FRC Use Requirements

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A question arose about the proper way to wear Flame Resistant Clothing (FRC).

OSHA standards to do not specify how FRC is to be worn. OSHA has released a letter of interpretation specifying when and where Oil & Gas workers are required to wear FRC. This letter is available here. The legal requirements for how to actually wear FRC garments have fallen to the manufacturers.

In a recent blog, Bulwark came out with their recommendations on how to wear FRC. Bulwark’s recommendations include:

  • Wear garments that are large enough to have an air layer between the clothing and the body. This creates an insulation barrier to reduce heat transfer.
    • Overly loose garments can lead to injury from getting caught in machinery.
  • Only wear natural fibers underneath FRC. In a flash fire synthetic fibers underneath FRC can melt and cause injury even though the FRC functions properly.
  • Keep FRC clean. Any flammables on the clothing will still ignite when exposed to ignition sources.
  • Cover as much body surface as possible. All fasteners, such as buttons, zippers, snaps, and velco, need to be fastened. Shirts must be tucked into pants. Sleeves cannot be rolled up. The outermost layer of clothing should always be FRC.

Since Bulwark has released these recommendations, OSHA can enforce these requirements through their general duty clause.

Carhartt has also release recommendations for the use of FRC, including a recommendation to use FR thread for embroidering FRC.

Also, NFPA 2113 is the Standard on Selection, Care, Use and Maintenance of Flame-Resistant Garments for the Protection of Industrial Personnel Against Flash Fire. In this standard, 5.1.9 states:

” Flame-resistant or nonmelting undergarments (closest to the skin) shall be used. An incidental amount of elastic used on nonmelting fabric underwear or socks shall be permitted.”

NFPA creates voluntary consensus standards, so these requirements are not enforceable, but provide excellent guidance for companies with questions about using FRC.

*Unless specific citations are shown, all answers are based on interpretations provided by authorized officials. As such, all information is deemed reliable, but not guaranteed.