Quick Tips #190
Although there are no Occupational Safety and Health Administration (OSHA) standards that specifically address chemical protective clothing (CPC), 29 Code of Federal Regulations (CFR) 1910.132 and 1910.120 do apply
1910.132 addresses protective equipment in general, under 1910.132(a) it states:
"Application. Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact."
According to the Hazardous Waste Operations and Emergency Response (HazWoper) standard (29 CFR 1910.120) site-specific safety and health plans must address the safety and health hazards of each site operation and include the elements of protective equipment to be used.
The employer must assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of chemical protective clothing (CPC). OSHA mandates that personal protective equipment (PPE) like CPC be used only if the use of engineering controls and/or administrative work practice controls are not feasible or do not reduce employee exposures to acceptable levels. This is known as the OSHA “Three Lines of Defense” philosophy, a commonly used and understood practice within the safety community. For chemical situations, knowing the hazards includes being aware of the type of chemical, the physical state (liquid, solid or gas) and the physiological effect (toxic, carcinogen, asphyxiant, corrosive, etc.). Knowing the level of exposure is also important when selecting protective clothing and equipment. Since CPC is the last line of defense for protecting the skin, care must be taken to ensure it provides the protection expected.
To help users choose a total PPE package, OSHA offers guidance on determining the four levels of chemical risks. These levels are adopted from the Environmental Protection Agency (EPA) and give a range from unknown or highly hazardous, which requires complete protection, to non-hazardous, which requires only basic work attire.
Level A protective equipment provides the highest level of skin and respiratory protection available. This type of protection must be gas-tight, vapor-tight and splash resistant. It is worn when there is a possible threat to life and health, such as during spill response and cleanup.
The minimum Level A equipment consists of:
See Quick Tips #193: SCBA Information and Quick Tips #191: Chemical Resistant Gloves Guide for more information.
Level B protective equipment offers chemical splash protection, but does not prevent exposure to gases or vapors. As with Level A protective clothing, an SCBA is used for respiratory protection. The CPC may or may not be completely encapsulating, since a lower level of skin protection is required.
The minimum Level B equipment consists of:
Level C protective equipment features the same type of clothing as Level B, but has a lower level of respiratory protection. An air-purifying respirator is used in place of an SCBA. This level is used when the chemicals are known and it has been established that an air-purifying respirator is appropriate protection for the hazard.
Level D protective equipment offers the lowest level of protection and is used when no potential or actual hazard exists. It consists of a normal work uniform (long sleeve coveralls, safety shoes, goggles, etc.), offering minimal protection for nuisance exposure.
Additional information on the four protection levels is given in OSHA 29 CFR 1910.120 Appendix B.
After the appropriate level of PPE has been determined, the choice of CPC material must be considered. The key is identifying the suit material that provides adequate protection against the chemical(s) used. Two important factors in selecting the appropriate CPC are chemical resistance and suit design.
The effectiveness of the CPC to resist chemicals can be measured by permeation testing. Permeation testing produces three important data points:
The ASTM F739 method only tests a swatch of the actual chemical protective clothing fabric. This means that the potential for permeation through a zipper, seam, face shield, etc. is not determined.
Chemical resistance data is frequently published and available from many manufacturers and distributors. Unpublished data may be supplied by manufacturers upon request.
Suit design deals with how a garment is put together. Seams are an important aspect of suit design. Two pieces of material can be joined by stitching or welding. The stitching process can create pin holes that may allow penetration of chemicals. Welded seams involve cementing or welding tape over the stitched seam. The welded (sealed) seam offers a higher level of protection against exposure to contaminants.
Clothing protection level, chemical resistance and suit design are the primary factors used in selection of CPC, however, other factors that are sometimes overlooked that need to be considered are:
The National Fire Protection Association (NFPA) has performance manufacturing standards for CPC that aid in its selection.
NFPA 1991 (2016 Edition): Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies and CBRN Terrorism Incidents provides requirements for protection for emergency responders against adverse vapor environments during hazardous materials incidents and from specified chemical, biological, or radiological terrorism agents during chemical and biological terrorism incidents. Provisions cover design, performance, labeling, testing, documentation, and certification requirements for new vapor-protective ensembles and ensemble elements. Additional optional criteria for escape protection only from chemical flash fires encountered during hazardous materials incidents are also provided. A suit meeting NFPA 1991 requirements is equal to the clothing required by EPA's Level A.
NFPA 1992 (2012 Edition): Standard on Liquid Splash-Protective Ensembles and Clothing for Hazardous Materials Emergencies provides requirements for protection for emergency responders against adverse liquid splash environments during hazardous materials emergency incidents. Provisions specify design, performance, certification, and documentation requirements; test methods for new liquid splash-protective ensembles and liquid splash-protective clothing. Additional optional criteria for escape protection only from chemical flash fires encountered during hazardous materials incidents are also provided. Garments meeting NFPA 1992 requirements are equal to the clothing required in EPA's Level B.
NFPA developed these standards to provide users with information on suit integrity, resistance to chemicals and flame, durability, and function of components. Garments that meet the NFPA requirements are approved and marked with a Safety Equipment Institute (SEI) label.
Selection of CPC is not a simple task. The selection must include a thorough hazard assessment, a methodical review of the needs of the wearers in the field, a thorough familiarity of the chemicals being handled, and an understanding of the information found in manufacturer’s chemical databases which includes testing data points such as degradation, permeation, and breakthrough. Other things to consider are availability of the selected items, the manufacturer’s willingness to stand behind the product, the reputation of the manufacturer, the distribution system for the products, and of course the price.
Q: What is the difference between single-use, limited-use, and reusable chemical protective garments?
A: Single-use garments are intended for one-time wear. Limited-use garments can be worn until they are damaged, altered, or contaminated. Reusable garments can be worn multiple times as long as the suits have not become damaged during use (or if so, repaired), the suits have been completely decontaminated after use, and the barrier performance of the fabric has not been compromised. Determining whether or not a reusable garment has been fully decontaminated and that the contaminants have not altered the strength or protection capabilities of the garment can be a difficult decision.
Q: Whose responsibility is it to select the appropriate chemical protective clothing?
A: OSHA 29 CFR 1910.132 states that it is the responsibility of the employer to:
29 CFR 1910.120, Hazardous Waste Operations and Emergency Response
29 CFR 1910.120 Appendix B
29 CFR 1910.132
OSHA Technical Manual, Section VIII: Chapter 1, Chemical Protective Clothing
DuPont information on Industry Methods, Standards & Regulations
DuPont Safespec chemical testing database
Lakeland Chemax chemical testing database
Kappler Hazmatch chemical protective clothing selection guide
National Fire Protection Association (NFPA)
ASTM International (ASTM)
Safety Equipment Institute (SEI)
Daniel H. Anna, Chemical Protective Clothing, Second Edition, American Industrial Hygiene Association (AIHA), 2003
National Institute of Occupational Safety and Health (NIOSH), Recommendations for Chemical Protective Clothing database.
Roder, M. M., A Guide for Evaluating the Performance of Chemical Protective Clothing, National Institute for Occupational Safety and Health, Cincinnati, 1990.
Krister Forsberg, Ann Van den Borre, Norman Henry, II and James P. Zeigler, Quick Selection Guide to Chemical Protective Clothing, Wiley, sixth edition, 2014.
National Environmental Trainers, Selection of Chemical Protective Clothing, blog posting.
The information contained in this article is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This article is not a substitute for review of current applicable government regulations, industry standards, or other standards specific to your business and/or activities and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.
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