As a safety manager, you’re in charge of providing employees with the tools and equipment that will help keep them safe. You also provide them with PPE, or personal protective equipment. Buying PPE isn’t usually a complicated task. But there are times when it can get a little tricky.
Let’s say you just purchased a new set of FR clothing for your maintenance workers. When the package arrives, you’re excited to see the new uniforms. But as you take a closer look, something appears to be missing. You suddenly realize how nice they would look with your company logo on them.
But FR clothing has very specific requirements. And you aren’t sure whether or not you can add any logos or embroidery. So what do you do?
Well, you could call your local embroidery shop and have them do the work. But do they really know much about FR clothing? Would they even think twice about the patchwork and material they use?
Whether or not company logos should be embroidered onto FR clothing is one of the most common questions in the flame-resistant clothing industry. So before you rush those garments into your local embroidery shop, here are some things you may want to consider.
What types of hazards does FR clothing protect against?
There are two types of FR clothing you may need to buy for your employees.
- AR Clothing
Regular FR clothing protects employees from fire-related hazards. The clothing that they wear is flame-resistant. It is not fireproof -- the clothing will ignite if exposed to flames or fires. However, the material will self-extinguish, limiting the surface area affected by the fire.
AR clothing is worn by electrical workers. AR stands for arc-rated. This type of clothing protects against electrical arc flash hazards. AR clothing is designed and tested to resist ignition. All AR clothing is also flame-resistant. But AR provides a higher level of protection than regular FR clothing.
Visit this post to learn more about the difference between AR and FR clothing.
Chances are, if you have employees who wear FR clothing, you also have some who wear AR clothing. You’ll need to consider safe options for embroidering both types of clothing.
What are the standards on logos and embroidery?
Currently, there are no OSHA regulations that prohibit the use of logos, name tags, or other emblems on FR Clothing. However, OSHA issued a letter of interpretation on the subject of embroidery for this type of clothing. The letter explains that the employer is responsible for determining whether or not such accessories will be allowed.
Here’s an excerpt from that letter:
“OSHA's standard at Section 1910.269(l)(8)(iii) requires that employees, who are exposed to flames or electric arcs, wear clothing that doesn't increase the extent of any injury sustained by the employee. That provision does not specify the construction methods or materials (including the embroidery) of the clothing, but it does list fabrics, including blends, that are prohibited (e.g., acetate, nylon, polyester, rayon) unless the employer can prove that the clothing made of these fabrics is worn in such a manner as to eliminate the hazard involved.”
Here’s the standard that the letter refers to:1910.269(l)(8)(iii)
- The employer shall ensure that each employee who is exposed to hazards from flames or electric arcs does not wear clothing that could melt onto his or her skin or that could ignite and continue to burn when exposed to flames or the heat energy estimated under paragraph (l)(8)(ii) of this section.
- Note to paragraph (l)(8)(iii) of this section: This paragraph prohibits clothing made from acetate, nylon, polyester, rayon and polypropylene, either alone or in blends, unless the employer demonstrates that the fabric has been treated to withstand the conditions that may be encountered by the employee or that the employee wears the clothing in such a manner as to eliminate the hazard involved.
OSHA often refers to other agencies and regulating associations. Their interpretation letter recommends employers review the ASTM standards to help them determine logo requirements. The NFPA also has some advice on the subject.
The American Society for Testing and Materials has its own recommendations for FR embroidery. ASTM F1506--10a is the standard for FR clothing and electric arc hazards. Regarding logos and embroidery, ASTM recommends that:
“Logos, name tags, and other heraldry, such as flag patches and company award insignias, are used to identify the organization and individual. If these items are constructed of non-flame resistant materials (such as polyester or rayon), their overall area should be minimized on the garment. For example, large company logos across the back of the garment should not be applied. In addition, the use of several logos over the entire garment should be avoided.”
ASTM does not prohibit the use of Non-FR logos and embroidery. They seem to view it as an acceptable risk. But they do provide some guidance on limiting the extent of that risk. They suggest minimizing the area that the logos and patchwork cover. In general, standard industry practice is to allow logos and patchwork that are no larger than the size of a credit card.
The National Fire Protection Association has specific standards about protection requirements for FR and AR clothing. You can find this information in NFPA 2112.
Related to logos and embroidery, the NFPA has two sections that discuss this issue:
- Section 1.3.4: “The requirements of this standard shall not apply to accessories that might be attached to flame-resistant garments.”
Section 220.127.116.11: “Labels and emblems [logos] shall not be required to be tested for heat resistance.”
Like ASTM, the NFPA condones the use of logos and embroidery. Both agencies recognize that such accessories could pose a hazard, but that it is an acceptable risk. Even so, employers need to minimize the amount of patchwork and accessories on FR clothing.
How to proceed with FR embroidery
Knowing all of this, what would you allow? Would you be willing to take the chance and let your employees wear logos and embroidery that is not FR rated? OSHA’s doesn’t require it. But you really ought to think about whether or not it’s worth the risk.
Don’t forget about the general duty clause either. Sometimes known as the “catch-all” standard, OSHA could still cite you for not adequately protecting your employees.
“Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”
If you do allow your employees to wear these accessories on their FR Clothing, make sure that the logos, name tags, and other accessories are not unreasonably large. By managing the size of the emblem, you’re minimizing the area that could be compromised if the FR garment were to catch fire.
You could also require FR or AR clothing to be worn underneath garments that have logos and patchwork. This would provide an added layer of protection.
Better yet, consider requiring that the stitching and material is made with FR thread. An alternative to embroidery and patchworks is to use FR ink silkscreens on your garments. Check with your suppliers to see what they can offer.
For more information on FR clothing requirements, visit our recent post on FR clothing for the oil and gas industry.