Introducing the FR Assessment Tool
When Do You Need to Use Flame-Resistant Clothing?
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The OSHA Personal Protective Equipment standard (1910.132) requires employers to assess the hazards present in the workplace and to provide employees with PPE adequate to protect them. In workplaces where flash fire is an identified hazard, NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Short-Duration Thermal Exposures from Fire, describes many factors to consider during a hazard analysis to determine if flame-resistant (FR) garments are required. While NFPA 2113 provides a framework for the hazard analysis, its methodology and execution are left up to the employer. Many times, the responsibility for performing this analysis rests with the safety team, which often includes IHs who may have limited experience in assessing this type of hazard.
Now, members of AIHA’s Protective Clothing and Equipment Committee have developed an FR Assessment Tool that guides users through the steps of a hazard assessment and helps determine whether FR clothing (FRC) is required for a particular task or operation. This article summarizes the steps of an FR hazard assessment, describes the FR Assessment Tool, and invites readers to provide feedback that will be used to improve the tool.
Beta-Test the FR Assessment Tool
Follow these instructions to help the development team improve the FR Assessment Tool:
  1. Go to the AIHA IH Apps and Tools webpage. Save the FR Assessment Tool to your laptop or desktop computer and review the user instructions included in the tool.
  2. Use the tool to gather information and perform assessments.
  3. Make notes of your experience with the tool, including its functionality, navigation, and technical content, and the clarity of its instructions.
  4. Email your feedback by Aug. 31 to the FR Tool Development Team.
The team will review the feedback, update the tool, and submit it to AIHA’s Content Portfolio Advisory Group for approval later this year. Once approved, the updated tool will be published on the AIHA Apps and Tools webpage.
FLASH FIRE RISK ASSESSMENT When determining whether FR clothing should be required, the key question is not so much how clothing responds to open flames, but how it responds in the event of a true flash fire. A flash fire is produced when, under the right conditions, flammable or combustible materials explode or flash with an immediate release of energy; this event differs from an open pool fire, a more common scenario where the energy is released slowly over a longer period. Two typical situations that can produce a flash fire in the presence of an ignition source are:
  • the release of flammable gases into the atmosphere
  • the handling of flammable or combustible liquids above their boiling points or flash points and their subsequent release into the atmosphere
A flash fire can also be produced without an ignition source if a material is being handled above its autoignition temperature at the point of release to atmosphere. (Combustible dust that becomes agitated and suspended in the air can also produce a flash fire but is beyond the scope of the FR Assessment Tool.)
Flash fires last only three to four seconds, but in that brief period they can result in severe burns, lung damage from breathing hot gases, and injuries from shrapnel and debris. Exposed skin will be burned by the heat and flame of a flash fire, but some of the worst burns can be caused by the ignition of common work clothing. The ignition of work clothing is especially problematic because the clothing burns in direct contact with the skin, will burn away from the point of ignition with increasing flame spread, and will continue to burn until extinguished or consumed as a fuel source. Typically, the clothing can burn for a much longer period than the initial flash fire.
The solution to ignitable work clothing is the use of FR clothing. However, it is important to note that FR clothing does not prevent or eliminate the hazard. It is intended to help mitigate the severity of the outcome or injury to the worker if a flash fire or other thermal emergency were to occur.
Determining whether FR clothing is necessary requires a risk assessment. The preferred approach for conducting this assessment is to assemble a team of subject matter experts in the operation and maintenance of the facility. Team members may include representatives from site engineering, the process areas being assessed, and management. These experts will understand the chemicals in use and the various job tasks and associated operating conditions. The team should typically include operators, maintenance personnel, engineering staff, and OEHS professionals.
The assessment will typically start with an initial screening of the materials in question to determine properties such as boiling point, flash point, and autoignition temperature. The National Fire Protection Association’s rating system—as described in NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response—is a good indicator of a material’s flammability or combustibility. NFPA 704 ratings range from zero for a minimal hazard to 4 for a severe hazard. Materials rated 3 or 4 should require further assessment of affected job tasks, but in some situations, even materials rated 1 or 2 may require further assessment. Therefore, it is important to note the specific tasks being conducted, their frequency, and any associated process conditions such as operating temperatures and pressures.
The assessment should also consider other situations unique to a particular task or the general work area that could increase the possibility of a flash fire, including the presence of open flames or other ignition sources, emissions from open process equipment, and the possibility of static discharges or an oxygen-enriched atmosphere. Other tasks in the vicinity could also create a flash fire.
But even considering these factors is sometimes insufficient to determine whether FR clothing should be used. In these cases, it may be useful to establish a numerical scoring system for key criteria. This approach can also expand the risk assessment by incorporating historical information about chemical releases, the level of controls in place, and the likelihood of an incident occurring. This information can help assess and more clearly describe the degree of risk a task presents. An example of such a scoring system is included in the FR Assessment Tool.
Finally, once the assessment is complete, it is necessary to document the results, including who participated, their roles and responsibilities, the tasks assessed, the decisions made, and the factors considered in arriving at those decisions. Good documentation will make it easier to answer questions that inevitably arise and possibly avoid the need to redo the assessment later.
HOW TO USE THE FR ASSESSMENT TOOL The AIHA members who developed the FR Assessment Tool drew on their professional experiences and from sources such as the “CMA Guide to Assessing Flame Resistant Clothing Use” from the Chemical Manufacturers Association and “The JOIFF Standard Handbook on Personal Protective Equipment (PPE) to Protect Against Heat and Flame” from JOIFF – International Organization for Industrial Emergency Services Management. The spreadsheet-based FR Assessment Tool works on Microsoft Excel 2010 and later versions. It helps users determine whether FR clothing is required in their work environment by posing a series of questions designed to document a risk assessment and its results. The intended users of the tool are competent occupational health and safety professionals and teams of subject matter experts.
Disclaimers and Limitations Users should understand the FR Assessment Tool’s limitations. As stipulated by the hierarchy of controls, PPE is the last line of defense; before using the tool, OEHS professionals should ensure that all possible risk treatment alternatives to prevent fire or explosion hazards have been considered. The tool is designed to assess specific tasks employees may be performing, but regulatory and industry standards also require employers to consider the need for FR clothing when employees are simply walking through a given work area or working in proximity to fire hazards. In addition, the tool is not intended to determine the acceptable level of risk; this crucial decision is for the organization to make. Finally, assessing the need for arc flash PPE—equipment that protects workers from electrical discharges—is beyond the scope of the FR Assessment Tool.
The FR Assessment Tool Interface When users open the tool, they will see the main menu shown in Figure 1. This menu provides access to modules that guide users through the process of documenting inputs, listing team members, and completing the risk assessment. Instructions for each module can be accessed from the main menu.
Figure 1. The main menu of the FR Assessment Tool.
Tap on the graphic to open a larger version in your browser.
The tool is built like Lego blocks and the user can follow all the steps by clicking on the respective buttons. The first step is to determine the scope of the risk assessment. This includes the planning data collected prior to the assessment, such as descriptions of tasks and the flash points of any chemicals involved. An Assessment Team Log allows users of the tool to capture the names and qualifications of team members as well as the dates of assessment meetings and those who attended.
The Initial Screening module guides users through the first set of questions to determine if a task requires FR clothing. If answering the questions in the Initial Screening module is insufficient to exclude the task from FR clothing requirements, it should be assessed further in the Process and Job Task Evaluation (JTE) module and, if necessary, the FRC Score module.
The FRC score is based on a prioritization matrix. In this module, additional variables must be assessed to make a final determination. These variables include:
Prior Releases Factor (PR). The user can select the following scores:
  • 1: No releases have occurred, and conditions haven’t changed within the last five years.
  • 3: A release has occurred within 1–3 years; no changes to conditions.
  • 5: A release has occurred within the last 12 months; no changes to conditions.
In instances where a release has occurred within the last 12 months and conditions have changed, users are instructed to assign a score of 3 and re-evaluate after 12 months have passed.
Fire Hazard (FH). This variable is based on the NFPA rating of the substance. Users can select a score of 1 (for NFPA 1), 3 (for NFPA 2), or 5 (for NFPA 3 and 4).
Hierarchy of Risk Treatment (HoRT). If higher levels of controls—such as avoidance, elimination, substitution, minimization, simplification, or engineering controls—can be implemented, the HoRT score will be 1. A score of 3 indicates the presence of warning mechanisms that alert workers to hazardous conditions; administrative procedures; or PPE. If there are no control measures in place, a score of 5 should be considered.
Likelihood (L). Users assign a score of 1 if a flash fire is highly unlikely, 3 if likely, and 5 if highly likely.
Frequency of Operations (FoO). This variable is based on the logic that the more frequently these operations are performed, the higher the risk of a flash fire. Infrequent operations—for example, those performed once a year—are given a score of 1, monthly operations are given a score of 3, and daily operations are given a score of 5.
The FRC score formula multiplies these variables:
PR x FH x HoRT x L x FoO = FRC Score
By default, the FRC score can range from 1 to 3,125; a score of 75 or greater will require the use of FR clothing for the assessed operation, process, or task. An example of an assessment with preset scores provided by the tool’s developers is presented in Figure 2. Users can customize the scoring range to fit their needs.
Figure 2. An example of FRC score estimation with preset scores provided by the tool’s developers.
Tap on the graphic to open a larger version in your browser.
Not all tasks assessed by the tool will yield an FRC score. A score will be generated only when previous modules are insufficient to determine whether FR clothing is necessary.
As a best practice, the FR Assessment Tool includes one final step: completing documentation of the decision- making process. This documentation includes a list of actions and assigned due dates as well as the names and signatures of team members. The results of your assessment from the prior steps are carried over to the documentation page, including a complete list of process tasks (see Figure 3) created in the Scope module; a list of the tasks that were assessed (Figure 4); and the results of the initial screening, the Process and JTE module, and the FRC score (Figure 5).
Figure 3. The tool documents the list of process tasks.
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Figure 4. The task being assessed is part of the documentation produced by the FR Assessment Tool.
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Figure 5. The task being assessed is part of the documentation produced by the FR Assessment Tool.
Tap on the graphic to open a larger version in your browser.
STEP-BY-STEP GUIDANCE A beta version of the FR Assessment Tool is available for review by the AIHA membership so that the development team can get user input to further improve it. We encourage AIHA members to participate in the beta test. Instructions for doing so appear above.
Understanding, evaluating, and selecting FR clothing can be a challenge for many OEHS professionals. The FR Assessment Tool provides step-by-step guidance for performing a flash fire risk assessment and helps users decide whether FR clothing is needed for a given work task.
CHERYL DUBOIS, CIH, is an industrial hygienist in the 3M Global Corporate Safety and Industrial Hygiene organization in St. Paul, Minnesota.
KEVIN MAHONEY, MS, CIH, CSP, is a senior safety representative for Energy Transfer Partners North East Terminals.
ALLIE FLETCHER is a technical marketing specialist for thermal apparel with DuPont Personal Protection.
CURTIS HINTZ, CIH, CSP, FAIHA, is a retired industrial hygienist previously employed by The Dow Chemical Company.
GEORGI POPOV, PHD, QEP, CSP, ARM, SMS, CMC, FAIHA, is a professor at the University of Central Missouri.
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Chemical Manufacturers Association: “CMA Manager’s Guide to Assessing Flame Resistant Clothing Use” (July 1997).
JOIFF – International Organization for Industrial Emergency Services Management: “JOIFF Handbook on Personal Protective Equipment (PPE) to Protect Against Heat and Flame” (2007).
National Fire Protection Association: NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response (2017).
National Fire Protection Association: NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Short-Duration Thermal Exposures from Fire (2020).
OSHA: Occupational Safety and Health Standards, Personal Protective Equipment.
Professional Safety: “Risk Treatment Strategies: Harmonizing the Hierarchy of Controls and Inherently Safer Design Concepts” (May 2019).
The Synergist: “Dual Hazard Protection: Selecting Protective Garments for Both Chemical Resistance and Flame Resistance” (June 2018).