If we agree consensus standards are the bare minimum (getting a group of people from varied backgrounds with varied agendas to agree on anything, come to consensus by default will result in the lowest common ground). So if you are not specifying NFPA 2112 certified garments why are you willing to accept garments that have not met what the industry has agreed should be the minimum “Standard for Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire”.
Can you meet the requirement for FR Clothing with non NFPA2112 certified garments? Yes you can meet the FR requirement for working in O&G exploration with FR garments that meet ASTM 2302 (This specification provides minimum requirements for labeling protective clothing as heat and flame resistant for applications where the potential for flame contact or high heat exposure exist.) This is a much easier specification to meet that NFPA 2112.
So if you are willing to use garments that are not NFPA 2112 certified, then my follow-up question is: Where are you willing to hurt me? Many garments can satisfy ASTM 2302 but cannot meet NFPA 2112 so the logical follow-up question is: Where do they fail?
Unfortunately you will not know where you will be hurt or where the garments failed NFPA 2112 until the day you need that garment to perform as PPE – let’s face it, navy blue FR coveralls all look the same when you are walking around the job site, where the difference between FR coveralls and NFPA 2112 certified coveralls comes into play is how they perform in a flash fire. Garments that are NFPA 2112 certified have at the very least passed a battery of tests providing you some peace of mind that garment has met or exceeded the requirements for the Fabrics, the Findings (what goes into constructing the garment, buttons zippers, pocket liners etc.) and the Facilities (the facility can consistently make the same garment time and time again). Because if the garments don’t have the 3 F’s – Fabrics, Findings and Facilities you have one F – Failure.
Why is this important, why does it matter how the garment is constructed and with what it is constructed with, if the fabric is “component recognized”? Take for example findings such as “zippers”, can you make a coverall with cheap “zippers” with plastic teeth and non FR synthetic tape? Yes you can and they work fine until you are in a thermal event and that zipper fuses shut or the non-FR tape melts into the teeth of the zipper due to the heat and traps you in the garment. The number one thing to minimize injury once you have escaped a thermal event is to get out of that garment! Every second spent in that garment is causing injury to your body. All the thermal energy that is stored in the fabric and in the air gap between the fabric and your skin is being transferred to you until you get out of that garment (at 140 degrees it only takes 3 seconds for a second degree burn. Remember a Flash Fire is between 1400 and 1900 degrees). A proper zipper with FR tape that does not fuse shut will allow you, a co-worker or a first responder to remove the garment effectively thus minimizing injury.
Are non – certified NFPA 2112 garments cheaper? Probably, it costs money to go the extra step to ensure that garments meet or exceed the standards, it costs money to make sure that everything that goes into that garment will not add to the injury. The real question is as a safety professional how much is your “peace of mind” worth? If you save $40 dollars per coverall, how many coveralls do you have to buy to make up for one extra day in a burn unit? An average day costs $25,000.00 a day and it only takes an extra 2 to 3 % body burn to add that extra day. That could easily equate to an extra 3 to 5 seconds your employee is stuck in that coverall because that zipper melted shut because those findings did not meet NFPA 2112 and that coverall was not NFPA 2112 certified but technically it was FR because it met ASTM 2302.
Yes you can be compliant and still be un-safe.