From: "Secretary, ACS Division of Chemical Health and Safety" <secretary**At_Symbol_Here**DCHAS.ORG>
Subject: Re: [DCHAS-L] Interesting article about flame retardants
Date: January 30, 2013 7:39:27 AM EST
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <6E41A647-701E-4C08-B889-61D00F3D4340**At_Symbol_Here**DCHAS.ORG>

From: Slawomir Janicki
Subject: RE: [DCHAS-L] Interesting article about flame retardants
Date: January 29, 2013 9:41:40 PM EST

(Sorry for the extra length of this post, but I wanted to get a grasp on
this interesting problem)

I came across some older reviews of toxicity of FR materials (cotton,
polyester, nylon) from NIST. The data indicates that in addition to the
additional toxicity of the FR fabric itself the heated/burned FR materials
produce outgases that are more toxic than those from the non-FR reference
materials. See here (free access):

Also, I looked at a few FR cotton and Nomex lab coats to see what standards
are quoted by the vendors. Most of them have limited application in a
chemistry lab. The standards for fabrics are separate from standards for the
FR PPE itself.

I have not seen any standards that set protection level for fires where the
fabric is soaked/covered in the accelerant.

When considering the level of protection of the employee/student what
matters is the actual protection of the garment, not just the properties of
the fabric. However, most of the standards cover just the fabrics.

The following is listed for some of the fabrics:

- Arc Rating (from ASTM 1959 Standard Test Method for Determining the Arc
Rating of Materials for Clothing)
- CFR 29 1910.269 (Electric Power Generation, Transmission, and
- NFPA 70E (Standard for Electrical Safety in the Workplace)
- Hazard Risk Category (also from NFPA 70E)
- ASTM F2302-03 (Standard Performance Specification for Labeling Protective
Clothing as Heat and Flame Resistant)
- ASTM F1506 (Standard Performance Specification for Flame Resistant and Arc
Rated Textile Materials for Wearing Apparel for Use by Electrical Workers
Exposed to Momentary Electric Arc and Related Thermal Hazards)
- NFPA 1977 (Wildland Fire Fighting Standard)
- NFPA 2112 (Standard for FR Garments for Protection Against Flash Fire)
- California GISO, Title 8 (Register 96, no.35;8-30-96),Section 3406 (c)(1)
(I haven't checked this one)

These standards describe resistance to either arc flash, flash fire, or pool
fire (NFPA 2112). IMHO, in a lab where the experiment scale is controlled
the flash fires are not large enough to cause severe injury and arc hazard
should be minimal. Both sources injure mostly by IR radiation and the fabric
is tested for resistance to a heat source away from the fabric.

The pool fire seems more relevant to a lab situation. In a pool fire the
victim stands in a pool of spilled accelerant. A lab coat gives next to no
protection from this kind of fire. In the video demonstrating the blue FR
lab coat the actor's pants are probably regular cotton/polyester with little
protection from a fire burning on the floor. Also, this kind of fire hazard
should be controlled by the amount of stored solvents. These are already
limited in many jurisdictions.

When considering the actual PPE garments there are a few standards that
could be useful:
- NFPA 2113 (Selection, Care, Use, and Maintenance of Flash Fire Protective
- SFI 3.2 (Driver Suits)
- SFI 3.3 (Driver Accessories)
- SFI 52.1 (Fueler Apron)
- CGSB 155.20 Standard for Workwear for Protection Against Flash Fire
(Canada) (very specific PPE and inflexible standard for lab situations)

The SFI standards are written for car racing and the described PPE is used
both by drivers and firefighters. The standards 3.2 and 3.3 are again for a
mixture of flash and pool fires and the fabric (SFI 3.2A) is specified with
about 4x resistance compared to the fabric specified by NFPA 2112. All the
clothing must be fire resistant and as specified is not that useful for lab

Only the SFI 52.1 specifies that the apron must be resistant to spilled

The NFPA 2113 specifies that the PPE must be selected for each specific
application. There is no "general" standard for any specific situation (lab
etc.). The process of PPE selection must be preceded by (my own wording):

- hazard assessment of the workplace
-- type of hazard present, potential magnitude and duration
-- adverse effects of unprotected exposure
-- possible engineering, administrative etc. controls instead of PPE
-- determination of garment performance characteristics needed for
-- decontamination assessment
-- ergonomic constraints imposed by PPE
-- comparison of risks and costs of all options
-- implementation of selected procedures
- evaluation of FR garment design and characteristics to determine
- the development of specifications for PPE purchase

This is hard to do for a R&D lab where chemicals change every day. In
addition, it seems to me that just doing the work necessary for the
selection of FR PPE should give sufficient hazard control to eliminate the
need for the extra PPE. Perhaps, in the heat of the moment and under the
pressure from our superiors to "do something" we occasionally skip the some
of the assessment process and just throw a complex "protection" equipment at
the problem. Sometimes the people in our care get lucky and our guess works.

Slawomir Janicki

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