Flame Resistant Clothing (FRC)

Purpose/Scope
The objective of this program is to provide an added degree of protection to
Personnel working in the Gulf of Mexico (GoM) upstream sector where an
assessment of the hazard indicates a need due to potential flash burn injuries.
General Requirements
Flame resistant clothing will be required for all BP employees and contractors
when performing any
Of the tasks listed in this section.
Key Responsibilities
The Person in charge is responsible for implementing the program requirements.
Other Garment Materials
When other garments are worn in conjunction with FRC, the FRC must be worn
as the outermost
Layer of clothing. Garments worn underneath FRC should be made of material
that does not melt
when exposed to heat from fire.
The following is a list of known acceptable and unacceptable fabrics to be worn
underneath
FRC clothing:
• Acceptable Fabrics: Cotton
• Unacceptable Fabrics: 100% Nylon, 100% Polyester, 100% Acrylic
Note: Outer work cloths made of 100% polyester, rayon or nylon acrylic
are prohibited.
Task Requiring FRC
The following tasks require the FRC to be worn fully zipped or buttoned up with
sleeves rolled down.
• Process equipment repairs involving hydrocarbon atmosphere where hot work is
being conducted. (Initial absence of hydrocarbon does not ensure that conditions
will remain safe
For the duration of the job.)
• Collecting hydrocarbon samples.
• Drill stem testing.

• Lighting gas fired vessels.
• Situations where an employee and supervisor identify a site-specific job and/or area
Exposure to flash burn injuries.

Scope/Field of application
Scope
This procedure provides the criteria for implementation of a Flame Resistant
Clothing
program to assure that employees are adequately protected while working in
areas where flash fire or electrical arc hazards exists. These criteria shall be
incorporated into the specific Flame/Arc protection program(s) developed by the
facility.
Field of Application
This procedure applies to all facilities owned and/or operated by Citgo
Petroleum
Corporation its affiliates, and subsidiaries. Contractors are responsible for
developing and implementing their own procedures to protect against flash fire
and electrical arc hazards.
Such procedures shall be at least as protective as this best practice.
References
Laws and Regulations
OSHA Personal Protective Equipment – 29 CFR 1910.132
OSHA Electrical – 29 CFR 1010 Subpart S
OSHA Electrical – 29 CFR 1926 Subpart I
Technical References
NFPA 1975 – “Station/Work Uniforms for Fire Fighters”
NFPA 701 – “Flame-Resistant Textiles and Films”
Method 5903 – “Flame Resistance of Cloth; Vertical” of Federal Test Method
Standard 191A.
NFPA 70E – “Standard for Electrical Safety in the Workplace”
ASTM F1959 – “Standard Test Method for Determining the Arc Rating of
Materials for Clothing”.
NFPA 30 – “Flammable and Combustible Liquids Code.”
NFPA 70 – “National Electric Code”.

API RP 500 – “Recommended Practice for Classification of Locations For
Electrical Installations at Petroleum Facilities”.
ASTM F1449 – “Standard Guide for Care and Maintenance of Flame, Thermally
and Arc Resistant Clothing”.

NFPA 2113 – :Flame-Resistant Garments for Protection of Industrial Personnel
Against Flash Fire”.
NFPA 1971 – :Standard on Protective Ensembles for Structural Fire Fighting and
Proximity Fire Fighting”.
NFPA 1972 – “Standard on Helmets for Structural Fire Fighting”.
NFPA 1973 – “Standard on Gloves for Structural Fire Fighting”.
NFPA 1974 – “Standard on Protective Footwear for Structural Fire Fighting”.
Definitions
Flame-Resistant Clothing (FRC)
Clothing intended to provide protection to the wearer from the hazards posed by
flash fire
Or electrical arc. FRC may be considered acceptable if it meets the requirements
of NFPA
1975 or ASTM F1959 for electrical arc protection. Manufactures of FRC not
tested to
NFPA 1975 specifications must be able to provide documentation that the
garment fabric
exhibits a maximum 2.0 seconds after-flame and a maximum 6.0 inch char
length when
tested in accordance with Method 5903 of Federal Test Methods Standard 191A.
In
addition, it must remain intact (not subject to dripping, melting, separation, of
ignition)
when tested for heat resistance as specified in NFPA 1975 or the equivalent. For
electrical
arc protection, manufacturers of FRC not tested to ASTM F1959 must be able to
provide
documentation that the garment fabric exhibits characteristics suitable to meet
the
requirements for the level of protection required by NFPA 70E. These desirable
properties
must be retained after successive launderings, for the useful life of a garment.

Self-Extinguishing
Those materials that pass either the “small” or “large” scale test when tested in
Accordance with NFPA 701, Method 5903 of Federal Test Method 191A, or the
Equivalent. Self-Extinguishing materials are not intended to provide thermal or
electrical
Protection.
Inherently Flame-Resistant
Those fabrics which are naturally flame-resistant as opposed to fabrics which are
Chemically treated to become flame-resistant.
Treated Fabric
Fabric which is not naturally flame-resistant but which has been chemically
treated, giving
It flame-resistant properties.
FRC Areas
Those “mandatory” Citgo operating areas that have been determined to have a
potential
For flash fire. These may include areas inside operating unit battery limits,
laboratory
Analytical areas, shops, tank farm areas, and marine docks as determined by
local
Management. In addition, electrical arc flash protective clothing will be required
in any area or for any task where the potential for arc flash burns exist when
evaluated using the criteria established in NFPA 70E.
Temporary FRC Ares
Those areas that would not normally have a high potential for flash fire or
electrical arc
Burn requiring FRC, but which could during certain jobs or operations.
Visitors To FRC Areas
Persons visiting (but not working) an FRC Area or a Temporary FRC Area.
Visitors
May or may not be Citgo employees. Visitors are not allowed inside the Limited

Approach Boundary for electrical arc flash as established by the criteria of
NFPA 70E
Without the required level of arc protective clothing.
Requirements
Commitment
Citgo management has committed to ensure that those who work in or visit
Citgo’s
FRC Areas or Temporary FRC Areas are provided a degree of protection by
wearing FRC.
Establishment of FRC Areas
Permanent (Mandatory) FRC Areas
Citgo Management determines whether or not FRC Areas exist, and if so,
establishes
definite boundaries. Such decisions are based on sound engineering principles
and
management judgment taking into account information provided in NFPA 30,
NFPA 70, NFPA 70E, and API RP 500. In addition, arc protective clothing may
be required for work in or near load centers, sub stations, switch gear, etc.
Permanent FRC boundaries are either physically identified or communicated to
all affected employees.
Temporary FRC Areas
The type and potential amount of flammable gas or vapor, ventilation, wind
direction, the type of work to be performed, and other factors are taken into
consideration to aid in establishing boundaries. For such operations, boundaries
are set up in advance of the job or operation and are either physically identified
or communicated to all affected employees.
Arc Flash Hazard Analysis
A flash hazard analysis shall be completed to determine the flash protection
Boundary, the incident energy, and the personal protective equipment that shall
be
Used with the flash protection boundary. The flash protection boundary (FPB)
can

be calculated using the equations given in70E. This boundary may also be
calculated
using one of many computer models commercially available.
Based on information provided in NFPA70 E, Appendix D, where the incident
energy
Is determined to be greater than 40 cal/cm2 a greater emphasis will be placed on
deenergizing equipment prior to performing work when practical. Task such as
“racking out” of energized high voltage breakers should utilize remote devices if
practical. Task such as trouble shooting may not be practical without the
equipment being energized. Sites shall have in place a process for reviewing and
documenting that deenergizing high voltage equipment is not practical and that
appropriate PPE is available and utilized.
In the event that deenergizing high voltage equipment is not practical, prudent
practices shall be utilized to minimize the risk of arc flash. One example of a
measure which can be taken is to have a switch on the protective relays. This
switch, when it is in Arc Flash Protection Mode, bypasses the normal setting of
the relay and enables the instantaneous trip[ of the nearest upstream breaker or
breakers. In case of an arc flash fault, the breaker/breakers will trip more quickly
resulting in a reduced arc flash energy level. After completion of the work the
switch be returned to normal operation. Older equipment may not currently have
this type of control in place but new equipment installed should have this type of
modification if feasible.
Enforcement
Citgo management at each facility is responsible for enforcing the requirements
as
established by this Standard.
Citgo Employees
Every Citgo Employee (including summer/temporary and part-time employees)
working
or visiting within an FRC Area wears the required FRC at all times within the
area . FRC
is also worn while within a Temporary FRC Area during those times that the
area is designated as such.
Every Citgo employee required to work within an FRC Area is provided with
FRC clothing.

For those locations that issue FRC for individualized use, Citgo provides an
adequate number of sets of clothing to allow employees to report for work in
relatively clean clothing
without requiring an unreasonable frequency of laundering. Issuance of
additional sets of clothing to those more frequently required to wear FRC is
taken into consideration.
For those locations that provide FRC for temporary or shared use, Citgo
management is responsible to ensure that there is an adequate supply in a variety
of sizes to accommodate most situations, and that the clothing will be
maintained in a clean and serviceable manner.
Contract Employees
It is the responsibility of the Contractor to ensure that their employees are
properly outfitted in FRC and/or arc protective clothing prior to allowing them
to report to a Citgo FRC Area or Temporary FRC Area.
Visitors
Visitors to FRC Areas are provided with FRC, if they do not provide their own.
Long sleeved,
Flame-resistant smocks or lab coats extending at least to the knee, are
considered acceptable for limited use by Visitors only (Visitors includes Citgo
office employees visiting
FRC Areas.) Care should be taken to ensure that smocks are not worn in areas
where entanglement could become a hazard. Clothing worn under the smocks
must include long pants which completely cover the legs and appropriate closed
toed footwear. The wearing
Of shorts, skirts, sandals, etc. Shall not be permitted.
Manner Worn
All FRC must be worn so as to provide the maximum protection for which it
was designed.
Shirts/coveralls/smocks are fastened up to the bottom of the neck )only top
button unbuttoned).
Sleeves remain extended to cover the wrists. However, if approved by local
management, cuffs may be rolled back while in Non-FRC Areas or where
extended sleeves could create a

More immediate hazard (working with certain rotating equipment).
Legs are covered the full length.
The looser fitting the FRC, the more thermal protection the clothing system will
provide. Air is a very effective insulator; therefore, maintaining an air gap
between the clothing and skin will improve thermal protection. However, a loose
fit must be balanced against the hazard of clothing being caught in moving
equipment. Most FRC products will shrink either the same or less than standard
work clothing, and should be sized accordingly.

FRC should be worn over non-melting fabrics or other flame resistant materials.
For example, one recommended combination is wearing a Nomex IIIA coverall
Over a 100% cotton tee shirt and underwear. Layering garments in this manner
dramatically increases the thermal protection of the clothing system by adding
“air gaps” that provide excellent thermal insulation.
FRC, where required, must be the outermost garment worn. Non-Flame
Resistant Clothing is not allowed to be worn over FRC while in an FRC Area.
FRC Maintenance
Damaged FRC
FRC is replaced if it has been torn or otherwise damaged, or has become worn to
the point that its fire resistance is questionable. If the damage is repairable, then
repairs are made only by authorized individuals in a manner and with materials
that will provide protection
equivalent to the FRC when new.
Patches/Embroidery
Only patches or embroidery provided or authorized by Citgo are allowed on
FRC
worn by Citgo employees. Care must be taken to not add potential fuel sources
to the FRC which will compromise the ability of the FRC to provide the
intended
protection. For example, embroidery work and patches might or might not be
produced from flame retardant materials.
Laundering

Employees laundering their own FRC are responsible to ensure that the
manufacture’s
Recommendations are being followed. Care must be taken to assure that
detergents or additives such as fabric softeners will not compromise the flame
retardant properties of the FRC. FRC garment care and laundering requirements
are specified by ASTM 1449 (2001 Edition): Standard Guide for Care and
Maintenance of Flame, Thermally and ARC Resistant
Clothing. In addition, inspection requirements for FRC garments are outlined in
NFPA 2113 (2001 Edition): Flame-Resistant Garments for Protection of
Industrial Personnel Against Flash Fire.
Should local Citgo management choose to provide laundering service for FRC,
assurance will be made that the FRC will be laundered according to the
manufacturer’s recommendations.
Evidence of laundering in such a manner as to make the flame resistance of the
garment questionable, is considered justification for replacement of the FRC and
a reassessment of the laundering technique(s). Replacement will be according to
local policy.
Consideration should be given to the fact that FRC made from Treaded Fabric
needs to be replaced at laundering intervals as recommended by the
manufacturer.
Training
All Citgo employees provided with FRC shall receive the following information:
• The limitations of the FRC provided.
• Manufacturers recommended Care and Use instructions (include
laundering).
• The effects of various types of fabric worn under FRC in the event of a
flash fire.
• The potential effects of wearing non-flame Resistant Clothing over FRC.
• Electricians shall be trained on the rating of their FRC and effects of arc
flash.
Special Jobs / Circumstances
Jobs Requiring Disposable Coveralls

For tasks likely to ruin FRC (e.g. spray-painting) or for tasks requiring
disposable coveralls (e.g. asbestos removal) in an FRC Area, disposable
coveralls may be worn over, or in lieu
of FRC if approved by the site safety department . This is provided that they are
worn only during that task, with the total time worn minimized to the extent
possible. Disposable
or limited-use coveralls made from Self-Extinguishing materials shall be
considered for use where feasible.
Jobs Requiring Acid or Rain Suits
Employees working in FRC Areas requiring protective clothing for potential
acid exposure may wear appropriate chemical protective clothing instead of, or
over FRC if approved by the site safety department. Rain gear may be worn over
FRC. Rain gear and/or acid protective clothing made from Self-Extinguishing
materials shall be considered for use where feasible.
Marine Dock Locations
Employees working in FRC Areas requiring the wearing of life preservers may
wear life preservers over FRC. Life preservers that have an outside layer
certified by the manufacturer to be Self-Extinguishing shall be considered for
use where feasible.

Welders
Welders (and others subject to contact with molten metal) requiring FRC, may
be provided FRC garments made from fabric not easily damaged by hot slag
(e.g. flame-retardant cotton clothing) in lieu of types of FRC which can be easily
ruined by contact with hot slag (e.g. lighter-weight Nomex III). Welder’s vest
and sleeves may be worn over FRC.
Electricians
Flame retardant clothing may not be sufficient for protection from electrical arc
hazards.
Electricians (and others subject to exposure to electrical arc) requiring electrical
arc protective clothing may be provided with garments which are rated for arc
protection and may be worn over or in lieu of types of FRC which may not
provide sufficient protection from electrical arc hazards.

Laboratory Areas
Citgo employees assigned to work within laboratory analytical areas that are
designated as FRC Areas must wear appropriate FRC smocks, coveralls or
equivalent, e.g. pants and long sleeved shirts as designated by local
management.
Bunker Gear
Member of fire brigades or other groups acting as fire brigades may wear
approved bunker gear over FRC. Firefighter’s protective clothing includes
gloves, helmet, bunker coat, bunker pants (NFPA No. 1971, 1972, 1973, and
boots (1974).
Vehicles within FRC Areas
Persons within a vehicle passenger compartment passing through FRC Areas are
except
From wearing FRC as long as they remain within the vehicle, provided such
practice is approved by local management.
Flammable Gas and Vapor free FRC Areas
The requirement to wear FRC may be temporarily suspended by local Citgo
management in FRC Areas that have had the hazard of flash fire eliminated.
This situation will occur most often during turnarounds when entire units have
been shut down and cleared of flammable liquids, vapors, and/or gases.
Notifications as to exactly when the requirement to wear FRC is lifted and/or
reinstated will be very clearly communicated.
Allergic Reaction
Employees providing medical evidence from a physician supporting a claim of
allergic reaction to the selected type of flame resistant fabric are given the option
of receiving FRC
made from an alternate type of fabric.
DEET, the active ingredient in most insect repellents, is a flammable product (as
are the propellants used in the sprays) and may decrease the effectiveness of fire
retardant clothing when the clothing is saturated with the product. DEET must
not be sprayed directly on clothing and should only be applied to the skin.

Reports and Recordkeeping
Any unauthorized exception of this standard meeting the reporting requirements
of CIMS-101, Incident Investigation Standard shall be recorded and entered into
IMPACT Enterprise
database as a first report of an incident.
The initial incident report shall identify the potentially-exposed employees by
job tittle only.
The initial incident report shall provide sufficient information to contact a
responsible part for follow-up information.
Copies of arc flash reviews will be maintained per the Citgo Records
Management Procedure 20-12 latest revision.