OSH Magazine

BREAKTHROUGH STRATEGIES: ATTENTIONALLY AVOIDING TRAPS AND TRIPS
MARCH 2015
VOL. 84 NO. 3 | www.ohsonline.com
HEARING PROTECTION:
Taming Workplace Noise 19
HAZMAT:
Head-to-Toe Protection 28
PROTECTIVE APPAREL:
Disposable Secondary
FR Garments 32
Testing & Maintaining

Fire Protection Equipment
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FROM THE EDITOR
Recognizing
Real Progress
www.ohsonline.com
VOLUME 84 NUMBER 3
EDITORIAL STAFF
oe Main, head of the Mine Safety and Health Administration, gave a speech in late January in which he summarized how much mine safety in the United States has
improved during the past five years. Speaking at the
West Virginia Coal Associations 42nd Annual Mining Sym- U.S. mining deaths
posium in Charleston, W.Va., he said mining deaths fell from fell from an average
an average of 96 to 45 per year during the first half of this of 96 to 45 per year
decade, and that 16 coal miners died on the job during 2014, during the first half of
which was the lowest number ever recorded for the industry
this decade, MSHA
in the United States.
Main said compliance also has improved, with total cita- chief Joe Main said.
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 underground coal mines have fallen to new lows since 2009, when MSHA launched its End
Black LungAct Now campaign, he said, and he touted the benefits of recently enacted
rules to prevent coal dust explosions and require proximity detection devices on continuous 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. MSHAs 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 equipment, and to provide and wear PPE.
JERRY LAWS
jlaws@1105media.com
Occupational Health & Safety (ISSN 0362-4064)

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Occupational Health & Safety | MARCH 2015
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Jerry Laws
EDITOR
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2/9/15 3:42 PM
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TABLE OF CONTENTS
MARCH 2015 | Volume 84, Number 3 | www.ohsonline.com
40
The Evolution of FR Denim

Todays workers are looking for the fits, features, and finishes
of retail-ready denim but with proven flame-resistant protection. by Craig Tutterow and John Strickland
44
Durable Flame Resistance:

Comfort and Quality
Real-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
48
features
JUSTIN KRAL/SHUTTERSTOCK.COM
LOCKOUT/TAGOUT
51
HEAT STRESS & THIRST QUENCHERS

10
16
Reducing Heat Stress with HVLS Fans

High-volume, low-speed fans help cool off employees and
improve efficiency. by Dan Anderson
Maintaining Body Temperature in
Extreme Conditions with FR Garments
By 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
Addressing Noise in the Workplace
One 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 Injuries
Preventing occupational head injuries starts by following the
hierarchy of controls. by Jerry Laws
HAZMAT
28
Hazmat Protection from Head to Toe

True 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 Garment
Clearly, 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
0315ohs_006_TOC_v2.indd 6
Technology to the Rescue

LOTO technology can create a safer workplace and
make compliance more efficient. by Darcie DaSilva
and Steve Burgess
TRANSPORTATION SAFETY
54
DOTs Lithium Battery Final Rule Takes Effect

Now, 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
HEARING PROTECTION
19
Implementing a Fire Protection Inspection,

Testing, & Maintenance Program for
Water-Based Fire Protection Equipment
History has shown that some of the largest industrial
fires have occurred when systems were out of service,
or impaired. by Walter S. Beattie
Machinery Safety Survey Results:

Safety Interlocks and Used Equipment
It 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
departments
4
8
60
61
62
64
64
65
66
From the Editor

Newsline
New Products
Practical Excellence
by Shawn Galloway
Product Spotlights
Product Literature
Classifieds
Advertiser Index
Breakthrough Strategies
by Robert Pater
Find OHS on:
Twitter
http://twitter.com/OccHealthSafety
Facebook http://facebook.com/ohsmag
Safety Community http://www.safetycommunity.com/
profile/OHSMagazine
www.ohsonline.com
2/9/15 3:42 PM
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To order or to get more details, call (800) 421-0668,

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NEWSLINE
On the Move
Haws Corporation announced four new
team members and four internal promotions in December 2013: Per Lindvall
joined as managing director-Asia Pacific, Lynda
Murdock as human resources manager, Brandon Siri as digital marketing manager, and Arthur
Salas as Haws Integrated
production
supervisor. PER LINDVALL
Those promoted include
Michael Joyer to research & development
manager, Theresa Auld
to director of human resources, Stephanie Kilroy to human resources
program manager, and
Daniel Page to assistant
production
supervisor.
. . .SHOWA has named MICHAEL JOYER
Shuji Kondo as its Americas president and COO, the company announced Jan. 5. He replaces Bill Alico, who
remains on the companys board of directors and serves as a strategic adviser. Also,
Charles Miller has been appointed Americas vice president of sales and marketing after 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 generation of visionary leaders, Alico said. Kondos 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 directors. He is a registered professional engineer 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 Oklahoma Corporation Commission (OCC)
and had been deputy director and assistant
8
director for environmental services in the

Oil and Gas Division of the Railroad Commission of Texas prior to that. . . . Health
Conservation, Inc., which is based in
Rockford, Ill., and provides mobile audiometric 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 Systems 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. Morgan 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 president 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 salesUSA/Canada; Rick Kreczmer to director, aftermarket 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 previously was senior vice president, Strategy
and Business Development.
Business Moves
Bloomfield, Conn.-based Kaman Corporation 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 employees of Delamac for their commitment
and service to Kaman and believe the new
0315ohs_008_Newsline_v2.indd 8
www.ohsonline.com
ADVISORY BOARD
Leo J. DeBobes, MA (OH&S), CSP, CHCM,
CPEA, CSC, EMT
Stony Brook University Medical Center
Stony Brook, NY
Scott Lawson
The Scott Lawson Companies
Concord, N.H.
Angelo Pinheiro, CSP, CRSP, CPEA
Senior HES Professional
Marathon Oil Company
Houston, Texas
William H. Weems, DrPH, CIH
Director, Environmental & Industrial Programs
University of Alabama College of Continuing Studies
Tuscaloosa, Ala.
Barry R. Weissman, MBA
Principal
Weissman Consultants
Piscataway, N.J.
Henry Wright, MBA, CFPS
Senior Vice President & Director Risk Solutions
BB&T Insurance Services Inc.
Charlotte, N.C.
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 Environmental Health and Safety from Missouri
Southern State University in Joplin, Mo.,
recently joined the Institute for Safety and
Health Managements Board Approved Degree 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 semester hours of management-exclusive
safety courses. A student earning a BS in
EHS from Missouri Southern is automatically qualified for the institutes 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 programs from 12 other higher education institutions in Alabama, West Virginia, Kentucky, Pennsylvania, Wisconsin, Michigan,
and Texas. For more, visit www.ishm.org.
www.ohsonline.com
2/9/15 3:43 PM
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Reducing Heat Stress with HVLS Fans

High-volume, low-speed fans help cool off employees and improve efficiency.
RITE-HITE FANS
BY DAN ANDERSON
xtremely hot weather has always presented

problems for industrial facilities, but never
more so than today. Excessive heat issues can
directly affect an organizations 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 temperatures on the rise, and several high-profile lawsuits
in the publics consciousness (and case law books),
facility managers are facing a perfect storm of heatrelated issues this summer. Fortunately, there are several ways to address this issue.
Types and Causes of Heat Stress
Heat stress can manifest itself in a variety of forms.

While some are less severe than others, all are potentially dangerous. The mildest form are heat fatigue, in
which workers begin to lose concentration and perform erratically, and heat rash, which occurs when
sweat ducts get plugged and skin becomes agitated
and painful. People whove 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
10
0315ohs_010_014_Anderson_v3.indd 10
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 occur 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 bodys 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 convulsions. 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,
www.ohsonline.com
2/10/15 10:05 AM
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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 categories, 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 Control
Warehouses and loading docks are inherently dangerous and fast-paced environments, 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-conditioned, while most dock staging areas are
expansive spaces with tall ceilings, making
them hard to cool even if they are air-conditioned. 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 annual 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 fulfillment employees to work faster than ever.
The fast pace of online retailer operations
has had a ripple effect on consumer expectations 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 pushback, complaints, and high-profile lawsuits
in recent years, there is no reason to think
this trend will change.
Higher Temperatures =
More Mistakes, Legal Exposure
An uncomfortably hot warehouse and

loading dock not only lowers the morale of
employees, it can make them less efficient.
Its 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 temperatures rise to 85 degrees F, worker output drops by 18 percent and errors increase
by 40 percent.
While OSHA does not have specific
regulations for indoor workplace temperatures, the agency recommends a temperature range between 68 and 76 degrees.
Twenty-five states have adopted OSHA-approved plans for compliance with and enforcement 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 Stroke
There are a number of ways facilities managers can address heat stroke issues. From
a physical standpoint, water breaks should
be encouraged, along with consumption of
electrolyte-enhanced sports drinks. Workers moving from a cooler part of the plant or
coming back to work after time off should
be given time to acclimate to their conditions with unit-output requirements gradually 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 imme12
Circle 37 on card.
www.ohsonline.com
2/10/15 10:05 AM
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 production equipment. Insulated curtain walls
provide up to 40 degrees of temperature
separation and can be installed in custom
configurations and moved when building needs, or seasons, change. High-speed
doors, which can operate at up to 100 inches 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 Heat
While adding air-conditioning to a distribution center is the best-case scenario, it

isnt always practical due to cost considerations 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. According 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 disruptive and provides little, if any, added cooling benefit.
The advantage of HVLS fans is their
ability to move large volumes of air and create a steady, light breeze. When the breeze
reaches people during the warm months, it
creates an evaporative cooling effect and reduces the effective temperature by 10-12 degrees F. To put this in perspective, the effective 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
www.ohsonline.com
can replace as many as 10 to 20 floor fans,

reducing clutter on the ground and lowering 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 allows up to a 5 degree F increase in the AC
systems thermostat setting with no change
in employee comfort.
Considerations for HVLS Set-up
There are a number of factors to consider

when deciding how and when to use HVLS
fans. They include obstructions such as pallet 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 further 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 buildings where overhead obstructions preclude
the use of the traditional ceiling-mounted
HVLS fans.
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Circle 6 on card.
13
2/10/15 10:05 AM

Fan suppliers can help configure an array 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 resources are not available. While the basic
concept is similar across all HVLS fan manufacturers, fan design and performance are
key factors to consider. There are significant
differences between manufacturers, including the shape and number of blades, blade
tilt, hub construction, blade-to-hub connection, and safety features. The performance 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 fans diameter.
Other important considerations include ease of installation, fan controls, local
representative support, trial program availability, and warranties.
The use of HVLS fans has gained increased attention as a practical and affordable 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
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14
Circle 15 on card.
company
engineers control energy costs and improve

employee comfort and productivity. Capitalizing on the advantages of HVLS fans requires careful analysis of each application,
as well as each HVLS fan design.
Creating a more comfortable, healthier
workplace clearly signals that a companys
management is willing to invest in employees and is serious about their safetyas
well as the accuracy of the shipments it
sends to its customers. All can have a direct
and significant impact on the organizations
bottom line.
Case Study: HVLS Fans in Action
Indiana 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 plants 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 plants 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 Indiana subsequently installed three 24-foot
diameter fans of its own.
Dan Anderson, Rite-Hite Fans product
manager, has more than 25 years of experience in warehouse safety. He started working for Rite-Hite in 1995 and became product 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.
www.ohsonline.com
2/10/15 10:05 AM
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Untitled-1 1
CIRCLE 39 ON CARD
2/4/15 4:51 PM
HEAT STRESS
Maintaining Body Temperature in

Extreme Conditions with FR Garments
BY CORTLANDT MINNICH
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 stresswhich is commonly experienced by
workers exposed to extreme heatcan result in heat
stroke, heat exhaustion, heat cramps, or heat rashes.1
In fact, the U.S. Bureau of Labor Statistics (BLS) reports 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 factors, 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 temperature. Just as choosing the right clothing makes a difference when exercising, it is also a key factor in regulating temperature while working in a physical role.
This is why it is essential to consider how the company
uniform can affect a workers 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 comfort 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 samples on specially designed plates that simulate hot,
sweaty skin under controlled lab conditions, the ability of the fabric to transfer heat can be precisely measured. 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 physical activity may face discomfort, physiological strain,
decreased productivity and performance, and potentially increased accident rates on the job.4 A uniform
with better performance can have some level of impact on these challenges.
16
0315ohs_016_018_Minnich_v3.indd 16
Considerations for FR Garments

in Hot Environments
When specifying PPE clothing, incorporating THL

performance should be taken into consideration.
THL is a measurement that combines the performance of several fabric properties, including air permeability and moisture wicking. Certain PPE garments 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 fabrics 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 modifications to the prescribed equipmentaffecting 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 Environments
Just as garments affect body temperature in hot conditions, 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 appropriate 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 insulation will cause overheating and accompanying sweat.
This moisture is one of the biggest challenges for comfort in a winter clothing system. Just as in hot conditions, 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: Layering
Factors to consider when specifying FR garments

www.ohsonline.com
2/9/15 3:44 PM
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CIRCLE 9 ON CARD
Untitled-2 1
2/2/15 11:10 AM
HEAT STRESS
in cooler locations include the temperature and humidity of the environment,
the level of physical activity, wind, break
cycles, and the workers 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 sweating. 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 sweating, 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 industries to FR protection and compliance with
2112 and 70E, especially in winter. Garments that are not FRespecially heavyweight versionare 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. Additionally, many non-FR winter base-layers
are made from Polypropylene and blends
that contain Polyester. Both of these materials 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, nylon, polyester, polypropylene, and spandex
shall not be permitted in fabric underlayers
(underwear) next to the skin.
Implications for Safety Managers
FR garments should be assessed not only

for their comfort, but also for how well they
can contribute to the safety and productivity 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 garments 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 customize their personal uniform using garment layers, the better the chances they will
remain compliant.
Cortlandt Minnich works in Business Development for the TECGEN Brand. Visit http://
industrial.tecgen.com/ for information.
REFERENCES
1. Centers for Disease Control and Prevention
2. Bureau of Labor Statistics
3. Fire Engineering
4. Extreme Physiology & Medicine
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18
Untitled-2 1
0315ohs_016_018_Minnich_v3.indd 18
www.ohsonline.com
2/5/15 10:48 AM
2/9/15 3:44 PM
HEARING PROTECTION
Addressing Noise in the Workplace
One 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
MOLDEX-METRIC, INC.
xcessive noise levels are found in many workplaces and can cause problems other than just
hearing loss. They also can create dangerous
situations, such as an inability to hear warning signals, a decline in ones ability to communicate
with fellow employees, and a decrease in ones 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. However, engineering and administrative controls are not
always possible, and therefore hearing protection devices may be needed to properly protect employees.
There are many occupational noise sources. They
include, but are not limited to, manufacturing equipment, power generators, use of motor vehicles or heavy
www.ohsonline.com
0315ohs_019_022_Birkner_v2.indd 19
equipment, aircraft noise, hammering, jackhammering, 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 employee. 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 Strategies
Determining 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.
MARCH 2015 |
Occupational Health & Safety
19
2/9/15 3:45 PM
HEARING PROTECTION
Properly evaluating the problem requires a
qualified professional to perform the
measurements and analyze the results.
Controlling the problem.
Recognizing the problem can be as simple as being unable to
properly communicate with another worker a few feet away. However, 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 professional to perform the measurements and analyze the results. For general 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 administrative controls, engineering controls, or hearing protection devices. 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 protectors must be worn. There are many situations when the only practical 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 devices, wearing hearing protectors might seem like a nuisance. Use
of hearing protectors can preserve an employees hearing when
noise cannot be engineered out of the workplace. The most common complaints by employees are that the protectors are uncomfortable, 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
Circle 22 on card.
1
20 Untitled-2Occupational
Health & Safety | MARCH 2015
2/3/15 10:58 AM
www.ohsonline.com
2/9/15 3:45 PM
Create a
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CIRCLE 12 ON CARD
Untitled-4 1
2/3/15 12:15 PM
HEARING PROTECTION
Many work sites are predominated by low frequency
noise. Ear muffs can be very helpful in these types
of environments.
employees hearing. These objections can be overcome by implementing 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 characteristics 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 Selection
Many types of hearing protectors are available to meet employee

needs in terms of both compliance and user acceptance. For example, ear plugs have varying NRRs for different situations and come
in many different colors and shapes. Selecting an appropriate device that does not overprotect the user can alleviate concerns about
not being able to hear warnings and fellow employees. Adequate
26+$
training and allowing the employee to get used to the device also
can help.
Choosing the right hearing protector requires careful consideration. 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 successful program is to get employees to feel like they are being included 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.
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www.ohsonline.com
2/9/15 3:45 PM
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CIRCLE 8 ON CARD
Untitled-5 1
1/29/15 1:46 PM
Preventing Occupational and Non-Occupational Head Injuries
Preventing occupational head injuries starts by

following the hierarchy of controls.
BY JERRY LAWS
ZELFIT/SHUTTERSTOCK.COM
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 workplace 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 Injury Response in CDCs 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 problem, with about 580,000 people with TBI diagnoses
dying during that decade.
Key Mandatory and Consensus Standards
OSHAs 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
24
0315ohs_024_026_Headface_v2.indd 24
or face hazards from flying particles, molten metal, liquid 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 incorporates 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 equipment with filter lenses that have a shade number appropriate 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 consensus standard, which are incorporated by reference. In
fact, the current edition is ANSI/ISEA Z87.1-2010, approved by ANSI in in April 2010. A significant change
in the 2010 edition was its focus on the hazardimpact
from flying fragments or particles, chemical or molten
metal splash, hot sparks, dust, optical radiation, fine
dust particlesrather than the type of protector.
ISEA announced Jan. 27, 2015, that it is accepting comments from stakeholders and the public on a
proposed update to Z87.1-2010. According to ISEAs
release, specific proposals include testing of protectors 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, ISEAs director of member and technical services, at cfargo@safetyequipment.org.
The head protection section requires employers to:
Ensure that each affected employee wears a protective 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 conductors that could contact the head.
Ensure that the head protection PPE being used
complies with ANSI/ASSE Z89.1-2009, American National Standard for Industrial Head Protection, or the
www.ohsonline.com
2/9/15 3:46 PM
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CIRCLE 31 ON CARD
Untitled-4 1
2/3/15 2:16 PM
JUST BECAUSE WE DIDNT

START THE FIRE, DOESNT MEAN
WE CANT PUT IT OUT.

2003 or 1997 editions of that consensus
standard, which, again, are incorporated by
reference. This standard establishes requirements for industrial head protection relating to impact protection, penetration protection, and electrical insulation protection.
Head Injury Prevention
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Circle 19 on card.
0315ohs_024_026_Headface_v2.indd 26
Preventing occupational head injuries

starts by following the hierarchy of controls. There is no one hierarchy of controls that all health and safety professionals agree upon, but most are similar to the
hierarchy found in the American National
Standards Institutes (ANSI) and American
Industrial Hygiene Associations ANSI/
AIHA Z10-2012 Occupational Health and
Safety Management Systems standard,
which has six levels, starting with elimination, substitution, and engineering controls
in the higher levels and ending with warning systems, administrative controls, and
personal protective equipment (PPE) in the
lower levels, Matthew OConnell, 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 conducted several studies that looked at applying an assessment of safety risk in the
hiring process of a number of industries.
What these found is that fewer than 10 percent of employees accounted for a disproportionate percentage of work-related injuries. As part of a systematic approach to
safety management and risk reduction, its
clear that the identification and removal by
selection of high-risk individuals in a scientifically valid and legally defensible way
before they step onto the work site might
be one of the most cost-effective solutions
available, OConnell 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 composure and are likely to do something that
puts them or others into harms way.
(2) Aware of Surroundings. The second factor focuses on the individuals
awareness of his or her environment. Incidents often occur not because of overt actions such as taking shortcuts, not wearing
proper protective equipment, or behaving
in an unsafe manner, but because the individual 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 others. Those who are not are more likely to
increase their level of exposure by not following safety rules that they feel do not apply to them or are not important.
(4) Exhibits Caution. The fourth and
final factor focuses on the individuals proclivity 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-occupational 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 alcohol or drugs; wearing a helmet when playing contact sports, skiing or snowboarding,
or riding a bicycle or motorcycle; and taking 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.
REFERENCES
1. http://www.cdc.gov/mmwr/preview/mmwrhtml/ss6005a1.htm?s_cid=ss6005a1_w
2. http://www.merckmanuals.com/home/
injuries_and_poisoning/head_injuries/overview_of_head_injuries.html
3. http://www.bls.gov/iif/
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2/9/15 3:46 PM
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CIRCLE 18 ON CARD
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2/3/15 4:27 PM
HAZMAT
Hazmat Protection from Head to Toe
True hazmat gear must provide protection to

the entire body.
BY JIM TOWEY
rom health care workers fighting Ebola to the

main characters in Breaking Bad, the typical yellow hazmat suit has become a familiar
media image portraying dangerous work environments. 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, decontaminate it, and dispose of it properlywhether it is for
Ebola or any other hazardous event. As a result, many
manufacturers of hazmat protective gear have reported an increase in sales to consumers and businesses
alike. According to a report on CNBC, Amazon experienced a significant increase in full-body suits and
masks during this period.
The U.S. Department of Homeland Security defines a hazmat suit as an overall garment worn to protect 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 positivepressure, 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 component 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 Technical 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 Hazardous 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 resistance, 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 addresses 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
FOUR LEVELS OF HAZMAT PROTECTION
Level 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 chemicalresistant 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 Protection
Although comfort is not an NFPA-regulated 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 comfortable 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-resistant material. It is also important for
footwear to have a smooth surface for easy
cleaning and decontamination.
Four Levels of Hazmat Protection

Hazmat Equipment Needed
Level A
Hazmat suit - gas-tight, positive pressure
SCBA
Level B
Level C
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
Level D
Coveralls
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 degradations 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 component in providing complete safety for
emergency responders, health care workers, 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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PROTECTIVE APPAREL
Disposable Secondary FR Garments:

What Really Matters When Selecting a Garment
Clearly, 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
ost of our standards and test methods for flash fire and barrier/chemical
protection deal with these two hazards discretely, as if they occurred in a
vacuum. It is little wonder, then, that end users and
many manufacturers tend to evaluate garment performance against these hazards in the same manner.
Unfortunately, designing garments for use in multihazard environments, especially where flash fire or
flame is concerned, is not quite so simple. An event
where both hazards, flash fire and chemicals, are encountered simultaneously can have a drastically different result for the end user than if the hazards were
encountered individually. The use of disposable garments over thermally protective garments (TPGs) is
a classic example.
As the use of thermally protective garments increases 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 barrier 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 decisionmaking process is not so simple because of our predilection 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 secondary 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
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0315ohs_032_038_Roberson_v3.indd 32
cite a standard that was changed in 1996 and is no longer 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
garments 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 intended 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 barrier to water and some light sprays of liquid chemicals,
as evidenced by its ability to attain CE Type 6 classification. 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 polypropylene 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
wearers ensemble becoming a reservoir for flammable 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 underneath it, compromising the thermal protection otherwise provided by the TPG.
The same is true for garments made of hydroentangled woodpulp/polyester fabric. The woodpulp
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PROTECTIVE APPAREL
LAKELAND INDUSTRIES
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--especially 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 Hierarchy
Clearly, the addition of a flash fire or flame

hazard to a scenario involving dry or liquid
chemicals can significantly complicate protection. 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 impingement on combined TPG and disposable
Photo 1. ISO 6530 test equipment with multiple layers of fabric clamped to gutter.
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 combination 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-
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F L I G H T

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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 inch behind the fabric swatches (spaced).
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 otherwise. A significant component of this analysis should be the establishment of a protection 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 protection. This statement establishes the hierarchy for the hazards for which these garments 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
2015 IHOP Restaurants, LLC.
OHS2015
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Uniting Comfort & Safety
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PROTECTIVE APPAREL
that the disposable garment does. Therefore, barrier is the primary
function of the disposable, provided it does not prevent or compromise 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 secondary FR garments, end users first need to determine whether the
garment provides the barrier or other protection that is not provided 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 disposable 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 process 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 exposure 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 samples 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 comparing the total calories of heat energy that passes through the ensemble 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 secondary FR garment, combined with a flammable liquid, will compromise 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 protective 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 relative 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 standardswriting organizations globally. He has worked with disposable secondary FR fabrics since 1994 and has developed several fabrics within this product category. He holds a U.S. patent for that work.
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G
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The performance of protective apparel
starts before the garment is sewn. It begins

with the fiber from which the garment is made.
Protex is an inherently flame retardant fiber
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PROTECTIVE APPAREL
The Evolution of FR Denim

BY CRAIG TUTTEROW AND JOHN STRICKLAND
ack in the mid-1800s, the news of gold being found brought more than 300,000 goldseekers 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 its black
gold. The increase in U.S. oil and gas production in
during the past decade is proving to be another catalyst for denim, and this time it includes flame-resistant 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 significant 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, quarrying, 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 workroom to the boardroom have led to the rise in the
number of fits and finishes available. According to several surveys, the average American owns seven pairs
of jeans, which means that variety is a very important
factor when it comes to jeansincluding those worn
for protection from flash fire and electric arc flash. But
just because someone is wearing FR denim doesnt
mean that he has to look as if hes just stepped out of a
1970s catalog. Todays 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 Garments 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
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0315ohs_040_042_Tutterow_v2.indd 40
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
fabricsand therefore making it worthy of consideration in your companys 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 flameresistant 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 create these effects should be tightly controlled to maintain 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 fashion 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 doesnt sacrifice the durability and longevity
of the FR protection. Consider flame-resistant denim
that is mechanically softened with open width, continuous 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 wont 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, particularly 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 bilateral flex, which allows them to elongate sideways
and diagonally. This eliminates any sagging or bagging 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 enhance 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
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PROTECTIVE APPAREL
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 Garments
Many producers of FR fabrics guarantee the flame resistance for

the expected life of the garment, as long as the recommended laundering 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 protection thats 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 flammable 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 peroxide), either alone or in combination, must not be used on FR
treated fabrics. Repeated exposure to bleach will damage the flameretardant 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 detergent 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 wasnt 100 percent produced
here. In addition, if the fabric wasnt 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 chemistry and product development and engineering. Contact him at
craigt@mvmills.com.
John Bud Strickland is the director of denim product development for Mount Vernon FR. He has 40 years of textile industry
experience. Contact him at johnst@mvmills.com.
AIHce
+ SALT LAKE CITY, UTAH
May 30 June 4, 2015
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PROTECTIVE APPAREL
Durable Flame Resistance: Comfort and Quality

Real-world applications have brought on an increasing demand for garments that are suitable
for use in environments with multiple hazards.
BY THOMAS KIDDLE
CARHARTT, INC.
here are three basic uses for industrial flameresistant clothing:

1. Flash fire exposures: This apparel is
needed by workers in refineries and for combustible 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 exposed to a flash fire. Durable flame resistance is critical, 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 wildland firefighting typically require inherently flame-
44
0315ohs_044_046_Kiddle_v2.indd 44
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 inherently 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 designed 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 marketplace that creates concern about whether the flame
resistance can be washed out of treated fabrics. Its
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 potential hydrocarbon flash fire and potential arc flash
environments without ever having an incident.
Understanding the need for comfortable FR protective 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 resistant 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 increase the wear life, thus making the FR cotton/nylon
more durable than simple treated cotton.
The Importance of ASTM F1506

and NFPA 2112
Previously it was common to have garments marketed 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
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PROTECTIVE APPAREL
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.
effective, practical, and to keep employees
comfortable, real-world applications have
brought on an increasing demand for garments that are suitable for use in environments with multiple hazards.
Over time, NFPA and ASTM developed
washing requirements and a battery of tests
to ensure that treated cotton fabrics maintained 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 development of multi-hazard PPE products can
save employers money while keeping the
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0315ohs_044_046_Kiddle_v2.indd 46
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worker protected and even more comfortable. In light of this, many companies require 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 certified 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, comfortable 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 capitalized 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 additional benefits through technologies such as
sweat-wicking, anti-odor, or durable water
repellent (DWR).
Additionally, theres 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 proliferation of improved flame-resistant fabrics
and styles on the market today, comfort
and protection are no longer a compromise. Employers and their crews now have
many choices, and as long as the fabrics
whether treated cotton or inherentmeet
the testing standards described in this article and the garment laundering/care instructions 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 Carhartts non-traditional
sales channels, including Industrial Sales,
Discount Sales, Wholesale.com, and Inside
Sales. He joined Carhartt in 2001 as the director of Carhartts Industrial Sales Division
and previously was the business group manager for Bullard.
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FI R E
S AFET Y
Implementing a Fire Protection Inspection,

Testing, & Maintenance Program for
Water-Based Fire Protection Equipment
History has shown that some of the largest industrial fires
have occurred when systems were out of service, or impaired.
By Walter S. Beattie
JUSTIN KRAL/SHUTTERSTOCK.COM
any corporations require

that all of their facilities be
provided with automatic
sprinkler protection to protect their employees and preserve corporate assets. Municipalities may also require facilities within their jurisdiction to
be provided fire protection systems, such
as sprinklers, alarms, and various special
protection systems to protect the community 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 fa48
cility, you, your fellow managers, and coworkers 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 during 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 primary standard in use in most companies
and municipalities is NFPA 25, Standard
for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems. NFPA 25 establishes the minimum
requirements for the periodic inspection,
0315ohs_048_050_Beattie_v2.indd 48
testing, and maintenance of water-based

fire protection systems. It is not an optimum 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 comprehensive program include:
Inspection: A visual examination
of a system to verify that it appears to be
in operating condition and is free of physical damage.
Test: A physical trying or operation 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 performed to repair and/or maintain equipment 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 contract. The building owner may elect to
outsource the ITM services to a sprinkler
contractor or other inspection, testing,
and maintenance service. When the service is contracted to others, the building
owner is typically the responsible party
who should be overseeing the work, reviewing 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 verified by actually operating and testing each
device on the system. Alarms will be verified from the devices to the alarm control
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Many facilities will need to respond to multiple

AHJs, and the most stringent requirements
generally prevail.
panel and from the panel to the alarm receiving company. In setting 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 Tasks
NFPA 25 states that a qualified person or company must perform 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 individual responsible for enforcing the requirements of a code or standard 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 Program
Many 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 systems. 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 especially pay off when an emergency situation arisesthere will be
expertise available to respond immediately. Your facility emergency 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 Program
Management has many financial challenges in todays market.

To meet these financial challenges, many companies have reduced their employee payroll and outsourced many tasks. One
of the tasks outsourced is the inspection, maintenance, and testing of the fire protection and alarm systems. Outsourcing services 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
www.ohsonline.com
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 experience in the care required for the system. Selecting a competent
contractor that employs well-trained and quality people is important. 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 demonstrated 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 philosophies and culture. Their focus is solely on your fire protection 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 ITM
A good compromise for many companies is to develop a program 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 serious mishandling of the systems during an emergency situation
when they are most needed.
Using employees to perform daily and weekly visual inspections 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 inspections and some testing in house. Testing of inspectors test waterflow 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 contractors perform annual and five-year ITM. This incorporates
MARCH 2015 |
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2/9/15 4:08 PM
FI R E
in-house expertise that is immediately
available for questions or handling routine issues. In the event of an emergency
situation during working hours, there are
knowledgeable people on site to quickly
respond to the situation. Contractors provide additional expertise to ensure equipment 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 internal condition and functionality of the
equipment. Contractors have the equipment needed to perform testing, saving
the expense of purchasing hoses, fittings,
nozzles, calibrated gauges, and other testing equipment.
Documentation
Regardless of the ITM program you implement, 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 inspections 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 documentation system may be a paper system
or an electronic system that uses electronic 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 historical data to track any deterioration in the
equipments operational performance.
Impairments
History 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 suppression system is shut off or otherwise taken out of service, completely or in part.
While it is recognized that impairments
are necessary during testing, mainte50
S AFET Y
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, precautions must be taken to provide temporary protection, reduce hazards, and
ensure prompt restoration.
Your facilitys human element safety
program should include a comprehensive
written fire protection impairment handling program. The impairment program
outlines the measures to be taken before,
during, and after any impairment to ensure 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, especially hidden or unplanned impairments,
are found in properly inspected and wellmaintained systems. NFPA 25 devotes an
entire chapter to the handling fire system
impairments.
Additional Considerations
NFPA 25 addresses water-based fire protection systems such as sprinkler, standpipe 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 Signaling Code, as well as numerous other
NFPA standards.
Another very important consideration to be aware of is change. The property 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 adequacy 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 water supply. That is the role of the building
owner or his designated representative.
Conclusion
Whether your management opts to maintain your fire protection systems using inhouse employees, out-sourced contract
services, or a mixture of both, it is important 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) insurance field since 1979 in various technical
capacities and has extensive manufacturing process fire protection experience in
many industries. He was active in the volunteer fire service for fire, hazardous materials response team, and ambulance for
more than 30 years, holding line officer
and training positions; served as a principal member of several NFPA committees; and is an active member of American Society of Safety Engineers Council
on Professional Development and ASSE
Fire Protection Practice Specialty Advisory Committee. His website is http://
waltbeattie.com/.
Walter S. Beattie, Beattie Fire Protection & Risk Consulting
BIBLIOGRAPHY
National 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.
www.ohsonline.com
2/9/15 4:08 PM
LOCKOUT/TAGOUT
Technology to the Rescue
LOTO technology can create a safer workplace

and make compliance more efficient.
BY DARCIE DASILVA AND STEVE BURGESS
DCWCREATIONS/SHUTTERSTOCK.COM
ccording to the U.S. Bureau of Labor Statistics, up to 80 percent of injuries related

to servicing and maintenance of equipment
and assets can be attributed to not following simple lockout/tagout (LOTO) procedures. Additionally, LOTO is consistently listed in OSHAs 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 companies 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:
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0315ohs_051_052_DaSilva_v3.indd 51
1. It makes compliance easier and more efficient

than ever before.
It is estimated that at least 60 percent of companies 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
MARCH 2015 |
51
2/10/15 10:06 AM
LOCKOUT/TAGOUT
Automated scheduling helps ensure safety and compliance
managers dont miss required LOTO procedure audits.
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 compliance managers dont miss required LOTO
procedure audits.
The ROI for this new LOTO technology
investment comes down to this: How quickly can your team author, certify, and manage
all required LOTO procedures in your facility, 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 return 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 procedure, 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
workermaybe in his last week before retirementdoes 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 transparency 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 informedall 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 technology clearly documents every procedure to
seal off an isolation point, and when executed, 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 anyone 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 (ddasilva@mlock.com) is
a sales manager for Master Lock Field iD.
He has been with Field iD since 2011, moving 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 (sburgess@mlock.com) is
general manager, global sales and marketing
at Master Lock Field iD.
52
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TRANSPORTATION SAFETY
DOTs Lithium Battery Final Rule Takes Effect

Now, 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
COPRID/SHUTTERSTOCK.COM
s of Feb. 6, 2015, companies and manufacturers that ship and package lithium batteries must comply with a new final rule
on lithium batteries, formally known as
HM-224F. Originally published by the U.S. Department of Transportations Pipeline and Hazardous
Materials Safety Administration (PHMSA), this rule
represents a significant change in how lithium batteries 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 Organization (ICAO) Technical Instructions, the International
Maritime Dangerous Goods (IMDG) Code, and the
UN Model regulations. This means that U.S. companies will have to update training programs and comply with new labeling requirements.
Lithium batteries are unique in that they serve as
a reliable source of power for many different applications and devices. This source of power is also the reason why they are so heavily regulated; several significant incidents involving fires in cargo and passenger
aircraft have been caused by poor transportation of
lithium batteries.
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0315ohs_054_055_Holden_v2.indd 54
The Federal Aviation Administration has tracked

more than 50 lithium battery incidents in aviation
alone, encompassing both traveling passengers baggage 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 International 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 occurred 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
dont just occur while in flight; any time a device is being 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 companies 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 regulations, said Richard. Then they should get function-specific training, depending on what products
theyre handling. We like to make it very specific to
that company.
Richard said companies such as power tool companies ship all of their batteries packed into the tools, so
they dont have to worry about contained-in practices
and other techniques that dont 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 challenges because they might not be aware of some of
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2/9/15 3:54 PM
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 Logistics
A 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 without the correct labeling materials. Richard
advises his clients to provide consumers
with good information by designing safe
and compliant kits for returning items.
Its not only consumers; some companies have franchisees and distribution
centers, he said. Look at the auto industry. Weve developed hazmat courses
online at the dealership level that provide
them with kits.
Part of Richards process involves visiting individual companies in order to assess
their needs. Instead of making blanket assumptions about what certain industries
need, he can help companies apply techniques 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 better 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 Procedures
So what is it about the international regulations that make them seemingly superior 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 shipments properly, the carriers will reject
them. Fines and violations are always a
concern for businesses and manufacturers, but when the products arent getting
shipped, that reflects poorly on those businesses 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, simplified shipping names and UN numbers.
Under the previous regulations, shippers
needed to know the ELC of the batteries
being shipped, something that isnt necessarily easy to determine. Measuring watthours 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 numbers. One simplification is the use of the
same numbers for batteries that are contained 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 (mholden@1105media.com)
is an associate content editor for 1105 Media, Inc. He received his MFA and BA in
journalism from Ball State University.
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LOCKOUT/TAGOUT
Machinery Safety Survey Results:

Safety Interlocks and Used Equipment
BY GARY M. HUTTER
ver wonder if your approach, or your safety

managers approach, to safety is like others responsible for safety? Does your experience 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 professionals judgment? These areas
are explored based on the results of a survey of selfidentified safety professionals.
In fall 2013, the National Safety Councils 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 respondents to the computer-based survey, all of whom
were identified by the councils 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 professional judgment zone. Consultation with various occupational safety and health regulations, letters of
interpretation, and other publications could provide
more detailed and perhaps exact answers to the questions, 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 experience and good and poor workplace tradition.
Below is a summary of the results and a short discussion of these findings.
The survey was short, consisting of 11 questions
that typically requested yes/no responses, the frequencies of certain safety activities, and estimates of
accident-related events. There also was an opportunity for comments concerning the issues in the survey.
This author thanks all of those who participated.
Questions concerning machine safety, safety interlocks, 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
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0315ohs_056_058_Hutter_v2.indd 56
have all of the necessary safety equipment

the failure of an interlock causing and/or contributing to an injury
General Overview of Results
1. 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 indicated 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 indicated that occurred less than once per shift, about
39 percent indicated once per shift, and 9 percent indicated 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 indicated they would use an interlock in lockout/tagout.
6. Of the 111 respondents, 12 (~11 percent) indicated they knew of a safety interlock failure causing
an injury.
7. When queried on the purchase of used equipment, it was almost unanimous that they would expect that safety devices on the used equipment that
they acquire would be checked by their staff.
8. In addition, on used equipment, 97% of respondents indicated that they would not assume the reseller of the used equipment provided all the necessary
safety features.
Safety Interlock Definition
A safety interlock is a device or means that places a

machine or machine component into a zero, or substantially reduced, danger-mode upon intent to access; 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 Testing
The concept of interlocking for safety can be traced

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2/9/15 3:54 PM
back several decades, with perhaps electrical fuses and shear pins on power transmission shafts being two of the earliest widespread applications of some form of safety
interlock. While these two early forms of
interlocks did not necessarily prevent injuries, 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 occur. Properly designed pull back devices on
mechanical power presses prevented the
bad behavior of reaching into a cycling machine; properly designed two-hand control
would stop a part revolution clutch, making it safer if the operator detected a possible 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 interlocks 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 return devices (e.g., springs, gravity, counterweights) 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, preventing gravity from resetting the interlock.
Verification of the performance of safety
interlocks did not guarantee future performance but provided an opportunity to
correct malfunctioning safety mechanisms,
potentially before an accident.
In the 1960s and 1970s, the patent history 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 detection means). These devices may not have
had the same mechanical switches, alignment, and/or jamming considerations of
the prior generation of mechanically activated switching mechanisms, but they, too,
require some sort of functional testing. For
example, many providers of light curtains
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specify intervals for functional testing of

their performance and coverage. Rockford
Systems (a provider of safety hardware and
training) publishes a checklist for light curtain installations that states: Light curtains
should be function-tested at every set up, operator 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 interlock 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 configurations and/or for the newer invisible detection means often actually simulating behaviors 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 difficult 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 exercising 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 longevity 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 electronic circuits3, movable safety interlock
mounting elements to simulate operation
without human involvement4, and/or mechanical redundancy and hardware5. There
has been some criticism6 of the reliance on
these attempts of self-checking as manifested on interlocks in the form of redundancies, interlock bypasses, and/or negative vs.
positive failure mode monitoring7.
Regardless of the frequency of exercising and/or testing of safety interlocks, most
of the subsequent results can only monitor
past performance and often have little ability 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 functioning 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 Standards
Various codes and standards include safety

interlock criteria. American National Standards Institute standards and National Electrical 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 ensure the integrity and performance of control circuits (e.g., interlocks):
Medium Risk Potential Any exposure
to serious injury. A dual channel circuit of
industrial rated components that is selfchecking or monitored through the use of a
safety relay or safety PLCs 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 interlocks: A monitoring device shall be provided 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 interlocks and devices.
More recent International Standards
Organization (ISO) standards and criteria
have begun to more specifically address
these issues of testing equipment-mounted 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 Rockford Automation summary of that standard
states: Designated Architecture Category 2
must use basic safety principles {see index
MARCH 2015 |
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2/9/15 3:54 PM
LOCKOUT/TAGOUT
of EN ISO 13829-2}. There must also be diagnostic 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 frequency of testing somewhat poorly defined,
and this was confirmed through contact
with one of the major interlock suppliers,
who referenced ISO 13489, section 4 (design of safe machine control systems). That
standard, for example, discusses a Category 2 interlock architecture, para 4.1.3,
wherein The periodic test interval is depending on the application. . . . The checking
interval can be established or based on the
operating cycle or the machine cycle. It is important that the interval is suitable for [the]
application. The checking interval needs to
be evaluated/determined during the risk assessment for the application.
For the above considerations, interlocks
should be exercised and/or checked (monitored) 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 Compliance
The concept of control of hazardous energy focuses on the elimination or control of hazards and hazardous energy for
maintenance and certain servicing operations. 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 control 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 disconnected from all electric energy sources.
Control circuit devices, such as push buttons,
selector switches, and interlocks, may not
58
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 Safeguarding Equipment and Protecting Employees from Amputation, OSHA 3170-02R,
2007: Interlock control circuitry may not
be used for all maintenance and servicing
work10 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 components 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 Equipment
The terminology Used Industrial Production Equipment may have multiple connotations to different user groups. When we
as non-industrial equipment purchasers go
and buy a used car from a used car dealership, we generally expect that it is in reasonably good shape from a safety perspective. This does not mean that if we purchase
a 1964 car, we expect it to have seatbelts
(having been made prior to the mandatory seatbelt requirement) or that even the
purchase of a 2012 car will assure us the
protection of airbags all around. But in either 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 expectations.
In an industrial setting, there are sellers 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 integrity 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 defined in the original questionnaire, it is
apparent that those responding generally knew that used industrial production
equipment may not have all the safety
whistles and bells, and therefore responded as they did in regard to checking and
evaluating safety items on this type of used
equipment.
Gary M. Hutter (mrhutter@earthlink.net),
P.E., Ph.D., CSP, is Principal at the consulting Firm, Meridian Engineering & Technology, Inc. (www.mederianeng.com), in Glenview, Ill. He is a National Safety Council
AMPS machinery safety committee member
and its current chairman.
REFERENCES
1. 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
Tools1990 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 Mechanism, 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 Acceptable Alternative to Lockout, W. Switalski, Triodyne
Inc., 9/2000
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PRACTICAL EXCELLENCE
BY SHAWN GALLOWAY
Lagging to Leading to
Transformational Indicators:
Measuring the Contribution of Value
easuring activities to determine the health of improvement efforts or culture tells you very little if
excellence is your goal. Excellence is not just zero injuries 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 continuous 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 particular, 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 shouldnt 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 doesnt mean causation, but this is forgotten with improved results: We had better performance and we were doing
these things; therefore, we had better performance because we were
doing these things. Sounds logical, doesnt 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 doesnt get me hurt
must be safe!
Alternatively, it is easy to become distracted when rates dont improve 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 improvement, 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 strategy 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 organizations evolved from measuring lagging indicators (their results)
to leading indicators (typically inputs and activities) to transformational 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 efwww.ohsonline.com
0315ohs_061_Galloway_v3.indd 61
fort. However, if you check your blood

pressure and it is high or has increased Problems arise
and you are making healthy eating de- when the rates
cisions and regularly exercising, the answer is rarely more diets and increasing improve. Most
exercise. You might need a different in- leaders know
tervention, as more is rarely the answer. correlation doesnt
Your blood pressure is a transforma- mean causation,
tional indicator that tells you the value
but this is forgotderived from your activities.
In both health and safety, we must ten with improved
all evolve to measure not just the results.
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 examples 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, believe 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 performance 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 transformational 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 Excellence 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 info@ProActSafety.com.
MARCH 2015 |
61
2/9/15 3:55 PM
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Untitled-10 1
0315ohs_062_063_ProdSpot_v4.indd 63
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CIRCLE #
COMPANY
PAGE #
1
Aerionics Inc.
www.macurco.com
11 AIHce 2015
www.AIHce2015.org
45 American Red Cross
www.redcross.org
44 Applebees
https://storefront.wgiftcard.com/applebees
12 Brady
www.bradyid.com/5SPlusguide
13 BullEx Digital Safety
www.bullex.com
14 CarbonX
www.carbonx.com/videogallery
8
Carhartt
www.carhartt.com
42 Columbia Southern University
www.ColumbiaSouthern.edu/OSHmag
16 Draeger
www.draeger.com
17 e-Hazard Management, LLC
www.e-hazard.com
6
Encon Safety Products
www.enconsafety.com/oshng2
19 Ergodyne
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18 Ergodyne
www.ergodyne.com
20 Gateway Safety
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21 GlenGuard FR
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22 Glove Guard
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15 GMI
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26 IHOP
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4
J.J. Keller & Associates
www.jjkeller.com
28 Larson Electronics LLC
www.LarsonElectronics.com
29 Little Giant Ladder Systems
www.laddersafetyhub.com
11
42
53
38
21
46
33
23
41
31
60
13
26
27
35
22
20
14
36
29
34
9
CIRCLE #
COMPANY
PAGE #
7
MCR Safety
www.mcrsafety.com
Metlon Corp.
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30 Moldex-Metric, Inc.
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31 MSA
www.MSAsafety.com
2
Newell Rubbermaid
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23 OH&S Online
www.ohsonline.com
32 Protective Industrial Products
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27 Protex
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46 Revco Industries
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33 SafeStart
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34 Salisbury by Honeywell
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5
SonicAire by IES
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3
Springfield LLC
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35 TecGen FR
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TenCate
www.tencateprotectivefabrics.com
36 TenCate
9
3M
www.3m.com/versaflo
37 Tingley Rubber
43 Tingley Rubber
25 Uvex by Honeywell
www.uvex.us/HydroShield
38 Waldorf College Online Programs Services
www.waldorf.edu/OS
39 Wolverine
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2
30
7
25
45
59
67
39
63
5
37
CIRCLE #
COMPANY
Product Spotlights
54 CarbonX
www.carbonx.com
61 Draeger
www.draeger.com
55 Ergodyne
www.ergodyne.com
57 Fibre-Metal
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56 Glove Guard
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58 Moldex-Metric, Inc.
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59 TecGen FR
www.tecgenfr.com
60 Wolverine
www.wolverine.com
53 Scaffold Training Institute

www.scaffoldtraining.com
Classifieds
43
50 Rutgers School of Public Health

http://ophp.sph.rutgers.edu
52 Specialized Safety Products
www.specializedsafetyproducts.com
51 VAC-U-MAX
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1
3
17
12
52
68
62
63
62
62
62
62
62
63
Product Literature
55
47
PAGE #
64
64
64
64
New Products
301 Ergodyne
300 GfG Instrumentation
302 Larson Electronics LLC
303 New Pig
60
60
60
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18
15
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0315ohs_065_AdIndex_v4.indd 65
MARCH 2015 |
65
2/10/15 10:07 AM
BREAKTHROUGH STRATEGIES
B Y RO B E R T PAT E R
Attentionally Avoiding
Traps and Trips
hen 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. Every 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 actually do. Understanding this, internal martial arts masters instruct
students to initially focus on affecting attackers perceptions: First
move their mind in order to move their body. Similarly, skid control trainers remind drivers to Stare, dont steer, into a turn. That
where you focus is where youll wind up heading (termed target
fixation in aviation.)
Turning attention toward preventing the persistent problems of
slips, trips, and falls, Im sure youve seen similar statistics over and
over again they dont 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 didnt result in impact)?
Further, no surprise, this issue affects companies wherever people walk, worldwide. For example, Great Britains Health & Safety
Executive reported that in 2013-14, falls and slips & trips accounted 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/reminders and footwear, the level of these injuries has still clearly been
holding steady at a dull roar. And, regrettably, there are some convinced 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 havent yet discovered 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, recalling 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 didnt notice we were holding our breath (raising tension and
sapping balance) when traversing an at-risk surface. Ive found that
a high-level ability to prevent slips, trips, and falls relies on being
66
0315ohs_066_pater_v2.indd 66
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 percent (!) of the brains energy output is used for maintaining balance
in space.
Stress is an additional factor, because it narrows vision/attention (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 its 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 shes been taught
because her minds 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 reestablishment of balance. 2) Sarcopenia, age-related loss of muscle
strength, means leg strength may no longer be adequate to compensate for slight unbalancing that can result in any misstep. 3) Vision 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 cant 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 youve not yet tried. However,
rest assured its 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.
www.ohsonline.com
2/9/15 3:57 PM
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Untitled-2 1
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Untitled-2 1
2/6/15 11:22 AM

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BREAKTHROUGH STRATEGIES: ATTENTIONALLY AVOIDING TRAPS AND TRIPS

VOL. 84 NO. 3 | www.ohsonline.com

Testing & Maintaining

mcr-03-15_WFR-OHS_Ad 1/28/15 4:39 PM Page 1

Thermal Garment Features:

FROM THE EDITOR

Occupational Health & Safety (ISSN 0362-4064)

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Occupational Health & Safety | MARCH 2015

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MARCH 2015 | Volume 84, Number 3 | www.ohsonline.com

The Evolution of FR Denim

Durable Flame Resistance:

HEAT STRESS & THIRST QUENCHERS

Reducing Heat Stress with HVLS Fans

HEAD & FACE PROTECTION

Preventing Occupation and

Hazmat Protection from Head to Toe

Disposable Secondary FR Garments: What

Technology to the Rescue

DOTs Lithium Battery Final Rule Takes Effect

Implementing a Fire Protection Inspection,

Machinery Safety Survey Results:

From the Editor

Find OHS on:

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Occupational Health & Safety | MARCH 2015

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HEAT STRESS & THIRST QUENCHERS

Reducing Heat Stress with HVLS Fans

xtremely hot weather has always presented

Types and Causes of Heat Stress

Heat stress can manifest itself in a variety of forms.

Occupational Health & Safety | MARCH 2015

back, arms, legs, and abdomen. Dehydration and

HEAT STRESS & THIRST QUENCHERS

Factors Affecting Heat Stress Control

of online retailing and overnight shipping

An uncomfortably hot warehouse and

Addressing Heat Stroke

diate impact, such as using fabric curtain