setting with no change in employee comfort.

Considerations for HVLS Set-upThere are a number of factors to consider when deciding how and when to use HVLS

fans. They include obstructions such as pal-let racks, machinery and product staging, personnel work areas, and overall building layout, to name a few. Larger-diameter fans (up to 24 feet in diameter) will move air fur-ther down rack aisles and over obstructions. Smaller-diameter fans (8-, 10-, and 12-foot fans) can be most effective in specific work areas or where installation space is limited. In recent years, floor-mounted HVLS fans also have become available for use in build-ings where overhead obstructions preclude the use of the traditional ceiling-mounted HVLS fans.

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Fan suppliers can help configure an ar-ray of fans, determining the number, size, and locations that provide the maximum benefit for the investment. They also can offer turnkey installation where on-site re-sources are not available. While the basic concept is similar across all HVLS fan man-ufacturers, fan design and performance are key factors to consider. There are significant differences between manufacturers, includ-ing the shape and number of blades, blade tilt, hub construction, blade-to-hub con-nection, and safety features. The perfor-mance of different designs will vary in the

uniformity of air movement directly below the fan, as well as the height and reach of air movement outward from the fan’s diameter.

Other important considerations in-clude ease of installation, fan controls, local representative support, trial program avail-ability, and warranties.

The use of HVLS fans has gained in-creased attention as a practical and afford-able solution to improving air movement, reducing heat stress, and creating overall better environmental control. These types of fans are now recognized as a valuable supplement to help facility designers and

engineers control energy costs and improve employee comfort and productivity. Capi-talizing on the advantages of HVLS fans re-quires careful analysis of each application, as well as each HVLS fan design.

Creating a more comfortable, healthier workplace clearly signals that a company’s management is willing to invest in employ-ees and is serious about their safety—as well as the accuracy of the shipments it sends to its customers. All can have a direct and significant impact on the organization’s bottom line.

Case Study: HVLS Fans in ActionIndiana and Illinois are infamous for their scorching summer temperatures, and the summer of 2011 was one of the hottest ever. However, for workers at one Illinois-based OEM automobile parts manufacturer, the record-setting heat was a stark contrast to noticeably cooler temperatures inside the plant, thanks to the arrival of three HVLS fans. Designed to move and mix air in large spaces, the fan installation brought down plant temperatures by roughly 6 degrees while allowing the plant’s air conditioners to run at decreased capacity. In addition to enjoying a cooler main workspace, the employees of the facility also noticed the air-conditioning in areas of the plant it had never reached before.

According to the plant’s maintenance manager, the newly comfortable conditions even motivated workers to be more energy conscious. “Many of our guys had never felt cooler air around the front shipping docks,” he said. “Now that they have, they are really careful about shutting doors to keep that cool air in.”

The fans at the plant were installed on a Saturday when the plant was closed, a mere three days after they were ordered. Their arrival received so much praise from employees that a nearby “sister” plant in In-diana subsequently installed three 24-foot diameter fans of its own.

Dan Anderson, Rite-Hite Fans’ product manager, has more than 25 years of experi-ence in warehouse safety. He started work-ing for Rite-Hite in 1995 and became prod-uct manager for Rite-Hite Fans in 2006. Anderson has other industry experience from ADS and Todd Equipment. He has a degree in business with a focus in business management.


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HEAT STRESS


T he ability to regulate body temperature in extreme temperatures can be challenging under even the most normal circumstances. But in situations requiring flame-resistant

(FR) garments, the natural insulation properties of FR clothing can create additional obstacles. When developing an FR garment program for hot or cold environments, special considerations must be taken to ensure workers remain as safe and comfortable as possible on the job.

Heat stress—which is commonly experienced by workers exposed to extreme heat—can result in heat stroke, heat exhaustion, heat cramps, or heat rashes.1 In fact, the U.S. Bureau of Labor Statistics (BLS) re-ports that “exposure to environmental heat” caused 177 deaths and 13,580 cases of days away from work in the private sector workforce2 from 2003 to 2008.

While heat stress can be attributed to external fac-tors, such as temperature, workplace uniforms and other factors can contribute to the impact of these sources of heat. A worker may not consciously realize the effect of his or her garments on core body temper-ature. Just as choosing the right clothing makes a dif-ference when exercising, it is also a key factor in regu-lating temperature while working in a physical role. This is why it is essential to consider how the company uniform can affect a worker’s thermal comfort when evaluating and specifying flame-resistant garments.

Total heat loss (THL) is a method used to measure the maximum workload or metabolic activity rate a person can sustain while maintaining thermal com-fort in a garment (personal protective equipment). This measure is part of the certification for garments in the firefighting industry.

THL measures the amount of conductive (dry) and evaporative (wet) heat loss that occurs through the fabric of a PPE garment.3 By placing fabric sam-ples on specially designed plates that simulate hot, sweaty skin under controlled lab conditions, the abil-ity of the fabric to transfer heat can be precisely mea-sured. In hot conditions, a fabric that holds less heat is more desirable.

In hot environments, choosing garments with high THL performance is important for employees as well as management. Employees in roles with physi-cal activity may face discomfort, physiological strain, decreased productivity and performance, and poten-tially increased accident rates on the job.4 A uniform with better performance can have some level of im-pact on these challenges.

Considerations for FR Garments in Hot EnvironmentsWhen specifying PPE clothing, incorporating THL performance should be taken into consideration. THL is a measurement that combines the perfor-mance of several fabric properties, including air per-meability and moisture wicking. Certain PPE gar-ments have a low air permeability rate, which limits evaporation and normal heat dissipation through airflow. This, in turn, increases body temperature and sweating.5 Air permeability is a key contributing factor to good THL performance.

An FR garment must not only offer breathability, but also moisture wicking. Cotton shirts are soft and comfortable in moderate temperatures, but when exposed to increased levels of sweat, they become saturated. Retaining moisture reduces a fabric’s THL rating because it decreases the evaporative cooling capability. The same cotton that feels comfortable around the house becomes a liability in an extremely hot work environment. The natural reaction to facing a hot environment in heavy clothing is to make modi-fications to the prescribed equipment—affecting its intended purpose. Rolling up the sleeves and leaving a coverall unzipped are common modifications that undo FR safety protocols and in some cases may add the risk of entanglements.

Considerations for FR Garments in Cold EnvironmentsJust as garments affect body temperature in hot condi-tions, it is also important to consider how they affect the body in cooler temperatures. When working in extremely cold environments, safety and comfort are driven by different attributes.

Matching the right fabric technology and the ap-propriate insulation level to the daily tasks of a worker is critical in cooler environments. Too little insulation exposes workers to the cold, while too much insula-tion will cause overheating and accompanying sweat. This moisture is one of the biggest challenges for com-fort in a winter clothing system. Just as in hot con-ditions, removal via evaporation must be managed closely because it creates cooling. A careful balance of insulation, moisture transportation, and evaporation must be achieved.

Maintaining Body Temperature in Cold Environments: LayeringFactors to consider when specifying FR garments

Maintaining Body Temperature in Extreme Conditions with FR GarmentsBY CORTLANDT MINNICH

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HEAT STRESS

in cooler locations include the tempera-ture and humidity of the environment, the level of physical activity, wind, break cycles, and the worker’s size, weight, and physical condition. It is also important to consider the difference between a body in its resting state versus an active state. In colder temperatures, a body will burn calories not only to do work, but also to regulate body temperature. The body has a network of sensors that keep close track of temperature, so any area of the body that overheats get the signal to cool by sweat-ing. Workers may need to adjust their uniform based on the activity they are performing at the time.

Layers are recommended for outdoor workers because they can be removed or added to meet very precise conditions. A session of hard work can be done in two layers to minimize overheating and sweat-ing, and then a cool-down period can be performed with an additional insulation layer added on top.

Special attention must be paid in oil and gas, electrical, and manufacturing indus-tries to FR protection and compliance with

2112 and 70E, especially in winter. Gar-ments that are not FR—especially heavy-weight version—are actually additional fuel. Wearing a non-FR hoodie underneath an FR shirt will add a comfort layer, but the exposed non-FR hood is dangerous and non-compliant with FR standards. Addi-tionally, many non-FR winter base-layers are made from Polypropylene and blends that contain Polyester. Both of these mate-rials have low melting points and can lead to tragic injuries if exposed to a thermal incident. Section 130.7 (C) 9 of NFPA 70E states: “Meltable fibers such as acetate, ny-lon, polyester, polypropylene, and spandex shall not be permitted in fabric underlayers (underwear) next to the skin.”

Implications for Safety ManagersFR garments should be assessed not only for their comfort, but also for how well they can contribute to the safety and productiv-ity of the workers who wear them, because workers may require fewer, shorter breaks and time off related to heat stress issues.6

In colder environments, it is essential to offer uniforms with layering in mind to

ensure that workers comply with necessary regulations. Combining non-FR garments with an FR uniform can be very hazardous.

In addition to specifying optimal gar-ments for hot and cold environments, safety managers should take the initiative to educate employees on selecting the right undergarments, if they provide their own.Each garment should be assessed in terms of breathability, moisture-wicking ability, and weight. The more employees can cus-tomize their personal uniform using gar-ment layers, the better the chances they will remain compliant.

Cortlandt Minnich works in Business Devel-opment for the TECGEN® Brand. Visit http://industrial.tecgen.com/ for information.

REFERENCES1. Centers for Disease Control and Prevention

2. Bureau of Labor Statistics

3. Fire Engineering

4. Extreme Physiology & Medicine



Tony BarkerWaldorf College StudentB. A. Organizational Leadershipwith OSH concentration

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HEARING PROTECTION

www.ohsonline.com MARCH 2015 | Occupational Health & Safety 19

E xcessive noise levels are found in many work-places and can cause problems other than just hearing loss. They also can create dangerous situations, such as an inability to hear warn-

ing signals, a decline in one’s ability to communicate with fellow employees, and a decrease in one’s ability to concentrate. Excessive noise has even been found to cause stomach problems and high blood pressure.

In some cases, excessive noise can be controlled through engineering or administrative controls. How-ever, engineering and administrative controls are not always possible, and therefore hearing protection de-vices may be needed to properly protect employees.

There are many occupational noise sources. They include, but are not limited to, manufacturing equip-ment, power generators, use of motor vehicles or heavy

equipment, aircraft noise, hammering, jackhammer-ing, sawing, drilling, emergency vehicle sirens, and construction sites. All of these noises can easily exceed safe levels and, in time, result in hearing loss.

Hearing loss usually occurs over an extended period of time and may not be noticed by an em-ployee. Humans do not become acclimated to noise. Although some losses can be temporary, once a loss become permanent, you will not recover any hearing.

Control StrategiesDetermining whether or not engineering controls, administrative controls, or hearing protection devices are necessary is a three-step process:

■ Recognizing that a noise problem may exist.■ Evaluating the extent of the problem.

Addressing Noise in the WorkplaceOne of the most important things for a successful program is to get employees to feel like they are being included in the decision process of developing the program.BY LARRY BIRKNER

MO

LDEX-M

ETRIC

, INC

.

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HEARING PROTECTION

■ Controlling the problem.Recognizing the problem can be as simple as being unable to

properly communicate with another worker a few feet away. How-ever, it can also be very complicated. For instance, a work site might have many different machines contributing to the overall excess of noise; there may be acoustic cues associated with determining whether a machine is operating properly or even sounds from some machines that appear to be the most dangerous source, but in fact that may not be the case.

Properly evaluating the problem requires a qualified profession-al to perform the measurements and analyze the results. For gen-eral industry, the federal OSHA standard on Occupational Noise Exposure is 29 CFR 1910.95. It sets the permissible exposure limit (PEL) at 90 dBA as an eight-hour time weighted average (TWA). When levels exceed 85 dBA as an eight-hour TWA, 29 CFR 1910.95 requires the employer to institute a hearing conservation program. This entails annual audiograms, training, providing a choice of hearing protectors to the employees, and various other elements.

One should refer to this regulation for details. Employers also should look to see whether their state has its own program. State

regulations will be at least as stringent as the federal regulation. They can be stricter and possibly have additional requirements.

Controlling the problem can be accomplished using admin-istrative controls, engineering controls, or hearing protection de-vices. Generally accepted practice dictates that administrative and engineering controls be exhausted before hearing protection is used. However, if neither administrative controls nor engineering controls can reduce the noise level below the limit, hearing protec-tors must be worn. There are many situations when the only practi-cal means of noise control is through the use of personal protective equipment (PPE).

When hearing protection is required, it is sometimes difficult to ensure that employees are using the device properly. This is often due to a lack of training, a misuse of the protection device, or other program compliance issues. A good hearing conservation program can avoid many of these problems.

Until employees understand the hazards associated with noise and become acclimated to the use of the hearing protection de-vices, wearing hearing protectors might seem like a nuisance. Use of hearing protectors can preserve an employee’s hearing when noise cannot be engineered out of the workplace. The most com-mon complaints by employees are that the protectors are uncom-fortable, hot, cause headaches or earaches, and create a situation where the employee cannot hear warning signals or fellow workers. All of these objections can and must be overcome to protect the

Properly evaluating the problem requires a qualified professional to perform the measurements and analyze the results.

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HEARING PROTECTION

employee’s hearing. These objections can be overcome by imple-menting a program that chooses the appropriate protector for the situation, provides training for the employee, and requires periodic compliance checks.

If compliance is lacking, the employer should investigate the cause by asking employees why they are not wearing the assigned hearing protection. The employees may not fully understand the need for hearing protection, or the situation may simply require that another hearing protector with similar attenuating character-istics be provided. If the employees do not want to wear the hearing protector, then disciplinary action might be appropriate, but only as a last resort.

Hearing Protector SelectionMany types of hearing protectors are available to meet employee needs in terms of both compliance and user acceptance. For exam-ple, ear plugs have varying NRRs for different situations and come in many different colors and shapes. Selecting an appropriate de-vice that does not overprotect the user can alleviate concerns about not being able to hear warnings and fellow employees. Adequate

training and allowing the employee to get used to the device also can help.

Choosing the right hearing protector requires careful consider-ation. Many work sites are predominated by low frequency noise. Ear muffs can be very helpful in these types of environments. Bands and muffs also can be useful in situations that require the employee to periodically leave a noisy environment, thus causing the employee to remove the device several times throughout the day.

If the employee has to wear a hearing protector for extended periods of time, ear plugs are often preferred. They are comfortable and require little maintenance. Another very important factor is how the hearing protector interacts with other PPE, such as hard hats, eye protection, and welding hoods.

Last but not least, one of the most important things for a suc-cessful program is to get employees to feel like they are being in-cluded in the decision process of developing the program. This must be done with the appropriate training and motivation and also by impressing upon them that once hearing is lost, it does not come back.

Jeffrey Birkner, Ph.D., CIH, is Vice President-Technical Services & Quality Assurance for Moldex-Metric, Inc. a leading manufacturer of hearing and respiratory protection equipment. For more information, visit www.moldex.com.

A n t i - s t a t

|

Distributed exclusively by:

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Many work sites are predominated by low frequency noise. Ear muffs can be very helpful in these types of environments.



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HEAD & FACE PROTECTION


T housands of Americans suffer a traumatic brain injury each year: About 1.7 million did from 2002 to 2006, Merck & Co. Inc.’s Merck Manual reported a few years ago, and CDC

reported 2.5 million traumatic brain injuries occurred nationwide, either as an isolated injury or along with other injuries, in 2010 alone. Most TBIs are not work-place injuries, but between 4 and 7 percent of all traumatic head and brain injuries are occupational injuries, the Washington State Department of Labor & Industries has reported.

An average of 53,014 deaths per year among U.S. residents during 1997-2007 were associated with TBIs, Dr. Victor G. Coronado of the Division of In-jury Response in CDC’s National Center for Injury Prevention and Control and colleagues reported1 in May 2011 in MMWR. They found that although the death rate declined by 8.2 percent during the period, TBIs remained a significant U.S. public health prob-lem, with about 580,000 people with TBI diagnoses dying during that decade.

Key Mandatory and Consensus StandardsOSHA’s 29 CFR 1910 Subpart I, Personal Protective Equipment, contains sections specific to eye and face protection (1910.133) and head protection (1910.135). The first of these requires employers to:

■ Ensure that each affected employee wears eye or face protection PPE when he or she is exposed to eye

or face hazards from flying particles, molten metal, liq-uid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.

■ Ensure that each affected employee uses eye protection that provides side protection when there is a hazard from flying objects.

■ Ensure that each affected employee who wears prescription lenses while engaged in operations that involve eye hazards wears eye protection that incor-porates the prescription in its design or wears eye protection that can be worn over the prescription lenses without disturbing the proper position of the prescription lenses or the protective lenses.

■ Ensure that each affected employee uses equip-ment with filter lenses that have a shade number ap-propriate for the work being performed for protection from injurious light radiation.

It requires that eye and face PPE comply with ANSI/ISEA Z87.1-2003, American National Standard Practice for Occupational and Educational Eye and Face Protection, or the 1989 edition of that consen-sus standard, which are incorporated by reference. In fact, the current edition is ANSI/ISEA Z87.1-2010, ap-proved by ANSI in in April 2010. A significant change in the 2010 edition was its focus on the hazard—impact from flying fragments or particles, chemical or molten metal splash, hot sparks, dust, optical radiation, fine dust particles—rather than the type of protector.

ISEA announced Jan. 27, 2015, that it is accept-ing comments from stakeholders and the public on a proposed update to Z87.1-2010. According to ISEA’s release, specific proposals include testing of protec-tors commonly referred to as readers and magnifiers; testing changes for prescription safety lenses; angle of dependence criteria for welding devices; updated product markings; and updated use and selection guidance. The deadline for submitting comments is March 9, 2015. For a copy of the draft standard and a comment form, or for more information, contact Cristine Fargo, ISEA’s director of member and techni-cal services, at [email protected].

The head protection section requires employers to:■ Ensure that each affected employee wears a pro-

tective helmet when working in areas where there is a potential for injury to the head from falling objects.

■ Ensure that a protective helmet designed to reduce electrical shock hazard is worn by each such affected employee when near exposed electrical con-ductors that could contact the head.

■ Ensure that the head protection PPE being used complies with ANSI/ASSE Z89.1-2009, American Na-tional Standard for Industrial Head Protection, or the

Preventing Occupational and Non-Occupational Head InjuriesPreventing occupational head injuries starts by following the hierarchy of controls.BY JERRY LAWS

ZELFIT/SH

UTTER

STO

CK

.CO

M

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2003 or 1997 editions of that consensus standard, which, again, are incorporated by reference. This standard establishes require-ments for industrial head protection relat-ing to impact protection, penetration pro-tection, and electrical insulation protection.

Head Injury PreventionPreventing occupational head injuries starts by following the hierarchy of con-trols. “There is no one hierarchy of con-trols that all health and safety profession-als agree upon, but most are similar to the hierarchy found in the American National Standards Institute’s (ANSI) and American Industrial Hygiene Association’s ANSI/AIHA Z10-2012 Occupational Health and Safety Management Systems standard, which has six levels, starting with elimina-tion, substitution, and engineering controls in the higher levels and ending with warn-ing systems, administrative controls, and personal protective equipment (PPE) in the lower levels,” Matthew O’Connell, Ph.D., co-founder and executive vice president of Select International, Inc., and Ron Gantt, CSP, ARM, vice president of operations for Safety Compliance Management, pointed out in their article “Moving Selection to the Top of the Hierarchy,” published in our July 2013 issue.

This article is worth revisiting: They wrote that Select International had con-ducted several studies that looked at ap-plying an assessment of safety risk in the hiring process of a number of industries. What these found is that fewer than 10 per-cent of employees accounted for a dispro-portionate percentage of work-related in-juries. “As part of a systematic approach to safety management and risk reduction, it’s clear that the identification and removal by selection of high-risk individuals in a sci-entifically valid and legally defensible way before they step onto the work site might be one of the most cost-effective solutions available,” O’Connell and Gantt wrote.

Select International reviewed research in this area and came up with these four primary risk factors, as described in their article:

(1) Stays in Control. This relates to personal and emotional control. This is an important factor that typically only comes into play under stressful situations. In other words, some people may perform well on the other three factors under normal situ-

ations, but when an emergency happens, they have difficulty maintaining compo-sure and are likely to do something that puts them or others into harm’s way.

(2) Aware of Surroundings. The sec-ond factor focuses on the individual’s awareness of his or her environment. Inci-dents often occur not because of overt ac-tions such as taking shortcuts, not wearing proper protective equipment, or behaving in an unsafe manner, but because the in-dividual was not sufficiently aware of the dangers around him.

(3) Follows Rules. This factor focuses on diligence, following rules, working hard, and taking responsibility. Simply put, some individuals are more rule-bound than oth-ers. Those who are not are more likely to increase their level of exposure by not fol-lowing safety rules that they feel do not ap-ply to them or are not important.

(4) Exhibits Caution. The fourth and final factor focuses on the individual’s pro-clivity toward risk-taking behavior, as well as his impulsivity. Impulsive individuals tend to be more volatile and unpredictable. Individuals high in risk taking are often described as “thrill seeking” or “sensation seeking.” Combining volatility and thrill seeking greatly increases the likelihood of increased exposure.

If the approaches in the higher levels of the hierarchy cannot fully eliminate the hazard, complying with the standards above is the answer. To prevent non-oc-cupational head injuries, CDC and others recommend wearing a seat belt whenever you drive or ride in a motor vehicle; never driving while under the influence of alco-hol or drugs; wearing a helmet when play-ing contact sports, skiing or snowboarding, or riding a bicycle or motorcycle; and tak-ing several steps to prevent falls at home, such as using non-slip mats in bathtubs and showers, installing grab bars, and removing tripping hazards.

Jerry Laws is the editor of Occupational Health & Safety.

REFERENCES1. http://www.cdc.gov/mmwr/preview/mmwrht-ml/ss6005a1.htm?s_cid=ss6005a1_w

2. http://www.merckmanuals.com/home/injuries_and_poisoning/head_injuries/over-view_of_head_injuries.html

3. http://www.bls.gov/iif/

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HAZMAT

F rom health care workers fighting Ebola to the main characters in “Breaking Bad,” the typi-cal yellow hazmat suit has become a familiar media image portraying dangerous work envi-

ronments. Primitive versions of hazmat suits date back to the 14th century as protection against the bubonic plague. Unfortunately, those suits may have spread more disease than protected people in those days.

The Ebola crisis has drawn attention to not only the construction of hazmat protection, but also the proper ways to put it on and take it off, decontami-nate it, and dispose of it properly—whether it is for Ebola or any other hazardous event. As a result, many manufacturers of hazmat protective gear have report-ed an increase in sales to consumers and businesses alike. According to a report on CNBC, Amazon ex-perienced a significant increase in full-body suits and masks during this period.

The U.S. Department of Homeland Security de-fines a hazmat suit as “an overall garment worn to pro-tect people from hazardous materials or substances, including chemicals, biological agents, or radioactive materials.” Hazmat protection is rated from Level A to Level D (see the sidebar and chart). At the highest Level A, the worker is essentially sealed in a gas-tight, vapor-tight, and splash-resistant suit with a positive-pressure, self-contained breathing apparatus (SCBA) and chemical-resistant inner and outer gloves.

But there is more to hazardous material protection than suits. All levels of protection call for chemical-

resistant footwear, preferably boots with a safety toe and puncture-resistant midsole. However, protective boots and shoes are sometimes an overlooked compo-nent for worker safety. Improper hazmat footwear can allow toxic materials to penetrate, puncture, or cause a worker to slip and possibly damage his suit. Just as precautions need to be taken to prevent the cutting or puncturing of sealed hazmat suits, the same applies to hazmat footwear to maintain a protective barrier. The wrong type of footwear in a hazardous setting can prevent proper decontamination and carry dangerous materials from one environment to another.

The National Fire Protection Association Tech-nical Committee on Hazardous Materials Protective Clothing and Equipment develops standards to test and certify emergency protective apparel. The NFPA 1991 Standard on Vapor-Protective Ensembles for Haz-ardous Materials Emergencies (2005 edition) requires testing footwear resistance to 21 different chemical classes. It also includes requirements for puncture and tear resistance, temperature performance, slip resis-tance, abrasion resistance, and flex fatigue of footwear materials. In addition, it covers optional protection for chemical and biological agents, which must be clearly indicated on product labels.

NFPA 1994 Standard on Protective Ensembles for First Responders to CBRN Terrorism Incidents ad-dresses chemical and biological terrorism incidents at three different threat levels. To learn more about these standards, visit the NFPA web site at www.NFPA.org.

With greater recognition of terrorist threats using chemical warfare or biological weapons, NFPA 1991 provides permeation resistance testing for primary suit, gloves, and footwear materials against chemical warfare

Hazmat Protection from Head to ToeTrue hazmat gear must provide protection to the entire body.BY JIM TOWEY

FOUR LEVELS OF HAZMAT PROTECTIONLevel A is the highest level of protection to protect the skin, eyes, and respiratory system in the most dangerous situations. If there is a possible threat to life and health from incidents such as cleanup from a chemical spill, Level A protection is required. Level A hazmat gear protects against vapors, gases, mists, and splashes, so it must be gas-tight, vapor-tight, and splash resistant to offer protection against dangerous chemicals or other materials. Level A hazmat suits require a gas-tight suit, positive-pressure SCBA, chemical-resistant inner and outer gloves, and chemical-resistant boots with steel toe and midsole.

Level B is the second-highest level of protection. It provides protection against hazardous chemical splashes but does not provide protection against vapor or gases. Level B protection requires SCBA or positive-pressure supplied air respirator with an escape SCBA. In addition, it includes chemical-resistant clothing, gloves, and boots with a steel toe and midsole.

Level C is for protection against known hazardous chemicals and airborne substances, but not chemical emergency situations or potentially oxygen-deficient environments. Level C requires similar garments to Level B. Instead of an SCBA, an air-purifying respirator is sufficient. Level C equipment also includes a hard hat and disposable, chemical-resistant outer boots.

Level D offers the lowest level or protection, and it is typically worn when there is no danger to workers from chemical exposure. It includes a pair of coveralls and chemical-resistant footwear with steel toe shoes and midsole.

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HAZMAT

agents Sarin (GB) and Sulfur Mustard (HD).

What to Look For in Proper Hazmat Footwear ProtectionAlthough comfort is not an NFPA-regu-lated requirement, it is essential for safety. Hazmat suits are often uncomfortable, especially considering that the wearer is sealed in a suit. Hazmat workers typically are on their feet for long periods of time. If their footwear is not comfortable, they are

more likely to wear a boot that is comfort-able but not designed to maintain a seal of protection. Plus, uncomfortable footwear hinders productivity and can cause fatigue.

Chemical resistance is essential for hazmat. To protect against liquid hazardous chemicals, boots must be made of neoprene, PVC, butyl rubber, or other chemical-re-sistant material. It is also important for footwear to have a smooth surface for easy cleaning and decontamination.

When Should Chemical-Resistant Hazmat Footwear Be Replaced?Hazmat footwear should be inspected regularly and replaced if it shows signs of wear that may weaken its ability to provide protection:

■ Discoloring, swelling, breaks, cracks, holes, or other surface degrada-tions such as tears should be observed.

■ Worn soles or treads can reduce slip resistance (traction).

■ Metal or other items embedded in the soles should be observed for potential breakthrough and could create an electrical hazard.

The iconic yellow suit is only one com-ponent in providing complete safety for emergency responders, health care work-ers, and military personnel. True hazmat gear must provide protection from head to toe.

Jim Towey is Vice President of Marketing at Tingley Rubber, which has manufactured protective footwear and clothing to protect generations of workers since 1896.

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Four Levels of Hazmat ProtectionHazmat Equipment Needed Level A Level B Level C Level D

Hazmat suit - gas-tight, positive pressure

SCBA

Respirator - air-purifying

Hard hat

Gloves - chemical-resistant, inner & outer

Footwear - chemical-resistant w/steel shoes & shank

Outer boot - disposable & chemical-resistant

Clothing – chemical-resistant

Coveralls

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M ost of our standards and test meth-ods for flash fire and barrier/chemical protection deal with these two haz-ards discretely, as if they occurred in a

vacuum. It is little wonder, then, that end users and many manufacturers tend to evaluate garment per-formance against these hazards in the same manner. Unfortunately, designing garments for use in multi-hazard environments, especially where flash fire or flame is concerned, is not quite so simple. An event where both hazards, flash fire and chemicals, are en-countered simultaneously can have a drastically dif-ferent result for the end user than if the hazards were encountered individually. The use of disposable gar-ments over thermally protective garments (TPGs) is a classic example.

As the use of thermally protective garments in-creases around the world, so too does the need for disposable protective garments to be worn over them. Also increasing is the selection of products that claim to be suitable for this application and, subsequently, confusion over which disposable garment to choose.

These garments are commonly referred to as Disposable Secondary FR Garments because they are intended to provide barrier protection to the wearer without compromising the protection afforded them by the TPGs worn underneath. Once again, these garments are intended to provide the complete bar-rier protection the wearer requires, but they do not provide thermal protection unless worn over TPGs. While conceptually this is relatively straightforward and understood by most, applying it to the decision-making process is not so simple because of our pre-dilection for considering hazards individually rather than collectively.

There are numerous test methods and standards on flame resistance and thermal protection, but none of them is written specifically for disposable second-ary FR garments. Some certainly have application, but these standards and test methods focus on TPGs or on characterizing the flammability of a fabric. Further complicating this issue are some manufacturers who

cite a standard that was changed in 1996 and is no lon-ger applicable to protective clothing. As a result, many end users and even some manufacturers get “wrapped around the axel” over the FR testing of disposable secondary FR garments to the exclusion of all other testing. This is unfortunate and unnecessary if one takes the time to consider the disposable secondary garment’s function in the ensemble.

Disposable secondary FR garments differ from most disposable protective garments in that they are multi-hazard garments. As such, evaluation of these garments based on performance against any single hazard can be terribly misleading. Garments intend-ed to be worn as a part of a more complex ensemble should be tested as they will be worn and challenged with the hazards as they may be encountered in the workplace.

As an example of how testing against individual hazards can be misleading, consider a spunbond meltblown spunbond (SMS) polypropylene fabric or a hydroentangled (spunlaced) woodpulp/polyester disposable fabric that is treated with flame-retardant chemistry and sewn into garments. Either of these garments may achieve the flame resistance necessary to meet a simple FR standard or test method such as ASTM D6413. Both of these products are also capable of performing reasonably well in terms of dry particle barrier protection, but what about liquid barrier?

If these two garments do not have some chemical treatment to enhance their repellency, the wearer may unwittingly be at risk. SMS can provide adequate bar-rier to water and some light sprays of liquid chemicals, as evidenced by its ability to attain CE Type 6 classi-fication. But what happens when polypropylene SMS is exposed to a common workplace liquid such as oil, grease, hydraulic fluid, or solvent? The answer is that it absorbs these liquids. This characteristic of polypro-pylene is why it is commonly used in oil skimming booms to contain oil spills. It absorbs oil and repels water. The result would be the outer garment of the wearer’s ensemble becoming a reservoir for flam-mable liquid, holding that fuel in close proximity to the TPG worn underneath it. In case of saturation, the SMS garment may even act as a “wick,” transferring the liquid fuel into the structure of the TPG under-neath it, compromising the thermal protection other-wise provided by the TPG.

The same is true for garments made of hydroen-tangled woodpulp/polyester fabric. The woodpulp

Disposable Secondary FR Garments: What Really Matters When Selecting a GarmentClearly, the addition of a flash fire or flame hazard to a scenario involving dry or liquid chemicals can significantly complicate protection.BY CHARLES D. ROBERSON

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component of these fabrics is typically 55 percent by weight. Why is this important? Well, the woodpulp in the fabric, unless treated for repellency, will act just like a paper towel, absorbing most liquids--espe-cially oil, hydraulic fluid, or solvents--that may contact it. In such cases the woodpulp, just like the polypropylene SMS above, will become a fuel reservoir and a conduit for the transfer of fuel into the structure of the TPG underneath, with the same resultant loss of protection to the wearer.

Establishing a Protection HierarchyClearly, the addition of a flash fire or flame hazard to a scenario involving dry or liquid chemicals can significantly complicate pro-tection. In the case above, the inclusion of flash fire or flame along with exposure to something as common and innocuous as oil or hydraulic fluid highlights the hazard posed by the flammability of these liquids. This hypothesis is supported in modified (vertical orientation) TPP testing using a copper calorimeter and flame impinge-ment on combined TPG and disposable

secondary FR garment samples that have been exposed to as little as 10 ml of oil. (See photos 2 & 3.) The test resulted in heat transfer through the test samples that far exceeded the clean samples of the TPG by itself. This result shows that the combina-tion of disposable secondary FR garments that lack additional barrier protection and

flammable liquids may act to compromise the thermal protection of the TPG it is worn over.

Given that current test methods and standards address hazards individually, how then should disposable secondary FR garments be evaluated? The process begins with a detailed job safety analysis that in-

LAKELAN

D IN

DU

STR

IES

Photo 1. ISO 6530 test equipment with multiple layers of fabric clamped to “gutter.”

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cludes consideration for multiple-hazard environments and the impact that each of the hazards may have on other elements of the environment, including those that may not necessarily be deemed a hazard other-wise. A significant component of this anal-ysis should be the establishment of a pro-tection hierarchy for the hazards present.

In the case of disposable secondary FR garments, we have previously established that these garments are intended to provide the complete barrier protection needed by the wearer but not, by themselves, provide the wearer with adequate thermal protec-tion. This statement establishes the hier-archy for the hazards for which these gar-ments offer protection. You are wearing disposable secondary FR garments for their barrier properties, not their FR capability. For thermal protection, you have a TPG on underneath the disposable. Even the name “disposable secondary FR garment” alludes to the relative importance of barrier and FR protection. In short, why are you wearing a disposable secondary FR garment over TPGs? The answer is because the TPG fails to provide protection against some hazard

Photos 2, 3. Modified TPP testing of samples from ISO 6530--flame application on left and after flame on right. The copper calorimeter is located ¼ inch behind the fabric swatches (spaced).

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that the disposable garment does. Therefore, barrier is the primary function of the disposable, provided it does not prevent or com-promise the protection offered by the TPG. Focusing on the flame resistance of disposable secondary FR garments in the selection process ignores the primary reason for wearing the garment.

To effectively evaluate the performance of disposable second-ary FR garments, end users first need to determine whether the garment provides the barrier or other protection that is not pro-vided by the TPG and secondly that the disposable secondary FR garment will not compromise the protection offered by the TPG if subjected to a multi-hazard event. To accomplish this, testing of these garments should hinge on testing the ensemble, both the dis-posable secondary FR garment and the TPG, for repellency using a flammable liquid such as oil or hydraulic fluid and then subjecting the exposed samples to flammability testing that will quantify heat transfer through the ensemble to the wearer. This two-step pro-cess will characterize the performance of the each layer, as well as the total ensemble, in terms of barrier to commonly encountered flammable liquids and provide detailed information on the thermal protection offered by the ensemble when exposed to both hazards simultaneously.

ISO 6530, commonly referred to as “The Gutter Test,” allows for the evaluation of multi-layer garments or ensembles against expo-sure to 10 ml of liquid over a 10-second period of time while the fabric sample is positioned at a 45-degree angle. (See photo 1.) This is not unlike exposures that may be encountered in the workplace. Individual ensemble layers can then be weighed to determine the

effectiveness of the barrier offered by the ensemble.Once barrier has been determined, the same barrier test sam-

ples should be tested for thermal protective capability. For this, we recommend a modified TPP test using a copper calorimeter to measure the heat transfer through the entire ensemble. By com-paring the total calories of heat energy that passes through the en-semble samples, a good relative comparison of the effectiveness of the ensemble can be made. By testing a clean sample of the TPG using the same modified TPP test, a relative comparison can be made to the ensemble samples that were exposed to liquids and a determination can be made as to whether or not the disposable sec-ondary FR garment, combined with a flammable liquid, will com-promise the protection that the TPG alone is capable of offering. As an added benefit, this test protocol also can be used to evaluate barrier and effect on thermal performance for specific chemicals, for specific TPGs, or both.

Selecting the appropriate disposable for use over thermally pro-tective garments does not have to be difficult, provided that you first consider what the garment must do, consider multiple hazards in conducting your job safety analysis, and ask for data that is rela-tive to how the garment will be used.

Charles D. Roberson is the Vice President of International Sales at Lakeland Industries and represents Lakeland to various standards-writing organizations globally. He has worked with disposable sec-ondary FR fabrics since 1994 and has developed several fabrics with-in this product category. He holds a U.S. patent for that work.

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B ack in the mid-1800s, the news of gold be-ing found brought more than 300,000 gold-seekers to California, and the gold rush boom in the United States served as the

catalyst that propelled denim into the mainstream. Today, gold is doing it again, but this time it’s black gold. The increase in U.S. oil and gas production in during the past decade is proving to be another cata-lyst for denim, and this time it includes flame-resis-tant denim.

Researchers at FracTracker.org estimate that there were more than 1.1 million active oil and gas wells operating in the Unites States in 2014, which is a sig-nificant increase over the approximately 774,000 oil and gas wells reported by the U.S. Energy Information Administration in 2004. This rise in the number of wells has resulted in a more than 50 percent increase in non-supervisory employment in the mining, quar-rying, and oil and gas extraction sectors. Although the recent trend in the price of crude oil has led to some contraction in the industry, the number of workers who need protection from the hazards of flash fire and electric arc flash remains at near-record levels.

Jeans have become a staple in every wardrobe, and the popularity and acceptance of jeans from the work-room to the boardroom have led to the rise in the number of fits and finishes available. According to sev-eral surveys, the average American owns seven pairs of jeans, which means that variety is a very important factor when it comes to jeans—including those worn for protection from flash fire and electric arc flash. But just because someone is wearing FR denim doesn’t mean that he has to look as if he’s just stepped out of a 1970s catalog. Today’s workers are looking for the fits, features, and finishes of retail-ready denim but with proven flame-resistant protection.

NFPA 2112 is the Standard on Flame-Resistant Gar-ments for Protection of Industrial Personnel against Flash Fire. It requires testing of a standard garment by ASTM F1930, a test method used to provide human skin burn injury prediction. NFPA 2112 dictates that FR fabrics must record no more than 50 percent predicted body burn after a 3-second exposure at 2 calories/cm2 or a total thermal energy exposure of 6 calories/cm2. Three garments are tested, and the average predicted percent body burn is reported for the FR fabric. While the data from this test should not be considered a prediction of performance in an actual flash fire incident, it may be used to compare different protective fabrics under a standard set of laboratory test conditions.

Properly constructed and treated denim fabrics used for flame-resistant jeans will typically range from 11.5 to 14.75 ounces per square yard and have

a predicted percent body burn rating of less than 10 percent as determined by ASTM F1930, positioning denim among the most protective and durable of FR fabrics—and therefore making it worthy of consider-ation in your company’s PPE strategy. In addition to the protection offered, the case for selecting jeans to meet your FR clothing needs is also about satisfying the desire for denim and meeting the lifestyle needs of your workforce. Considering all of this, what are some of the things that you can look for to help you select an FR denim program for your workforce that looks, fits, and feels like retail-ready jeans?

Many producers of FR denim can incorporate the fashion looks that are popular today into their flame-resistant lineup, including fabrics that simulate the look of vintage denim fabrics through the use of yarn character created by introducing visible variations of yarn thickness. The spinning techniques used to cre-ate these effects should be tightly controlled to main-tain the quality and integrity of the yarn, as you never want to sacrifice strength and durability for fashion. Premium denim shades, which add richness and fash-ion appeal to protective garments, are another way to provide even more choices to the selection of FR jeans available to your workers.

When it comes to comfort, soft-hand finishes help create a more comfortable, ready-to-wear FR denim jean that doesn’t sacrifice the durability and longevity of the FR protection. Consider flame-resistant denim that is mechanically softened with open width, con-tinuous fabric processing using air under pressure because it results in FR denim that is softer on both sides of the fabric. An added benefit of denim that is mechanically softened is that the softness won’t wash out, which can happen with topical softeners. This type of mechanical softening process will also avoid unsightly “rope marks” that can occur when denim is softened in rope form.

The addition of flex to FR denim not only adds to the comfort of the garment, but also helps create the more up-to-date fits that are popular today, particu-larly among women. Two numbers are important to look for when considering flex denim: the percent of “stretch,” which should be in the low teens, and the percent of recovery, which should be as close to 100 percent as possible, enabling the garment to retain its shape after flexing. Some flex denim fabrics have a bi-lateral flex, which allows them to elongate sideways and diagonally. This eliminates any sagging or bag-ging in the garment and makes reaching and bending easier for workers.

Manufacturers of FR denim are also beginning to incorporate unique fiber blends into their fabrics to en-hance the comfort and wear properties of denim. One recent example is the introduction of cotton blended with Tencel®, which is the strongest cellulosic fiber available. This particular blend enhances the softness and comfort of flame-resistant jeans without a tradeoff

The Evolution of FR DenimBY CRAIG TUTTEROW AND JOHN STRICKLAND

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in durability. And despite the added strength of the fabric compared to 100 percent cotton, denim made with Tencel feels lighter than its true weight, which adds to the overall comfort of the garment.

Laundering FR GarmentsMany producers of FR fabrics guarantee the flame resistance for the expected life of the garment, as long as the recommended laun-dering instructions are followed. If your workers are laundering their FR jeans at home, it is very important that they follow these instructions to ensure they do not compromise the level of protec-tion that’s been built into the fabric:

■ Garments made from FR and non-FR fabrics should be washed separately to prevent cross contamination. Turning FR denim jeans inside out before laundering will help to prevent streaking and reduce color loss.

■ The objective in cleaning any FR fabric is to remove flam-mable soils and not to add anything that might reduce the FR properties of the garment. Therefore, flammable materials such as starch and fabric softener, which can accumulate on garments over repeated launderings, must not be used on FR jeans.

■ Chlorine bleach and oxygen bleach (e.g., hydrogen per-oxide), either alone or in combination, must not be used on FR treated fabrics. Repeated exposure to bleach will damage the flame-retardant polymer, reducing the flame-resistant properties of the garment. However, powdered detergents containing “color safe” bleaches, such as sodium perborate, may be used, and laundry de-tergent can be poured directly onto heavy stains to pretreat them

and aid in removal.■ Dryer sheets should not be used with any FR fabric because

the softeners in them could build up on the fabric surface, reducing the flame-resistant properties of the garment.

If Made in America is important to you, be sure to understand where each component of the FR fabric was produced. Does the fabric manufacturer use cotton fiber that was grown in the United States, which is in high demand these days due to its reputation for quality? Is the yarn spun in the United States, and where is the fabric woven? Does all of the fabric dyeing and FR finishing take place in the United States? Answering no to any of these questions means that the FR fabric wasn’t 100 percent produced here. In addition, if the fabric wasn’t made in the United States, can the manufacturer tell you where it was produced? When a manufacturer is unable to track the production of FR fabrics or even make it themselves, workers should consider that there may be a decreased level of quality control and reliability, which is of utmost importance when it comes to FR clothing.

Craig Tutterow is the technical director at Mount Vernon FR. Tutterow has 34 years of textile industry experience, and has worked in a variety of areas in the industry including dye chem-istry and product development and engineering. Contact him at [email protected].

John “Bud” Strickland is the director of denim product devel-opment for Mount Vernon FR. He has 40 years of textile industry experience. Contact him at [email protected].

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T here are three basic uses for industrial flame-resistant clothing:

1. Flash fire exposures: This apparel is needed by workers in refineries and for com-

bustible dust exposures and oil and gas operations. These flash fire-rated (FFR) garments are designed to be work clothing that needs to be comfortable and durable for daily work and may, at some point, be ex-posed to a flash fire. Durable flame resistance is criti-cal, but comfort is also paramount.

2. Arc flash exposures: Most electrical workers, electricians, and all line technicians for power lines require arc-rated (AR) garments. Like flash fire-rated garments, these garments are primarily work wear that once in a career may be exposed to an arc flash. They also need to be durably flame resistant and comfortable.

3. Firefighting: Structural firefighting and wild-land firefighting typically require inherently flame-

resistant fabrics due to the continual exposure and durability requirements in the field. These garments are exposed multiple times to heat and flame.

Twenty years ago, there were about five to six fabrics that were flame resistant, and there were two types of fabrics: treated flame-resistant fabrics and in-herently flame-resistant fabrics. Today, there are many new flame-resistant fabrics, either treated or inherent, that provide workers with comfortable options.

Inherent fabrics are made with fibers that are de-signed to be flame resistant. Flame resistance is part of the fibers’ DNA and is a permanent characteristic of the fabric.

Treated fabrics are cotton or cotton-blend fabrics that are treated with flame-retardant chemicals that change the molecular structure of the fabric, creating a permanent bond.

Sometimes there is misinformation in the market-place that creates concern about whether the flame resistance can be washed out of treated fabrics. It’s important to know that flame resistance cannot be washed out as long as the recommended laundering instructions on the garment are followed. Therefore, workers who require FR clothing should opt for styles made with whichever fabric provides them the most comfort, as long as it meets the safety requirements established by their employer.

Why is comfort so important in flame-resistant garments? The day-to-day needs of the clothing are primarily function, not protection, so getting the worker to wear the clothing for the “one in a million” incident is difficult if the clothing is not comfortable. Fortunately, most workers work entire careers in po-tential hydrocarbon flash fire and potential arc flash environments without ever having an incident.

Understanding the need for comfortable FR pro-tective clothing, scientists at several companies made two critical discoveries in the 1980s that improved on FR cotton while working to create military uniforms for the U.S. Navy and the U.S. Army. They discovered methods to treat cotton to make it as durably flame re-sistant as synthetic inherent fibers, but with additional comfort. In the 1990s, other scientists discovered that adding a small amount of nylon to FR cotton could in-crease the wear life, thus making the FR cotton/nylon more durable than simple treated cotton.

The Importance of ASTM F1506 and NFPA 2112Previously it was common to have garments mar-keted as FR but not certified for any hazard, but with the advent of ASTM F1506 and NFPA 2112, this has changed. In the past, garments were commonly rated separately for each hazard, but in an effort to be cost

Durable Flame Resistance: Comfort and QualityReal-world applications have brought on an in-creasing demand for garments that are suitable for use in environments with multiple hazards.BY THOMAS KIDDLE

CAR

HAR

TT, INC

.

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effective, practical, and to keep employees comfortable, real-world applications have brought on an increasing demand for gar-ments that are suitable for use in environ-ments with multiple hazards.

Over time, NFPA and ASTM developed washing requirements and a battery of tests to ensure that treated cotton fabrics main-tained permanent flame-resistant prop-

erties to help protect workers in arc flash and flash fire incidents. The two standards, ASTM F1506 and NFPA 2112, have helped to keep non-performing treated fabrics out of the U.S. market.

Many industrial workers face more than one hazard while at work, and the develop-ment of multi-hazard PPE products can save employers money while keeping the

worker protected and even more comfort-able. In light of this, many companies re-quire dual-hazard garments that meet both NFPA 2112 and ASTM F1506. Specifying these two standards will ensure that the garments are dually compatible with flash fire and electric arc exposures and will be the most durable (to wash) garments the market can provide.

For the price of one quality garment, an employer can protect its employees from two or more different hazards (electric arc and flash fires). There are no reported cases of failure in the flame resistance in any cer-tified dual-hazard garment. The peace of mind that durable, flame-resistant clothing offers is important for the worker, the safety officer, and the manager. Protected, com-fortable workers will not only to be an asset to companies, but also more productive in serving the customers. Keep them safe so they can outwork them all.

The FR clothing industry has capital-ized on these fabric improvements in order to expand offerings that provide protection and improve wearability for workers. In addition to protection and basic comfort, many FR garments are made with fabrics that offer desirable features and addition-al benefits through technologies such as sweat-wicking, anti-odor, or durable water repellent (DWR).

Additionally, there’s a wide range of style and layering options, including base layer, shirts, sweatshirts, pants, outerwear, bibs, coveralls, and accessories.

The bottom line is that with the prolif-eration of improved flame-resistant fabrics and styles on the market today, comfort and protection are no longer a compro-mise. Employers and their crews now have many choices, and as long as the fabrics—whether treated cotton or inherent—meet the testing standards described in this ar-ticle and the garment laundering/care in-structions are followed, they can be assured that the flame resistance will last the life of the garment.

Thomas Kiddle is director of Specialized Sales for Carhartt, Inc. He is responsible for managing Carhartt’s non-traditional sales channels, including Industrial Sales, Discount Sales, Wholesale.com, and Inside Sales. He joined Carhartt in 2001 as the di-rector of Carhartt’s Industrial Sales Division and previously was the business group man-ager for Bullard.

Specifying both NFPA 2112 and ASTM F1506 will ensure that the garments are dually compatible with flash fire and electric arc exposures and will be the most durable (to wash) garments the market can provide.

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SEARCH FOR OIL, NOT COMFORT- ABLE FR.

HIGH PERFORMANCE FR GARMENTS

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F I R E S A F E T YF I R E S A F E T YF I R E S A F E T Y


Many corporations require that all of their facilities be provided with automatic sprinkler protection to pro-

tect their employees and preserve cor-porate assets. Municipalities may also re-quire facilities within their jurisdiction to be provided fire protection systems, such as sprinklers, alarms, and various special protection systems to protect the com-munity and emergency responders. Fire protection systems are a significant part of the building systems as a whole, and as such, require maintenance and care so that they perform to their expectation in the event of a fire.

As the safety professional in your fa-

cility, you, your fellow managers, and co-workers are counting on these systems to protect your facilities, processes, and people. As with any emergency system, the time to test its readiness is not dur-ing a fire. Do not allow the presence of the sprinkler heads to lull you into a false sense of security. The best way to know that your systems are ready is through a documented inspection, testing, and maintenance (ITM) program. The pri-mary standard in use in most companies and municipalities is NFPA® 25, Standard for the Inspection, Testing, and Mainte-nance of Water-Based Fire Protection Sys-tems. NFPA 25 establishes the minimum requirements for the periodic inspection,

testing, and maintenance of water-based fire protection systems. It is not an op-timum standard. Rather, it specifies the minimum care required to maintain the system in an operable condition, and we should recognize that the level of action required by NFPA 25 is the base from which we should start and improve upon it to meet the needs of our facility.

The three main areas of a comprehen-sive program include:

■ Inspection: A visual examination of a system to verify that it appears to be in operating condition and is free of phys-ical damage.

■ Test: A physical trying or opera-tion of a system, or part of a system, to ensure or prove that it is functioning properly, as intended, or to an acceptable standard of operation.

■ Maintenance: The work per-formed to repair and/or maintain equip-ment in operable condition.

NFPA 25 states that the property owner or designated representative is responsible for properly maintaining a water-based fire protection system. The designated representatives may be the building occupant, management firm, or other person specified in a lease or con-tract. The building owner may elect to outsource the ITM services to a sprinkler contractor or other inspection, testing, and maintenance service. When the ser-vice is contracted to others, the building owner is typically the responsible party who should be overseeing the work, re-viewing reports, and authorizing repairs when needed.

There are many advantages of having a good fire protection ITM program. You will verify that all fire protection valves are open and the systems are in service. The operation of the equipment is veri-fied by actually operating and testing each device on the system. Alarms will be veri-fied from the devices to the alarm control

Implementing a Fire Protection Inspection, Testing, & Maintenance Program for Water-Based Fire Protection EquipmentHistory has shown that some of the largest industrial fires have occurred when systems were out of service, or impaired.By Walter S. Beattie

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TIN K

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panel and from the panel to the alarm receiving company. In set-ting up the program, you must decide if it is in your best interest to perform this work with in-house employees or with the use of contractors, usually established fire protection companies who install, inspect, test, and maintain systems on a daily basis.

Qualifications of People Performing TasksNFPA 25 states that a qualified person or company must per-form ITM tasks. A qualified person or company is competent and capable and has met the requirements and training in a given field acceptable to the authority having jurisdiction (AHJ). A qualified person is not required to be an engineer or hold a degree or certification. A qualified person should be competent, trustworthy, intelligent, and reliable. They should have training on the hazards, fire protection systems, and specific equipment they will be inspecting, testing, and/or repairing.

NFPA defines the AHJ as an organization, office, or individ-ual responsible for enforcing the requirements of a code or stan-dard or for approving equipment, materials, an installation, or a procedure. So, who is the AHJ? That depends upon your location or situation. If you live in a municipality that has an organized structure for safety, it may be the fire chief, fire marshal, building inspector, or other official. Your insurance carrier may act as the AHJ. In some companies, a risk manager or other management head may set policy and procedure, and that person acts as the AHJ. Many facilities will need to respond to multiple AHJs, and the most stringent requirements generally prevail.

In-house ITM ProgramMany companies utilize their own employees to perform ITM on their fire protection systems. Using in-house employees has advantages. The employees take ownership in the care of the sys-tems. They will be familiar with the location of each component of the system and will be confident in the understanding of its operation. Providing training for an in-house program can espe-cially pay off when an emergency situation arises—there will be expertise available to respond immediately. Your facility emer-gency response program will be strengthened with this in-house expertise. They will be able to take prompt action to mitigate losses and work with the emergency responders, such as the fire department or hazardous materials teams.

Outsourced ITM ProgramManagement has many financial challenges in today’s market. To meet these financial challenges, many companies have re-duced their employee payroll and outsourced many tasks. One of the tasks outsourced is the inspection, maintenance, and test-ing of the fire protection and alarm systems. Outsourcing servic-es can offer budget flexibility and control and allow management to purchase only the services they need, when they need them. It also reduces the need to hire and train staff in the completion of specialized tasks. In the end, outsourcing fire protection tasks

may reduce immediate capital and operating expenses.Using contractors to perform ITM services has advantages.

Contractor may be more familiar with details of fire protection equipment because they work on them daily and have experi-ence in the care required for the system. Selecting a competent contractor that employs well-trained and quality people is im-portant. The people servicing your equipment should be well trained and certified by an industry-recognized organization. If your state or municipality has minimum licensing qualifications, ask for the documentation certifying the employees. People holding NICET Certification offered by the National Institute for Certification in Engineering Technologies have demonstrat-ed mastery of key skills. NFPA offers training and certifications in various competencies. Also, you must develop a relationship with your contractor and trust their people who are assigned to service your systems.

There are disadvantages in depending on contractors to fully service your fire protection systems. Contractors are trying to be profitable, just like your company. They are going to perform their work as efficiently as possible in the least amount of time as possible. They may not be familiar with your company phi-losophies and culture. Their focus is solely on your fire protec-tion system and ensuring they are maintained to the minimum criteria, or as negotiated in the servicing contract.

Speaking of contracts, if you have contracted service, what does it include? Is it providing only quarterly or annual serving? Like most companies, fire protection contractors offer various levels of service. You may purchase any amount of servicing and testing, whether it meets the minimum requirements of NFPA or not. The ITM program is the responsibility of the building owner and/or occupant. Gaps between purchased services and required minimum service are your responsibility.

Combining In-house and Outsourced ITMA good compromise for many companies is to develop a pro-gram relying on both in-house and outsourced resources. The cost to have a completely outsourced ITM program that also meets NFPA and some of the daily and weekly requirements can be very high. The lack of in-house knowledge can result in seri-ous mishandling of the systems during an emergency situation when they are most needed.

Using employees to perform daily and weekly visual inspec-tions and checks of the fire protection system should not be a great burden upon your labor resources. It takes very little time to perform visual checks of items, such as confirming that a riser valve is open, that the temperature is adequate in a dry pipe valve house or fire pump house, that there are no unexplained system leakages at risers, that equipment is clear of obstructions, and that gauges indicate appropriate readings.

Many companies have ITM programs that handle inspec-tions and some testing in house. Testing of inspector’s test water-flow alarms and main drains might be performed by employees, while more involved testing is performed by contractors. Some companies have an in-house program and have sprinkler con-tractors perform annual and five-year ITM. This incorporates

Many facilities will need to respond to multiple AHJs, and the most stringent requirements generally prevail.



F I R E S A F E T YF I R E S A F E T YF I R E S A F E T Y


in-house expertise that is immediately available for questions or handling rou-tine issues. In the event of an emergency situation during working hours, there are knowledgeable people on site to quickly respond to the situation. Contractors pro-vide additional expertise to ensure equip-ment is operating properly. Dry pipe valve trip tests, deluge valve trip tests, fire pump annual flow tests, standpipe flow tests, and backflow preventer tests may be performed by a contractor who will provide expert evaluations of the in-ternal condition and functionality of the equipment. Contractors have the equip-ment needed to perform testing, saving the expense of purchasing hoses, fittings, nozzles, calibrated gauges, and other test-ing equipment.

DocumentationRegardless of the ITM program you im-plement, documentation is required to ensure the inspections and tests are being performed in an appropriate and timely fashion. The method of documentation may be designed to meet your system parameters. Weekly and monthly inspec-tions performed by a single person who visits each valve may be on a single sheet and initialed for each device and signed and dated before filing. If your program incorporates many people performing inspections by department, checklists posted at riser locations may be dated and initialed to verify inspections. The docu-mentation system may be a paper system or an electronic system that uses elec-tronic readers. Maintaining good ITM records will provide you with a historical record of the equipment. You will be able to compare current test data with histori-cal data to track any deterioration in the equipment’s operational performance.

ImpairmentsHistory has shown that some of the largest industrial fires have occurred when systems were out of service, or impaired. An impairment occurs when any alarm, fire, or explosion suppres-sion system is shut off or otherwise tak-en out of service, completely or in part. While it is recognized that impairments are necessary during testing, mainte-

nance, renovation, new construction, or because of equipment failure, you must understand that your facility is in greater jeopardy of major loss during an impairment. When an impairment is planned or occurs accidentally, pre-cautions must be taken to provide tem-porary protection, reduce hazards, and ensure prompt restoration.

Your facility’s human element safety program should include a comprehensive written fire protection impairment han-dling program. The impairment program outlines the measures to be taken before, during, and after any impairment to en-sure that increased risks are minimized and the duration of the impairment is limited. There should be an impairment coordinator designated to oversee your impairment program, with this person having designated individuals to oversee the program implementation during his/her absence. Fewer impairments, espe-cially hidden or unplanned impairments, are found in properly inspected and well-maintained systems. NFPA 25 devotes an entire chapter to the handling fire system impairments.

Additional ConsiderationsNFPA 25 addresses water-based fire pro-tection systems such as sprinkler, stand-pipe and hose, fixed water spray, private fire hydrants, water mist, and foam water systems. The standard does not address ITM of all components, such as electrical tripping systems or alarm devices. Other standards and codes will also apply, such as NFPA 72, National Fire Alarm and Sig-naling Code, as well as numerous other NFPA standards.

Another very important consider-ation to be aware of is change. The prop-erty owner or designated representative is responsible for the evaluation of the fire protection system when occupancy or process changes are made. When the occupancies or the processes change, new materials are introduced into the building or process, or when storage conditions change or other significant changes are made, an evaluation should be performed to ensure the fire system is capable of protecting against the hazards.

This evaluation is not considered part of the normal ITM program identified in NFPA 25. ITM performed in accordance with NFPA 25 does not address the ad-equacy of design criteria or the capability of the fire protection system to protect the building or its contents. It is not the role of a sprinkler contractor to determine the adequacy of the sprinkler system or wa-ter supply. That is the role of the building owner or his designated representative.

ConclusionWhether your management opts to main-tain your fire protection systems using in-house employees, out-sourced contract services, or a mixture of both, it is impor-tant that management and employees are trained in the system operation and valve locations. Your staff should be aware of how the fire protection systems work, the location of fire control valves, and other key components of the systems. In the event of a fire or other emergency at your facility, your emergency plans should be implemented immediately.

Walter S. Beattie, CSP, CFPS, CSHM, is President of Beattie Fire Protection & Risk Consulting, LLC. He has worked in the highly protected risk (HPR) insur-ance field since 1979 in various technical capacities and has extensive manufactur-ing process fire protection experience in many industries. He was active in the vol-unteer fire service for fire, hazardous ma-terials response team, and ambulance for more than 30 years, holding line officer and training positions; served as a prin-cipal member of several NFPA commit-tees; and is an active member of Ameri-can Society of Safety Engineers Council on Professional Development and ASSE Fire Protection Practice Specialty Ad-visory Committee. His website is http://waltbeattie.com/.

©Walter S. Beattie, Beattie Fire Protec-tion & Risk Consulting

BIBLIOGRAPHYNational Fire Protection Association. NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems. 2014 ed. Quincy, MA: National Fire Protection Association, 2014.


http://waltbeattie.com/

http://waltbeattie.com/



LOCKOUT/TAGOUT

A ccording to the U.S. Bureau of Labor Sta-tistics, up to 80 percent of injuries related to servicing and maintenance of equipment and assets can be attributed to not follow-

ing simple lockout/tagout (LOTO) procedures. Ad-ditionally, LOTO is consistently listed in OSHA’s list of most frequently cited violations, with the agency citing 120 fatalities and 50,000 injuries each year that could be prevented by instituting a LOTO program.

With those statistics in mind, how can compa-nies improve their LOTO practices? It starts with new technology that streamlines the LOTO process and provides greater efficiencies and visibility. New technology on the job site or in the workplace can be intimidating for both managers and their employees, but it could be the difference between life and death, making it well worth the investment.

Here are three ways new LOTO technology makes the workplace safer and helps companies stay compliant:

1. It makes compliance easier and more efficient than ever before.

It is estimated that at least 60 percent of compa-nies that need LOTO procedures simply do not have them. As a result, these companies are often out of compliance and are putting their employees and their reputation at risk. Many times they do not realize that they need LOTO technology until after something has gone wrong. No company can afford this in a day and age where safety is increasingly under the microscope and linked to corporate reputation and effectiveness.

New LOTO technology simplifies the ability to meet compliance standards, which in turn helps to ensure the safety of employees on work sites. Safety and compliance managers can access and update the LOTO procedures at any time from any location using the Web, smartphones, or tablets.

Technology makes it easier to author LOTO procedures up front and then certify and edit those

Technology to the RescueLOTO technology can create a safer workplace and make compliance more efficient.BY DARCIE DASILVA AND STEVE BURGESS

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LOCKOUT/TAGOUT


procedures as required. Users also can set up periodic audits of the procedures, as required by OSHA. This new automated scheduling helps ensure safety and compli-ance managers don’t miss required LOTO procedure audits.

The ROI for this new LOTO technology investment comes down to this: How quick-ly can your team author, certify, and manage all required LOTO procedures in your facil-ity, including all periodic audits and their timely completion? It is significantly more

cost efficient and effective to use technology to create and manage your LOTO program. The last factor to consider is: What is the re-turn on saving a life or a limb?

2. It eliminates dangerous shortcuts.Now that the LOTO procedures have

been authored up front, workers can follow step-by-step procedures on how to lock out each isolation point on the equipment. Each step is time-stamped and recorded, and there is verification after each step before a worker can move on to the next isolation

point. This process repeats no matter how many steps there are in the LOTO proce-dure, ensuring that nothing is overlooked.

It is not uncommon to hear stories of someone working on a machine for 30 years without an incident and then suddenly the worker—maybe in his last week before re-tirement—does not follow a procedure and has an accident that could have been prevented. You just never know. But new LOTO technology can avoid such a tragedy, simply because it can prevent shortcuts. The technology records all steps and events in the history of all assets, providing full trans-parency and reports for any auditors. There is no longer a need to maintain or search out paper records on short notice.

3. You are better informed—all the time.

Factories and major manufacturing facilities can be massive and complicated places, but safety is always a top concern. For safety managers in particular, it can be extremely challenging to keep a handle on what is happening at any given time. That is where new LOTO technology comes in: It provides traceability in your local facility or any other implemented facility around the globe.

All of this data helps employees on the floor because it creates clarity. The technol-ogy clearly documents every procedure to seal off an isolation point, and when exe-cuted, it shows who completed the lockout and when. As a safety leader, that leaves you better informed and in greater control.

People are always resistant to change. That cannot be denied. However, think about seatbelts for a minute. Hardly any-one wore those 50 years ago, but a change in the interest of safety took hold and now it is standard practice for all drivers. LOTO is no different. There are now tools in place that make LOTO significantly easier and more efficient. That should make all of us more comfortable.

Darcie DaSilva ([email protected]) is a sales manager for Master Lock Field iD. He has been with Field iD since 2011, mov-ing up from sales executive by focusing on positive public awareness and helping safety managers meet corporate and governmental safety standards through SaaS technology. Steve Burgess ([email protected]) is general manager, global sales and marketing at Master Lock Field iD.

Automated scheduling helps ensure safety and compliance managers don’t miss required LOTO procedure audits.

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TRANSPORTATION SAFETY


A s of Feb. 6, 2015, companies and manufac-turers that ship and package lithium bat-teries must comply with a new final rule on lithium batteries, formally known as

HM-224F. Originally published by the U.S. Depart-ment of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA), this rule represents a significant change in how lithium bat-teries are regulated when shipped by land, sea, and air in the United States.

Changes were made in order bring lithium battery regulations in this country closer to those overseas, such as the International Civil Aviation Organiza-tion (ICAO) Technical Instructions, the International Maritime Dangerous Goods (IMDG) Code, and the UN Model regulations. This means that U.S. compa-nies will have to update training programs and com-ply with new labeling requirements.

Lithium batteries are unique in that they serve as a reliable source of power for many different applica-tions and devices. This source of power is also the rea-son why they are so heavily regulated; several signifi-cant incidents involving fires in cargo and passenger aircraft have been caused by poor transportation of lithium batteries.

The Federal Aviation Administration has tracked more than 50 lithium battery incidents in aviation alone, encompassing both traveling passengers’ bag-gage as well as cargo shipments. For example, on April 28, 1999, a shipment of lithium metal batteries caught fire at the Northwest Cargo Facility at Los Angele In-ternational Airport when a pallet of lithium batteries was rolled onto its side while being offloaded at the cargo facility. A few hours after the pallet overturned, it caught fire, showcasing the latent dangers of lithium batteries. The concern was that the fire could have oc-curred while in the air mid-flight.

A study by the National Transportation Safety Board found that of the 34 aircraft-related incidents involving batteries since 2007, those involving lithium batteries were the most prevalent. Poor handling and packing were the most common causes. Incidents don’t just occur while in flight; any time a device is be-ing charged in poor conditions, such as in a bedroom under a pillow, there is risk involved, and the device could potentially overheat and start a fire.

Perhaps the biggest change for U.S. companies in the final rule is the elimination of the 12/24 exception. In the past, if a package contained no more than 12 lithium batteries or 24 lithium cells, no hazard mark or documentation was required. This provided com-panies with a broad exception for shipping a wide range of lithium batteries. Now, packages of any size containing lithium batteries must be properly sealed and labeled, which may challenge smaller businesses.

Bob Richard, vice president of regulatory affairs for LabelMaster, said these changes are likely to affect high-volume customers more than others due to the large number of shipments being made. In his role at LabelMaster, Richard often visits companies with the intent of putting them in a position to minimize the mistakes made due to the new rule.

“The people who make the classifications, as well as the people who work in distribution centers, packaging, shipping and loading, and receiving, they should have some general awareness of these regu-lations,” said Richard. “Then they should get func-tion-specific training, depending on what products they’re handling. We like to make it very specific to that company.”

Richard said companies such as power tool compa-nies ship all of their batteries packed into the tools, so they don’t have to worry about contained-in practices and other techniques that don’t apply. Companies that are affected by this final rule run the gamut, from cell phone companies to those that develop implantable defibrillators. Start-up companies also present chal-lenges because they might not be aware of some of

DOT’s Lithium Battery Final Rule Takes EffectNow, packages of any size that contain lithium batteries must be properly sealed and labeled, which could present a challenge to smaller businesses.BY MATTHEW HOLDEN

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the regulations before shipping prototypes with lithium batteries. Any company that ships a single lithium battery will have to be aware of these changes and act accordingly.

Reverse LogisticsA unique challenge this rule creates is the proper packaging for consumers to return items with lithium batteries. If someone has a faulty cell phone and wants to return it to the company that makes it, that person runs the risk of improperly packing it with-out the correct labeling materials. Richard advises his clients to provide consumers with good information by designing safe and compliant kits for returning items.

“It’s not only consumers; some com-panies have franchisees and distribution centers,” he said. “Look at the auto in-dustry. We’ve developed hazmat courses online at the dealership level that provide them with kits.”

Part of Richard’s process involves visit-ing individual companies in order to assess their needs. Instead of making blanket as-sumptions about what certain industries need, he can help companies apply tech-niques based specifically on what it is they produce and what kind of volume they manage. For example, Richard said a power tool company would sometimes be bet-ter off giving a customer a credit for a new tool instead of having the customer mail it in to be repaired or replaced. Not only is this less work, but also it can also prevent the customer from improperly shipping a lithium battery and causing an incident. Instead, the company gives the customer instructions on how to properly dispose of the equipment locally.

International ProceduresSo what is it about the international regu-lations that make them seemingly supe-rior to the old U.S. regulations? When Richard previously worked for PHMSA, the FAA asked him and his office to write a lithium battery rule that far exceeded the international rules. This would have made it harder for international companies to ship here in the United States because the rest of the world would have had to adapt. Instead, the group spent years revising the rule until it got to where it is today: in line with the international regulations. “In my mind it only makes sense to go through the international organizations and har-

monize with those rules,” said Richard. “If the international community agrees with something that you think is a real safety issue, then the U.S. has the authority to deviate when that happens.” He said this adaptation of the international rules has been a long time coming, as it promotes safety and enhances communication throughout the shipping world.

So What Does This Mean?The mandatory compliance that took place on Feb. 6 means if people have not changed their operations and packaged their ship-ments properly, the carriers will reject them. Fines and violations are always a concern for businesses and manufactur-ers, but when the products aren’t getting shipped, that reflects poorly on those busi-nesses in the eyes of consumers.

Some of the other major changes in HM-224F include the replacement of Equivalent Lithium Content (ELC) with watt-hours replacement and new, simpli-fied shipping names and UN numbers. Under the previous regulations, shippers needed to know the ELC of the batteries being shipped, something that isn’t neces-sarily easy to determine. Measuring watt-hours is a more standardized approach.

PHMSA also has adopted new proper shipping names for lithium ion and lithium metal batteries, as well as new UN numbers, which are essentially identification num-bers. One simplification is the use of the same numbers for batteries that are “con-tained in” and “packed with” equipment. Going forward, Richard said he expects more changes to come in the final rule. Work has already begun on HM-215M, which would further harmonize lithium battery requirements with international standards beyond what was adopted in the current final rule. Richard also has filed a petition to the rulemaking with DOT that identifies some corrections he considers necessary in the rule.

The fact that the final rule harmonizes U.S. procedures with those overseas will make shipping and packing products for a worldwide audience much easier going forward.

Matt Holden ([email protected]) is an associate content editor for 1105 Me-dia, Inc. He received his MFA and BA in journalism from Ball State University.

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LOCKOUT/TAGOUT

E ver wonder if your approach, or your safety manager’s approach, to safety is like oth-ers responsible for safety? Does your ex-perience match up well with that of others,

or are you in the minority in some issues of safety? Standards are pretty clear on the correct height range for a safety hand railing or the appropriate rise and run for a stairway, but what about compliance with procedural safety standards or those areas requiring more of a safety professional’s judgment? These areas are explored based on the results of a survey of self-identified safety professionals.

In fall 2013, the National Safety Council’s AMPS Committee, with the assistance of the National Safety Council (NSC), distributed a survey to more than 3,000 safety professionals concerning some issues of machine safety, safety interlocks (see the definition below), and used equipment safety. There were 111 re-spondents to the computer-based survey, all of whom were identified by the council’s database, and by the individual respondents, as being responsible for some aspect of industrial safety.

The questions typically did not have hard and fast answers, but fell to some extent into a gray or profes-sional judgment zone. Consultation with various oc-cupational safety and health regulations, letters of interpretation, and other publications could provide more detailed and perhaps exact answers to the ques-tions, but the range and diversity of answers shows that this may not be the case. The takeaway from the survey may be that safety compliance still relies heavily on ex-perience and good and poor workplace tradition.

Below is a summary of the results and a short dis-cussion of these findings.

The survey was short, consisting of 11 questions that typically requested yes/no responses, the fre-quencies of certain safety activities, and estimates of accident-related events. There also was an opportuni-ty for comments concerning the issues in the survey. This author thanks all of those who participated.

Questions concerning machine safety, safety inter-locks, and used equipment safety included the issues of:

■ testing and/or exercising of safety interlocks■ manufacturers’ directions on the frequency of

testing and/or exercising safety interlocks■ the need for testing of safety interlocks on used

equipment■ the implementation of “alternative” means over

more traditional lockout/tagout procedures■ the expectation that used equipment would

have all of the necessary safety equipment■ the failure of an interlock causing and/or con-

tributing to an injury

General Overview of Results1. More than 95 percent of respondents indicated their facilities utilized more than 31 safety interlocks on their machinery.

2. Eighty, or 72 percent, of the respondents indi-cated that all safety interlocks got exercised/tested every time a machine is placed into production, and 31, or 28 percent, indicated safety interlocks do not get exercised/tested when machines are placed into production.

3. When asked the frequency of safety interlocks being exercised/tested per shift, about 52 percent in-dicated that occurred less than once per shift, about 39 percent indicated once per shift, and 9 percent in-dicated more often than once per shift.

4. More than 77 percent indicated the machine provider did not provide a frequency on which to test safety interlocks.

5. When asked whether a safety interlock might be used in the lockout/tagout activity, 17 percent indi-cated they would use an interlock in lockout/tagout.

6. Of the 111 respondents, 12 (~11 percent) indi-cated they knew of a safety interlock failure causing an injury.

7. When queried on the purchase of used equip-ment, it was almost unanimous that they would ex-pect that safety devices on the used equipment that they acquire would be checked by their staff.

8. In addition, on used equipment, 97% of respon-dents indicated that they would not assume the resell-er of the used equipment provided all the necessary safety features.

Safety Interlock DefinitionA safety interlock is “a device or means that places a machine or machine component into a zero, or sub-stantially reduced, danger-mode upon intent to ac-cess; or a device or means that will actively prevent access to a hazard upon intended access. (Example: an interlocked clothes dryer door that upon opening will quickly stop high-speed rotation of the drum, or a clothes dryer door that will not allow intended access during high-speed mode of operation.)1

Safety Interlock TestingThe concept of interlocking for safety can be traced

Machinery Safety Survey Results: Safety Interlocks and Used EquipmentBY GARY M. HUTTER

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back several decades, with perhaps electri-cal fuses and shear pins on power transmis-sion shafts being two of the earliest wide-spread applications of some form of safety interlock. While these two early forms of interlocks did not necessarily prevent inju-ries, they may have mitigated some injuries and primarily were directed at preventing damage to equipment. Subsequent safety interlocks were more directed at reducing injuries by preventing behaviors that might cause an injury or by placing a machine in a safe status if inappropriate behaviors oc-cur. Properly designed pull back devices on mechanical power presses prevented the bad behavior of reaching into a cycling ma-chine; properly designed two-hand control would stop a part revolution clutch, mak-ing it safer if the operator detected a pos-sible “reach in” situation. Of course, pull back devices and two-hand controls that were misadjusted and/or mis-positioned would not provide a consistent level of safety, hence the need to regularly examine their performance.

More effective and modern safety inter-locks generally were being patented in the 1950s. They often used limit-switches or other linkages to detect the status of a guard, machine component, or machine operation to perform the safety interlock function. These mechanical elements required proper alignment, non-jamming features, and re-turn devices (e.g., springs, gravity, counter-weights) as basic elements of their design. To remain functional, their movements and performance needed to be verified in case a spring broke or something jammed, pre-venting gravity from resetting the interlock. Verification of the performance of safety interlocks did not guarantee future per-formance but provided an opportunity to correct malfunctioning safety mechanisms, potentially before an accident.

In the 1960s and 1970s, the patent his-tory indicates there was a marked increase in non-mechanical, non-limit-switch based interlocks, often in the forms of light curtains, proximity detectors, or other type of presence/motion detectors (invisible de-tection means). These devices may not have had the same mechanical switches, align-ment, and/or jamming considerations of the prior generation of mechanically acti-vated switching mechanisms, but they, too, require some sort of functional testing. For example, many providers of light curtains

specify intervals for functional testing of their performance and coverage. Rockford Systems (a provider of safety hardware and training) publishes a checklist for light cur-tain installations that states: “Light curtains should be function-tested at every set up, op-erator and shift change, as well as every time after maintenance is performed.”2

To perform some testing of interlocks (e.g., during removal for electrical inter-lock testing), there may be a need to bypass the interlock mechanism or to perform some invasive action (e.g., reach beyond a guarded area). A functional evaluation for the earlier limit-switch interlock configura-tions and/or for the newer invisible detec-tion means often actually simulating behav-iors that are hazardous; that is, simulating reaching into a moving machine, opening a hinged guard when the machine is on, or functioning on/off switches at what could be inappropriate times. Other interlock activities, such as those that do not allow a machine to restart by itself after a power outage and circuit reset, may be more dif-ficult to simulate but still may have required some orchestrated performance testing.

Because all of these safety interlocks still required some surveillance to determine their functionality, it was often deemed useful to check these interlocks by exer-cising them and/or testing them on some time-based frequency. For example, some manufacturers of commercial lawn, yard, and garden equipment provided some guidance on the frequency of testing of their machine interlocks. They typically operate in dusty, wet, and high utility-rate environments that can frustrate the longev-ity of such an interlock.

A third wave of safety interlocks that are reportedly self-checking are documented in the patent literature, generally starting around the mid-1980s and into the 1990s. These schemes may use redundant elec-tronic circuits3, movable safety interlock mounting elements to simulate operation without human involvement4, and/or me-chanical redundancy and hardware5. There has been some criticism6 of the reliance on these attempts of self-checking as manifest-ed on interlocks in the form of redundan-cies, interlock bypasses, and/or negative vs. positive failure mode monitoring7.

Regardless of the frequency of exercis-ing and/or testing of safety interlocks, most of the subsequent results can only monitor

past performance and often have little abil-ity to determine future performance of a particular safety interlock. In many ways, it is like the “test button” on a smoke alarm: It tells you the horn and battery are func-tioning today and most likely yesterday but does not tell you whether the battery will be good at the end of the week.

Relevant Codes and StandardsVarious codes and standards include safety interlock criteria. American National Stan-dards Institute standards and National Elec-trical Code (NEC/NFPA 79) for industrial machinery generally have not mandated a specific frequency for interlock exercising and/or testing, but in a liberal reading of ANSI/ASSE Z244.1-2003 (R2008)8, it does address self-checking or monitoring to en-sure the integrity and performance of con-trol circuits (e.g., interlocks):

“Medium Risk Potential – Any exposure to serious injury. A dual channel circuit of industrial rated components that is self-checking or monitored through the use of a safety relay or safety PLC’s to ensure integrity and performance of the control circuit. These systems typically have redundant interlock switch safety contacts, redundant isolation through positively guided electro-mechanical relays and are monitored or self-checking” (page 26, para 5.4.3.2)

In ANSI/SPI B151.21-2003 (for certain plastic manufacturing equipment), there is added detail about self-monitoring in-terlocks: “A monitoring device shall be pro-vided to verify the operation of the safety interlock(s). When improper operation is detected, the cycle shall be inhibited and an alarm shall be activated.”

This self-detection and self-stopping concept is repeated for electrical, hydraulic, pneumatic, and mechanical safety inter-locks and devices.

More recent International Standards Organization (ISO) standards and criteria have begun to more specifically address these issues of testing equipment-mount-ed safety interlocks. In EN ISO 13849-1 (2009), this issues of testing interlocks and other safety components/systems is addressed in various forms, including the concept of “Mean Time To Failure” and “Mean Time Between Failures.” The Rock-ford Automation summary of that standard states: “Designated Architecture Category 2 must use basic safety principles {see index




LOCKOUT/TAGOUT

of EN ISO 13829-2}. There must also be di-agnostic monitoring via a functional test of the system or subsystems. This must occur at startup and then periodically (underlining added for emphasis) with a frequency that equates to at least one hundred tests to every demand on the safety function.”9

This standard language leaves the fre-quency of testing somewhat poorly defined, and this was confirmed through contact with one of the major interlock suppliers, who referenced ISO 13489, section 4 (de-sign of safe machine control systems). That standard, for example, discusses a ”Cat-egory 2” interlock architecture, para 4.1.3, wherein “The periodic test interval is de-pending on the application. . . . The checking interval can be established or based on the operating cycle or the machine cycle. It is im-portant that the interval is suitable for [the] application. The checking interval needs to be evaluated/determined during the risk as-sessment for the application.”

For the above considerations, interlocks should be exercised and/or checked (moni-tored) for functionality. This may be due to possible mechanical, hydraulic, pneumatic, and/or electrical reasons. There appears to be a strong acknowledgement/codification for the need for periodic monitoring, but it also appears that there is some latitude as to the exact frequency when using equipment that preceded recent applicable safety standards.

Using Safety Interlocks for LOTO ComplianceThe concept of control of hazardous en-ergy focuses on the elimination or con-trol of hazards and hazardous energy for maintenance and certain servicing opera-tions. ANSI published standards on that issue prior to 1980, and OSHA codified the criteria in the 1980s and early 1990s in at least two portions of its standards: OSHA 29 CFR 1910 subpart S-Electrical, 29 CFR 1910.333, and in 29 CFR 1910.147, “The Control of Hazardous Energy.”

While the survey resulted in a rate of 17 out of 100 respondents indicating their approval of using an interlock for the con-trol of hazardous energy under LOTO conditions, this is not the current policy of OSHA. The published OSHA criteria are in 29 CFR 1910.333(b)(2)(ii)(B): “The circuits and equipment to be worked on shall be dis-connected from all electric energy sources. Control circuit devices, such as push buttons, selector switches, and interlocks, may not

be used as the sole means for de-energizing circuits or equipment. Interlocks for electric equipment may not be used as a substitute for lockout and tagging procedures.”

This admonition is repeated in other OSHA publications, including “Safeguard-ing Equipment and Protecting Employ-ees from Amputation,” OSHA 3170-02R, 2007: “Interlock control circuitry may not be used for all maintenance and servicing work”10 and 29 CFR1910.333(b)(2()ii)(B): “Interlocks for electrical equipment may not be used as a substitute for lockout and tagout procedures.”

While one might theoretically argue that if an interlock is good enough for safe access during operations, why should it not be sufficient for other activities, there are several reasons. One rationale is contained in the NFPA 79 standard and is based on the concept that when an interlock may neutralize electrically powered compo-nents from movement (e.g., a motor will not be able to run), there is still a possibility of electrocution if the electrical power itself is not eliminated.11

So, in general, following the traditional OSHA lockout/tagout procedures would not allow reliance on interlocks for worker safety.

The Safety of Used Industrial Production EquipmentThe terminology “Used Industrial Produc-tion Equipment” may have multiple conno-tations to different user groups. When we as non-industrial equipment purchasers go and buy a used car from a used car dealer-ship, we generally expect that it is in rea-sonably good shape from a safety perspec-tive. This does not mean that if we purchase a 1964 car, we expect it to have seatbelts (having been made prior to the manda-tory seatbelt requirement) or that even the purchase of a 2012 car will assure us the protection of airbags all around. But in ei-ther case, it would seem reasonable that the brakes have been tested, what airbags are there work, and the seatbelts are compliant. If we buy a used mechanical item from a garage sale, we may have much lower ex-pectations.

In an industrial setting, there are sell-ers of used equipment that advertise and warranty that the used equipment operates and/or that the safety components function as designed. Typically, they do not perform their own independent safety analysis, their own detailed destructive testing, or risk as-

sessments. Often these sellers do not know of the past service life or intended service application of the used hardware, forcing them, to some extent, to rely on the in-tegrity of the original design and the care of the new owner. Other sellers of used equipment may sell equipment in an “as is” condition. That is, the equipment was more of a salvaged item, perhaps to be used for spare parts or significant modification and upgrading by the purchaser.

While these distinctions were not de-fined in the original questionnaire, it is apparent that those responding gener-ally knew that used industrial production equipment may not have all the safety whistles and bells, and therefore respond-ed as they did in regard to checking and evaluating safety items on this type of used equipment.

Gary M. Hutter ([email protected]), P.E., Ph.D., CSP, is Principal at the consult-ing Firm, Meridian Engineering & Technol-ogy, Inc. (www.mederianeng.com), in Glen-view, Ill. He is a National Safety Council AMPS machinery safety committee member and its current chairman.

REFERENCES1. ANSI/SPI B151.21-2003 Defines an interlock as “An arrangement whereby the status of one control or mechanism allows or prevents the operation of another.” ANSI B11.19 for Machine Tools–1990 uses similar language.

2. Rockford Systems, Inc., www.rockfordsystems.com/online/training/lightcurtain.cfm, 2/2014

3. U.S. Patent, Keese, 1/25/94, Self-checking Interlock Control System 5,281,857

4. Foreign Patent, Barnett, 7/5/2000, Remote and Proximal Guard and Interlock Testing Mecha-nism, EP 1015862 A2

5. U.S. Patent, Kneip, 7/5/83, Self-checking Safety Mat, 4,392,176

6. “Safety Interlocks--The Dark Side”, F. Hall, Safety Brief, ISSN 1041-9489, June 1992, v7, No. 3

7. e.g., Negative Mode monitoring senses guard is closed and allows machine to operate; Positive Mode monitoring senses the guard is not closed and that prevents machine from operating.

8. Note this standard is written for the control of hazardous energy.

9. “Safety Performance Levels,” EN ISO 13849-1, Rockwell Automation

10. Table 1 information on interlocks.

11. Safety Bulletin,” Primary vs Secondary Protection: Why Interlocks and Not an Accept-able Alternative to Lockout,” W. Switalski, Triodyne Inc., 9/2000



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http://www.rockfordsystems.com/online/training/lightcurtain.cfm


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Measuring activities to determine the health of im-provement efforts or culture tells you very little if excellence is your goal. Excellence is not just zero in-juries or incidents; it is the ability to win through the

achievement of great results, with strong and confident insight into how the results were achieved and a culture that focuses on a con-tinuous improvement mindset.

Many well-intended organizations suffer from a programmatic focus and demonstrate an activities-based culture, whether these activities add value or not. For years, the safety profession, in par-ticular, has tried to compete with the business goals of production by integrating activities and thinking into everything to overcome this competition. If there is no real or perceived value that is yielded by the activities, the competition continues, as it was not correctly addressed. Our strategy shouldn’t be to compete; it should show how we will win by adding value. Zero injuries or incidents is the byproduct of the value of excellence, not the final goal.

Effective safety strategy, however, is still surprisingly lacking in many organizations. I have named the “strategy” in place for most the Perpetual Cycle of Avoiding FailuresSM, with zero injuries being the primary, misguided goal. The cycle repeats like this: 1) Review current injury rate. 2) Set new injury rate or objective. 3) Develop a list of initiatives (or programs). 4) Execute on the efforts. 1) Review current injury rate.

Problems arise when the rates improve. Most leaders know correlation doesn’t mean causation, but this is forgotten with im-proved results: “We had better performance and we were doing these things; therefore, we had better performance because we were doing these things.” Sounds logical, doesn’t it? This is just as flawed logic as individuals who define safe as zero injuries: “Safe means not getting hurt, so therefore, anything I do that doesn’t get me hurt must be safe!”

Alternatively, it is easy to become distracted when rates don’t im-prove or with each new incident when the search is revived for what else can be done. More seems to be the answer or driver for im-provement, rather than how we do safety better. At some point, how we do safety better is answered by removing effort that is no longer value-added, even though at one point in time, it might have been.

An effective strategy is a framework of choices an organization makes to determine how to capture and deliver value. This strat-egy answers, “How will we win and know we are winning?” These choices have been made by many ProAct Safety clients over the years with a culmination of advancements in what is measured (see Evolution of Safety Excellence MeasurementsSM). These organi-zations evolved from measuring lagging indicators (their results) to leading indicators (typically inputs and activities) to transfor-mational indicators (measurement of contributed value from the activities to the results).

Consider your health as an analogy: a lagging indicator might be having or not having a heart attack. Exercise, calories burned versus consumed, and diet would be leading indicators and are comparable to how we measure our leading indicators in safety: activities and ef-

fort. However, if you check your blood pressure and it is high or has increased and you are making healthy eating de-cisions and regularly exercising, the an-swer is rarely more diets and increasing exercise. You might need a different in-tervention, as more is rarely the answer. Your blood pressure is a transforma-tional indicator that tells you the value derived from your activities.

In both health and safety, we must all evolve to measure not just the things we do to try to improve the lagging indicator results, but also the contribution of value from our activities to our results. For safety, the following are proven ex-amples of transformational indicators: Desired Beliefs, Emotions, Knowledge Levels, Competencies, Behaviors, and Organizational Story-Telling.

Consider training: If we measure only attendance but not whether, as a result, people know what we need them to know, be-lieve what we need them to believe, and do or are able to do what we need them to do, is there any real return on investment of time and resources? If we had people in a class and results improved, should we trust how real and sustainable the results are?

Organizations on the path toward excellence in safety perfor-mance and culture realize they need a strategy. Strategy is making trade-off choices (what will we do, not do, or stop doing) to win. As part of their strategy, the focus and measurements evolve from results and activities toward capturing and delivering value to the customers of their safety efforts. In your organization, what trans-formational indicators would tell you the value contributed by your safety efforts? Focus on this and you will significantly increase your chances of winning.

Shawn M. Galloway is the coauthor of STEPS to Safety Culture Ex-cellence and President of ProAct Safety. He has helped hundreds of organizations within every major industry internationally achieve and sustain excellence in performance and culture. He is also the host of the acclaimed weekly podcast series Safety Culture Excellence®. He can be reached at 800-395-1347 or [email protected].

Lagging to Leading to Transformational Indicators: Measuring the Contribution of Value

PRACTICAL EXCELLENCEB Y S H A W N G A L L O W A Y

Problems arise when the rates improve. Most leaders know correlation doesn’t mean causation, but this is forgot-ten with improved results.

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BREAKTHROUGH STRATEGIESB Y R O B E R T P A T E R


When attention slips, so can we. Likely because the mind leads the body. Attention is much more than solely “mental” – it drives what our body does. Ev-ery action begins with our brain sending signals to

activate specific muscles for accomplishing selected tasks such as reaching, grabbing, lifting, or walking. In other words, what we see + what we intend + what we direct all lead to what we actu-ally do. Understanding this, internal martial arts masters instruct students to initially focus on affecting attacker’s perceptions: “First move their mind in order to move their body.” Similarly, skid con-trol trainers remind drivers to “Stare, don’t steer, into a turn.” That where you focus is where you’ll wind up heading (termed “target fixation” in aviation.)

Turning attention toward preventing the persistent problems of slips, trips, and falls, I’m sure you’ve seen similar statistics over and over again – they don’t seem to change much. According to the U.S. Bureau of Labor Statistics, there were 223,700 cases involving falls, slips, and trips in 2012. But how many more went unreported? Off the record, numerous corporate Safety pros reveal these are among the most underreported incidents. And what about those slip or trip injuries that are coded differently because they result in strains and sprains or are “bodily reaction” (basically a slip/trip/balance issue that didn’t result in impact)?

Further, no surprise, this issue affects companies wherever peo-ple walk, worldwide. For example, Great Britain’s Health & Safety Executive reported that in 2013-14, falls and slips & trips account-ed for over a third (35 percent) of all employee injuries.

Standard responses to these persistent problems are good and all and have undoubtedly managed to keep slips/trips/falls from becoming worse. But even with best mats/signs/flooring/remind-ers and footwear, the level of these injuries has still clearly been holding steady at a dull roar. And, regrettably, there are some con-vinced nothing else could be done, that these injuries are inevitable and ultimately unpreventable. In counterpoint, strongest leaders know that all problems have solutions, even if they haven’t yet dis-covered them.

Consider another approach: placing people more in control of their own safety by transferring to them the right mental and physical skills. This has shown to consistently prevent slips/trips/falls; it begins, as many things do, with attention.

Performance psychologist Robert Nideffer sees attention as having two dimensions: width and direction. Width means its field – what you see and/or hear or smell or feel – can be narrow or wide. Direction refers to where you focus, either internally (thoughts, re-calling procedures, dwelling on nagging pain in part of body, etc.) or externally (objects strewn on the ground ahead and more). We may be too narrowly focused to see that we could have walked around that slippery area or trying to be so externally aware that we didn’t notice we were holding our breath (raising tension and sapping balance) when traversing an at-risk surface. I’ve found that a high-level ability to prevent slips, trips, and falls relies on being

able to combine and shift between attentional fields, appropriately scanning for surface changes or obstacles with a wide/external view, then zooming in with a narrow external view – to note, for example, how elevator floor and threshold are at slightly different heights – while maintaining a wide/internal sense of balance.

While this may sound like a pretty tall order, we all already do this to some degree. The takeaway is this is a combo skillset that is neither haphazard nor hereditary; attention control can definitely be improved with the right practices. Which can, in turn, greatly alleviate these potentially daily injuries.

Now, consider that physical balance is brain-regulated with strong attentional components. Dr. Roger Sperry, winner of the Nobel Prize for Medicine/Physiology, demonstrated that 90 per-cent (!) of the brain’s energy output is used for maintaining balance in space.

Stress is an additional factor, because it narrows vision/atten-tion (resulting in tunnel vision, like walking with blinders at the sides of your temples) and so contributes to slips, trips, and falls. Trips come from unseen traps – it’s the small things that get you – typically obstacles on the ground at ankle level and below (running into something thigh-high may hurt but is unlikely to cause a trip). And have you heard of an upset or emotionally/mentally distracted person running into something that was otherwise plainly in sight? Or a worker not recalling prevention methods she’s been taught because her mind’s preoccupied with something else? Of course, these things only happen to others (LOL).

And aging workers are especially at risk for slips, trips, and falls. Some primary reasons? 1) Sway studies indicate that it takes longer for older people to reestablish balance than younger people, likely due to age-related lessened sensitivity of vestibulo-cochlear nerves in the inner ear, which detect sideways leans, thereby triggering re-establishment of balance. 2) Sarcopenia, age-related loss of muscle strength, means leg strength may no longer be adequate to com-pensate for slight unbalancing that can result in any misstep. 3) Vi-sion changes may make it harder to see (and therefore adjust to) surface changes or obstacles. 4) Cumulative loss of joint flexibility combined with soft-tissue collagen breakdown can hamper agility (for quick recovery). And more.

Regrettably, I can’t transfer personal techniques for preventing slips/trips/falls in writing (or video) any more than can I try to help you experience the taste of a spice you’ve not yet tried. However, rest assured it’s readily possible to help all kinds of workers of all ages learn how to better keep their balance while on the move and significantly reduce injuries from slips, trips and falls. But this has to emanate from leaders opening their mental vistas to provide for workers’ learning the right skills for becoming more in mental and physical control of their own safety. Ultimately, real attention to highest-level Safety begins with leaders.

Robert Pater is managing director and founder of Strategic Safety Associates/MoveSMART®, www.movesmart.com.

Attentionally Avoiding Traps – and Trips

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http://www.movesmart.com


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