Permian Basin STEPS Network
Meeting October 11, 2011
PPE Hazard Assessment
For US Onshore E&P
Rick Ingram, S.G.E.
OSHA VPP Advisor
BP North America Gas
rickey.ingram1@bp.com
National STEPS Network
Creating the Safest Industry in Industry
• Collaborate
• Research
• Standardize
• Simplify
• Educate
WOGISA
KO:2011
• >1000 companies
• > 4000 members
• growing
KO:
2012?
Fatality Rate in South Texas has dropped from 8 to 1
4 Corners
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May 5, 2011
OSHA Factsheet: www.OSHA.gov
PPE Standard; 1910.132.d
Training Requirements; 1910.132.f
FRC and the Oil patch – The Memorandum
How To: ABC’s of PPE Hazard Assessment
Examples of a PPE Hazard Assessment
A NIOSH Study: Unseen Hazards
Back-up slides: NFPA
OSHA, The US Oil patch & FRC
AESC, IADC, National Steps Network, API and
Attended a meeting with OSHA in Washington,
D.C. on August 16, 2010 and followed up on
September 21, 2011
OSHA is Joining a work team in Houston to
develop a Recommended Practice
Updated information will be shared upon request.
OSHA, The US Oil patch & FRC
Enforcement Policy for Flame-Resistant
Clothing in Oil and Gas Drilling, Well
Servicing and Production-Related Operations
A Memorandum was issued on March 19, 2010 by
Richard Fairfax, Director of Enforcement
Programs
The Memorandum was intended to clarify OSHA’s
policy for citing the general industry standard for
personal protective equipment (29 CFR
1910.132(a)) for failure to provide and use FRC
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Standard Interpretations - Table of Contents
• Standard Number:
1910.132; 1910.132(a); 1910.132(d)
OSHA requirements are set by statute, standards and regulations. Our interpretation letters
explain these requirements and how they apply to particular circumstances, but they cannot
create additional employer obligations. This letter constitutes OSHA's interpretation of the
requirements discussed. Note that our enforcement guidance may be affected by changes to
OSHA rules. Also, from time to time we update our guidance in response to new information.
To keep apprised of such developments, you can consult OSHA's website at
http://www.osha.gov.
March 19, 2010
MEMORANDUM FOR:
REGIONAL ADMINSTRATORS
STATE PLAN DESIGNEES
FROM:
RICHARD E. FAIRFAX, Director
Directorate of Enforcement Programs
STEVEN WITT, Director
Directorate of Cooperative and State Programs
SUBJECT:
Enforcement Policy for Flame-Resistant Clothing in Oil and Gas Drilling,
Well Servicing, and Production-Related Operations
This memorandum is intended to clarify OSHA's policy for citing the general industry standard for personal protective equipment (PPE),
29 CFR 1910.132(a), for the failure to provide and use flame-resistant clothing (FRC) in oil and gas well drilling, servicing, and
production-related operations. For the purpose of this memo, FRC includes both flame-resistant and fire retardant treated clothing.
Clarification of the need to provide and use FRC during certain drilling, servicing, and production-related operations is necessary to
resolve its inconsistent use among drilling contractors, well servicing contractors, and oil and gas companies that employ thousands of
workers in these operations. OSHA inspection history and current information, including consensus standards, scientific evidence, and
accident and injury data, indicate a potential for flash fires during certain well drilling, servicing, and production-related operations.
Where FRC is not being used by workers in these operations, a citation under 29 CFR 1910.132(a) requires evidence that the employer
had actual notice of a need for protective equipment, or that a reasonable person familiar with the circumstances, such as facts unique
to the industry, would have recognized a hazardous condition warranting the use of that equipment.
Subject: Follow Up to August 16th Meeting
To All OSHA Attendees to Industry/OSHA Meeting of 8/16/2010
Gentlemen,
We want to first thank each of you for allowing industry to comment concerning the memorandum
issued concerning FRC in March of this year. In summary, we wanted to make sure we were all in
agreement on our notes and what we believe the next actions are concerning the FRC issue.
This is what we understood in outlining the OSHA position:
·
·
FRC Memorandum will not be recalled
OSHA takes the concerns communicated in the many responses seriously and was
surprised by the number of responses received
·
Flash fires in upstream are a low probability, but high consequence
·
Memorandum is not an official Letter of Interpretation or Directive, but an enforcement
policy
·
Memorandum is an attempt to speed the regulatory update process by Asst. Secretary
Michaels
·
Formal Rulemaking, including public comment periods take too long to execute, as much as
8 years in some cases
·
OSHA attempted to sign alliances with API and IADC in 2005 but turned down because
IADC and API have worked with governmental agencies without signing any type of
agreement. Examples of industry working with OSHA are: Upstream e-Tool, OSHA Fatality
Study, Rig Inspection Form, Cooperation and support of the Steps alliance efforts
·
OSHA in DC is largely unaware of the work that the STEPS Networks, AESC, IADC, API,
IPAA have been doing, our positive impact and momentum
·
OSHA in DC is not aware of a general shift in industry organizations working with OSHA
proactively
·
Consequently, the general perception by OSHA is that industry is unwilling to work together
with OSHA proactively
·
OSHA is willing to listen and work with us and this meeting was an attempt to open the door
for comment on FRC use
·
FRC Memorandum can be revised or an addendum possibly added
·
Perception that most PPE hazard assessments in upstream Oil and Gas are
inconsistent and generally inadequate
·
OSHA has not added Oil and Gas upstream to a National Emphasis Program but could
PPE & Worker Protection
Personal Protective Equipment
PPE comes in at third place in OSHA’s
Hierarchy of means to protect workers.
“Eliminate Control and Protect”
PPE is the Last Line of Defense
From the OSHA PPE Factsheet
• Engineering controls involve physically
changing a machine or work environment.
• Administrative controls involve changing
how or when employees do their jobs.
• Work practices involve training workers how
to perform tasks in ways that reduce their
exposure to workplace hazards.
From the OSHA PPE Factsheet
As an employer, you must:
• Assess your workplace to determine if
hazards are present that require the use of
PPE.
• If such hazards are present, you must:
– Select PPE and require employees to use it
– Communicate your PPE selection decisions
to your employees
– and select PPE that properly fits your
workers.
The OSHA Standard: 1910.132(a)
Protective Equipment
1910.132(a) 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.
The OSHA Standard: 1910.132(b), (c)
Employer Responsibility, Design
• 1910.132(b) Employee-owned equipment.
Where employees provide their own protective
equipment (i.e. Boots),?? Who is responsible??
the employer shall be responsible to assure
its adequacy, including proper maintenance,
and sanitation of such equipment.
1910.132(c) Design. All personal protective
equipment shall be of safe design and
construction for the work to be performed.
OSHA Standard: 1910.132(d)
Hazard assessment and equipment selection.
1910.132(d)(1)
The employer shall assess the
workplace to determine if hazards are
present, or are likely to be present, which
necessitate the use of personal
protective equipment (PPE).
OSHA Standard: 1910.132(d)
Hazard assessment and equipment selection.
• If such hazards are present, or likely to be
present, the employer shall:
• 1910.132(d)(1)(i) Select, and have each
affected employee use, the types of PPE
that will protect the affected employee from
the hazards identified in the hazard
assessment;
OSHA Standard: 1910.132(d)
Hazard assessment and equipment selection.
1910.132(d)(1)(ii) Communicate selection
decisions to each affected employee; and,
1910.132(d)(1)(iii) Select PPE that properly fits
each affected employee.
Note: Non-mandatory Appendix B contains an example of
procedures that would comply with the requirement for a
hazard assessment.
1910.132(d)
Hazard assessment and equipment selection
1910.132(d)(2) The employer shall verify
that the required workplace hazard
assessment has been performed through
a written certification that identifies the
workplace evaluated; the person
certifying that the evaluation has been
performed; the date(s) of the hazard
assessment; and, which identifies the
document as a certification of hazard
assessment.
What if OSHA Asks? Demonstrate Compliance
How To:
PPE Hazard Assessment Basics
Make a list: A Simple Spreadsheet will work
• List the different types of tasks:
– Use JSA’s, Incidents, Near Misses, Industry Data
•
•
•
•
•
•
•
List the potential hazards within the tasks
List the PPE needed to help protect
Research the specific PPE needed
Involve the employees performing the work
Add a certification and date
Most effective are Craft Specific
Make it a living document and Post it
– Use it to develop better JSA’s
– Continually Improve the list
– Use it for training
Bringing On/Shutting In a
Well
Checking Separator Sight
Glass
Repair/Replacing Dump
Valve
Lighting a Reboiler
Working on a Chemical
Pump
Changing Glycol Filters
Starting a Compressor
Conducting Compressor
Maintenance
Shutting Electrical Breaker
Loading/Unloading
Chemicals
Transferring Chemicals
Rigging Slings
Using Electrical/Air Driven
Tools
Housekeeping
Spill Cleanup
Basic Workover Operations
Gauging a Tank
Meter Testing
Plate Inspection
Well Testing
Choke Change
Replacing Rupture Disc
Loading/Unloading Pipe
Climbing Ladder
Handling NORM Material
Chemical Storage Area
Basic Drilling Operations
Hard
Hat
Safety
Glasses
X
X
X
Steel
Toed
Boots
Hearing
Protection
Rubber
Gloves
Cotton
Gloves
Leather
Gloves
Splash
Apron
Face
Shield
X
X
X
X
X
X
X
X
X
X
X
X
X
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Kevlar
Sleeves
Ground
Fault
Interrupters
Respirator
FRC
X
X
X
X
X
X
X
X
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LOTO
Equipment
X
X
X
X
X
X
X
X
X
X
X
X
Safety
Harness
X
X
X
X
Goggles
X
X
X
X
X
X
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X
X
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X
Note: Not all Personal Protective Equipment will be required if a hazard assessment was conducted and it identifies that certain hazards are not present. The PPE associated with the non-present hazard may not be utilized.
X
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HAZARD ASSESSMENT/CERTIFICATION FORM
FOR PERSONAL PROTECTIVE EQUIPMENT (PPE)
___________________________________________________
Installation (Operation Center Facility)
Source of Hazard to
Employees (Operation)
Assessment of Hazard
(Agent)
____________
Date
Head Protection
Hand Protection
IMPACT: Grinding,
chipping, chiseling, sawing.
Flying fragments, objects,
large chips, slag,
PENETRATION: Glass,
hand tools, metal rods, board
road nails, etc.
Objects with the potential to
penetrate the hands or feet.
Material/Equipment handling,
compression, etc.
Objects falling, dropping, or
rolling.
CHEMICAL: Acid, caustic,
and other chemical handling,
contact with chemical
handling equipment, etc.
Splash, spray, coating on
surface of equipment.
Hard-hats meeting ANSI
Z89.1 - 1986.
Goggles, eyecup and cover
type.
Inhalation, ingestion, skin
contact, systemic effects, and
birth defects.
For spray or overhead
chemical handling a slicker
with hood is recommended.
Use of face shield and
goggles is required when
handling open containers
and/or splash potential
exists.
Refer to MSDS for specific
material requirements of
gloves that must be used.
Safety glasses with side
shields at all times.
Insulated gloves, designed
for heat.
HEAT: Boiler operations
steam equipment, hot crude
oil/water, production, fired
heater equipment, reboilers
and piping, welding, etc.
Hot sparks contact with high
temperature equipment.
Contact with high temperature
fluids.
Hard-hats meeting ANSI
Z89.1 - 1986.
Eye & Face Protection
__________________________________________
Signature (Individual certifying evaluation)
General (blowing dust, loose
particles) - Safety glasses
w/side shields (Z87.1)
Grinding/chipping etc. Safety glasses with side
shields and a full face shield
are required.
Hard-hats meeting ANSI
Z89.1 - 1986.
Raised temperature
operations - Face shields,
goggles/ spectacles with side
shields.
(Operations involving heat
may also involve light
radiation)
For light work a cotton or
canvas glove.
Rough or abrasive material
requires leather or leather
reinforced metal stitching.
Gloves should be selected
based on the type of
chemicals used.
Foot Protection
Metatarsal foot guards where
compression and material
handling may warrant guards.
Footwear that provides puncture
protection.
Incidental contact - Work
shoes or boots that provide a
continuous barrier against
absorption (no holes/reactive
synthetics)
Prolonged/significant
quantity contact - Rubber
boots.
Non-synthetic material that
maintains a continuous
barrier against absorption (no
holes).
Approver: Duane Allman, President
Document owner: Barry Oakley
Management Statement: My Company is committed to following the OSHA General Duty Clause, protecting our
employees from recognized hazards.
 The PPE Hazard assessment is designed to not only list recognized hazards in our operations, but to give each
employee an opportunity to provide input as new or potential hazards are recognized.
 Due to our diverse business, a separate PPE Hazard Analysis worksheet will be completed for separate types
of work we do.
 My Company JSA program is always to be used for recognizing and mitigating hazards encountered in daily
operations at work sites.
 The PPE Hazard assessment is similar to JSA, but is a more formal way to capture hazards, and proposed
changes will be reviewed by the HSE committee at regular meetings, with accepted changes formally added as
decided by committee with management approval.
 PPE identified on the Hazard Assessment will be provided and included in the My Company training program.
 My Company management encourages employee involvement and participation.
Definitions:
 PPE: Personal Protective equipment. A device designed to protect a specific body part from a known or
potential hazard.
 Hazard: Something which if not eliminated or controlled would potentially cause harm to people or damage
to the environment.
 Energy examples include: Gravity, Chemical, Thermal, Pressure, Biological, Motion, Radiation & Electrical
Type of work:
Job task
Hazard
Energy
Reviewed by: __________________ Date: __________
Revised: ______________ Approved by: ________________
Signed: _____________
Date:________
Body Part
PPE
Who is Responsible, Operator or
Contractor?
OSHA Standard: 1910.132(e)
Hazard assessment and equipment selection.
1910.132(e) Defective and damaged
equipment. Defective or damaged
personal protective equipment shall not be
used.
OSHA Standard: 1910.132(f)(1)
Training
1910.132(f)(1) The employer shall provide
training to each employee who is required by
this section to use PPE. Each such employee
shall be trained to know at least the following:
1910.132(f)(1)(i) When PPE is necessary;
1910.132(f)(1)(ii) What PPE is necessary;
1910.132(f)(1)(iii) How to properly don, doff,
adjust, and wear PPE; 1910.132(f)(1)(iv) The
limitations of the PPE; and, 1910.132(f)(1)(v)
The proper care, maintenance, useful life and
disposal of the PPE.
1910.132(f)(2)
Training
1910.132(f)(2) Each affected employee
shall demonstrate an understanding of
the training specified in paragraph (f)(1)
of this section, and the ability to use PPE
properly, before being allowed to perform
work requiring the use of PPE.
1910.132(f)(3)
Training
1910.132(f)(3) When the employer has
reason to believe that any affected
employee who has already been trained
does not have the understanding and skill
required by paragraph (f)(2) of this section,
the employer shall retrain each such
employee. Circumstances where retraining
is required include, but are not limited to,
situations where:
1910.132(f)(3)
Training
1910.132(f)(3)(i) Changes in the workplace
render previous training obsolete; or
1910.132(f)(3)(ii) Changes in the types of PPE to
be used render previous training obsolete; or
1910.132(f)(3)(iii) Inadequacies in an affected
employee's knowledge or use of assigned PPE
indicate that the employee has not retained the
requisite understanding or skill.
1910.132(3)(f)(4)
Training
1910.132(f)(4) The employer shall verify
that each affected employee has received
and understood the required training
through a written certification that
contains the name of each employee
trained, the date(s) of training, and that
identifies the subject of the certification.
Payment for PPE
1910.132(h) Payment for protective
equipment.1910.132(h)(1) Except as provided by
paragraphs (h)(2) through (h)(6) of this section,
the protective equipment, including personal
protective equipment (PPE), used to comply with
this part, shall be provided by the employer at
no cost to employees.
1910.132(h)(2) The employer is not required to
pay for non-specialty safety-toe protective
footwear (including steel-toe shoes or steel-toe
boots) and non-specialty prescription safety
eyewear, provided that the employer permits
such items to be worn off the job-site.
Payment for PPE
1910.132(h)(4) The employer is not required to
pay for:1910.132(h)(4)(i) The logging boots
required by 29 CFR
1910.266(d)(1)(v);1910.132(h)(4)(ii) Everyday
clothing, such as long-sleeve shirts, long pants,
street shoes, and normal work boots;
or1910.132(h)(4)(iii) Ordinary clothing, skin
creams, or other items, used solely for protection
from weather, such as winter coats, jackets,
gloves, parkas, rubber boots, hats, raincoats,
ordinary sunglasses, and sunscreen.
Payment for PPE
1910.132(h)(5) The employer must pay for
replacement PPE, except when the employee has
lost or intentionally damaged the PPE.
1910.132(h)(6) Where an employee provides
adequate protective equipment he or she owns
pursuant to paragraph (b) of this section, the
employer may allow the employee to use it and is
not required to reimburse the employee for that
equipment. The employer shall not require an
employee to provide or pay for his or her own
PPE, unless the PPE is excepted by paragraphs
(h)(2) through (h)(5) of this section.
Payment for PPE
1910.132(h)(7) This paragraph (h) shall become
effective on February 13, 2008. Employers must
implement the PPE payment requirements no
later than May 15, 2008.
Note to § 1910.132(h): When the provisions of
another OSHA standard specify whether or not
the employer must pay for specific equipment,
the payment provisions of that standard shall
prevail.
OSHA, The US Oil patch & FRC
What is a Flash Fire?
A flash fire is a fire that spreads rapidly
through a diffused fuel, such as
hydrocarbon liquids or gas, without the
production of damaging pressure.
PPE Hazard Assessment
Examples
http://nasupplierhsse.bpglobal.com
rickey.ingram1@bp.com
Cell: 361.816.7217
PPE Selection
• Based on the task performed
• Based on hazards present
• Physical state – gas, liquid, solid
• Concentration
Where do I get this information?
• Material Safety Data Sheet?
– List of constituents and composition
– “Wear gloves.” “Wear respiratory protection.”
• Websites – Ansell Edmont (glove
example); 3M respiratory protection
• Take field measurements of
concentrations
Example
Condensate, NGL, Produced Water, Rich Glycol
SOURCE OF EXPOSURE / ACTIVITY
Tank cleaning, piping replacement, gauging
Benzene [Skin]
HAZARD (0.5 ppm BP 8-hr TWA, 2.5 ppm BP STEL; 1 ppm OSHA 8-hr TWA, 5
ppm STEL
1910.1028)
["Skin" denotes hazards that can be absorbed through the skin.]
CONCENTRATION / ROUTE OF ENTRY Less than 0.5
ppm
0.5 - 50.0
ppm
No respiratory
Full-facepiece
protection
respirator + organic
1910.134(d)(3)(i)(A) Assigned Protection Factor: Full facepiece air purifying - 50
required.
vapor cartridge
CONTROL MEASURES
Greater than 50.0
ppm
Clothing /
gloves
Supplied air
respirator/SCBA
Nitrile, viton,
neoprene
gloves
Task: Operating mountain mover (MM), transfer belt (TB) and blender
truck (BT)
Mountain mover
MM oper.
station
Transfer belt
Mountain mover and
transfer belt not operating
Blender truck
operator
Mountain mover and transfer belt
moving sand to blender truck.
MM and BT truck operators wore
N-95 filtering face piece respirators.
Task: refilling mountain mover with frac sand
•
Hose connections from sand refill truck are made on both sides of mountain
mover (MM); pressurization of MM causes fine dust to escape from MM
Sand truck
Mountain mover
fill nozzles
As opposite sides of MM are being refilled
with frac sand, fine dust is released from
filling nozzles
Task: operation of equipment pump trucks
• Diesel engines
Midday: diesel particulates
not highly visible despite multiple
operating engines
Early a.m. diesel emission cloud visible
above work area due to Tyndall effect
from stationary lighting sources
Task: Chemical truck operator
•
Chemicals contained in plastic carboys, direct connections made to blender truck via
mixing manifold. Workers well protected, dermal, respiratory protection used
appropriately, work operations occur in open area.
NIOSH Frac Study
• October 20-21, 2009 - field site visit BP location McAlester, OK
• September, 2010 – field site visit – Encinal, TX
• Chemical/work task observations for development of
exposure assessment sampling strategy
– Silica – 40/70 frac sand transferred from Mountain Movers via
transfer belt to blender truck
– Diesel particulate – generated from use of motive power (14
diesel engines pumper trucks) used to pressurize well fracturing
fluids.
– Chemicals – review of MSDS’s, observation of use & handling of
chemical products used in well fracturing operations
NFPA 2113-07-FRC
A.3.3.16 Definition: Flash Fire.
A flash fire requires an ignition source and a
hydrocarbon or an atmosphere containing
combustible, finely divided particles (e.g., coal
dust or grain) having a concentration greater
than the lower explosive limit of the
chemical.
Both hydrocarbon and dust flash fires generate
temperatures from 538°C to 1038°C (1000°F
to 1900°F).
NFPA 2113-07-FRC
The intensity of a flash fire depends on the size of
the gas or vapor cloud. When ignited, the
flame front expands outward in the form of a
fireball.
The resulting effect of the fireball’s energy with
respect to radiant heat significantly enlarges the
hazard areas around the gas released.
Additional information describing flash fires is
provided in Assessing Flame-resistant
Clothing Use, CMA Manager’s Guide.
NFPA 2113-07-FRC
Chapter 4 : Selection
4.1 General. The organization’s selection process
for flame resistant garments shall be based on
the following:
(1) The conduct of a hazard assessment of the
workplace to determine the need for the wearing
of flame-resistant garments
(2) An evaluation of flame-resistant garment
designs and characteristics to determine the type
of flame-resistant garments suitable for
protecting workers from flash fire
(3) The development of specifications for
purchasing flame resistant garments
NFPA 2113-07-FRC
4.2* Workplace Hazard Assessment.
4.2.1 The organization shall conduct a hazard
assessment of the work environment to
determine the requirement for wearing flameresistant garments.
NFPA 2113-07-FRC
4.2.2 The hazard assessment shall be performed
based on a review of the facility to determine if
flammable materials are present in quantities that will
generate a flash fire and endanger a person.
(3) The potential for the task being performed to
increase the possibility of a flammable release; this
could result from a mechanical failure such as a line
breaking.
(4) Operating conditions of the process — that is,
potential for flammable fumes or vapors, and so forth.
NFPA 2113-07-FRC
(5) The presence of engineering controls
designed to reduce exposure to flammable
materials present during normal operations
(6) Accident history
(7) Means and duration of egress within potential
exposure zone (e.g., location and distance to
exits, potential congestion, elevated or restricted
areas, connections to lifelines/ fall protection,
capability of workers to escape, etc.)
NFPA 2113-07-FRC
4.2.3* The general workplace hazard assessment
process shall include consideration of the following:
(1) Determination of the type of hazard or hazards
present in the workplace and the potential
magnitude and duration of the hazard
(2) Determination of the adverse effects of
unprotected exposure to the hazards identified
(3) Determination of whether other control options
(engineering, administrative, and so forth) can be
used instead of flame-resistant garments
NFPA 2113-07-FRC
(4) Determination of garment performance
characteristics needed for protection.
(5) Determination of the need for garment
decontamination where applicable.
(6) Determination of ergonomic constraints of
work to be performed while wearing the
garment.
(7) Comparison of risks and costs of all options.
(8) Implementation of selected option (s)
NFPA 2113-07-FRC
4.2.4 A specific evaluation of the work environment to determine
the requirement for the wearing of flame-resistant garments
shall be based on the potential hazards that workers are
exposed to as part of their work duties.
4.2.5 Factors in determining if flame-resistant garments are
required shall include, but not be limited to, the following:
(1) Proximity of the work to be performed to a hazard presenting
a flash fire potential
(2) The presence of flammable materials in the environment
during process operations
(3) The potential for the task being performed to increase the
possibility of a flammable release; this could result
from a mechanical failure such as a line breaking
NFPA 2113-07-FRC
4.2.5 (continued)
(4) Operating conditions of the process — that is,
potential for flammable fumes or vapors, and so forth
(5) The presence of engineering controls designed to
reduce exposure to flammable materials present
during normal operations
(6) Accident history
(7) Means and duration of egress within potential
exposure zone (e.g., location and distance to exits,
potential congestion, elevated or restricted areas,
connections to lifelines/ fall protection, capability of
workers to escape, etc.)
NFPA 2113-07-FRC
4.2.6* The initial review of a facility shall determine if
flammable materials are present in quantities necessary to
generate a flash fire and endanger a person.
NFPA 2113-07-FRC
4.3* Selection of Flame-Resistant Garments.
4.3.1 In addition to flame-resistant garments complying
with NFPA 2112, Standard on Flame-Resistant
Garments for Protection of Industrial Personnel
Against Flash Fire, the organization shall consider
factors in selecting flame-resistant garments