ISEA vs. ISO: Apparel Standards Examined
These chemical protective clothing standards are fairly similar, but there are important differences.
FOR many industrial protective apparel end users, determining the proper protective garment to ensure worker safety is problematic. 29 CFR 1910.132, the personal protective equipment section of the OSHA General Industry Regulations, requires that employers "assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE)."1 If such hazards are determined to exist, employers are further required to "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."2 While this regulation is effective, in that it is written in a manner that can be applied to all U.S. industries and workplaces, it is not very specific and places a tremendous burden on the employer.
Industry Standards
Organizations such as the National Fire Protection Association (NFPA); American National Standards Institute (ANSI); the International Safety Equipment Association (ISEA); ASTM International; and ISO all have standards-writing groups that seek to provide employers with clear requirements that will result in compliance with performance standards specified in federal regulations and will ensure workers' safety. Standards published by these organizations represent a collaborative effort by representatives of all stakeholders within an industry. Compliance with these standards is not mandatory, but companies that voluntarily comply with these standards will have benefit of documented selection criteria in the event of an OSHA audit and can claim conformance to industry standard practices, if not best practices.
Currently, less than 10 percent of all chemical protective garments sold in North America are certified to a standard for chemical protective clothing. This is surprising to many, given the number and complexity of safety equipment standards covering hard hats, eye protection, high-visibility garments, fall arrest equipment, hearing protection, thermally protective garments, and garments for hazardous materials response that employers encounter on a daily basis. The certified garments sold are designed for higher levels of chemical protection and/or extreme conditions.
The most common certifications are to NFPA 1991, Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies; NFPA 1992, Standard on Liquid Splash-Protective Ensembles and Clothing for Hazardous Materials Emergencies; NPFA 1994, Standard on Protective Ensembles for Chemical/Biological Terrorism Incidents; and NFPA 1999, Standard on Protective Clothing for Emergency Medical Operations. These standards are limited in scope and do little to help the average industrial employer comply with OSHA regulations or protect workers on a daily basis.
ASTM International has published a number of standards and guides on garment labeling requirements; care and maintenance; terminology; and evaluation/selection of chemical protection garments to assist employers in protecting workers. While these documents contain excellent information that will prove useful even for the most sophisticated end user, considerable time and effort will have to be dedicated to locating, understanding, and utilizing these standards and guides. These standards are available for purchase on the ASTM Web site (www.astm.org) and can be located using the ASTM search engine and entering "F23 published standards."
The European Approach
While U.S. standards-writing bodies have focused on chemical protective clothing for emergency response, Europe has had a comprehensive standard(s) in place for several years.
The European Committee for Standardization (CEN) has written five chemical protective clothing standards that are applicable to general industry on a daily basis. This set of standards is commonly referred to as the "CE marking system." Collectively, these standards divide chemical protective apparel into six major classifications:
EN 943-2:2002--CE Type 1, Gas-Tight Clothing
EN 943-1:2002--CE Type 2, Non-Gas-Tight Clothing
EN 14605:2005--CE Type 3, Liquid-Tight Clothing; CE Type 4, Spray-Tight Clothing
ISO 13982-1:2004--CE Type 5, Solid Particulate Protective Clothing
EN 13034:2005--CE Type 6, Limited Liquid Chemical Protection
Some "Types" are further divided into sub-types based on garment or ensemble configuration. In aggregate, the CE mark system provides end users with standards for a wide range of challenges and exposure levels. In addition to being comprehensive, the European System is easy for end users to apply. All that is needed is an understanding of which work environments require which "Type" of garment. The end user can then consider the various garments that are labeled as certified to the relevant standard.
In addition to fabric performance standards, the European Norms include ensemble testing to ensure that not only the fabric, but also the entire garment is an effective barrier to the specified chemical challenges. This is significant because, in the absence of ensemble testing or a similar type classification system, many end users tend to focus on fabric test data when selecting chemical protective clothing. They incorrectly assume that if the fabric is an effective barrier, garments made from that fabric will also be effective. Seam type (serged, bound, and sealed); glove, boot, and respirator interfaces; and closure systems are frequently not given proper consideration in the selection process.
ISEA and ISO Standard Developments
Unfortunately, the CE Type system cannot be applied directly to the U.S. marketplace. There are some significant differences in test methods, standards, and regulations governing the European system and what is required in the United States. The most contentious of these differences centers on determination of chemical permeation and penetration. The European threshold for determining chemical permeation is 10 times greater than the U.S. standard.
Two organizations are working to develop standards modeled after the European Norms system. The ISEA and International Standards Organization (ISO) are both working on draft standards that will help employers select the proper chemical protection for workers performing common or routine work. The ISO standard, formerly ISO/DIS 16602.3, is modeled after a draft standard prepared by ISEA, ANSI/ISEA 103-200x, American National Standard for Classification and Performance Requirements for Chemical Protective Clothing. Both of these draft documents divide chemical protection into six separate classifications or "types" similar to European Norms (EN) standards. The ISEA draft employs ASTM test methods to the standard, whereas the ISO version applies ISO test methods where possible and seeks to resolve conflicting U.S. and European test methods and standards. ISO/DIS 16602.3 was expected to be submitted for balloting in July 2006.
Passage of the ISO standard is far from certain. The subcommittee responsible for the standard has struggled to reconcile the differences between U.S. standards and European Norms, making considerable progress. However, with so many voting interests with differing perspectives on these issues, progress to Final Draft status is not necessarily indicative of broad support. In fact, this standard has already been defeated once after attaining final draft status.
Concurrent with ISO's efforts, ISEA is working to complete its own draft standard. Upon completion, consensus of product group members, and end user canvassing, this document will be sent to ANSI as a proposed U.S. national standard. ANSI will review the document and the development process. If it meets the requirements, ANSI will publish the document as an ANSI standard.
The document, designated ANSI/ISEA 103-xxx, seeks to improve worker protection by addressing many of the issues outlined in this article. Like the current EN standards and the draft ISO document, the ISEA document utilizes a garment classification system. Unlike these documents, however, all classification requirements are contained in a single document. To facilitate ease of use, it includes a "Chemical Protective Clothing Decision Matrix" to aid in determining which "classification" garment is required for a particular job or task.
Chemical protective clothing is divided into six "U.S. Categories" with sub-classifications similar to the European Norms. ANSI has opted to use "U.S. Categories" to avoid confusion with ISO and CE Type classification on garment labels and in end user specification. In addition to ensemble testing, the current draft provides for easy comparison of the physical data, requiring that each property be rated on a scale of high, medium, or low based on the actual test results. This will facilitate relative comparison of competing fabrics used in a particular classification of garment.
The garment classifications proposed are as follows:
U.S. Category 1--Gas-tight, full body chemical protection
U.S. Category 2--Non-gas-tight, full body chemical protection
U.S. Category 3--Liquid-tight, full body chemical protection
U.S. Category 4--Spray-tight, full body protection
U.S. Category 5--Particulate-tight, full body protection
U.S. Category 6--Limited spray-tight chemical protection or partial body protection
The draft will require that garment classification be noted on the label, making it easy for end users to determine the protection offered by a particular garment. Physical properties data are to be included with the user instructions that accompany the garment. No longer will end users be forced to contact manufacturers to obtain information regarding strength, abrasion resistance, or barrier. The availability of this information will facilitate end user substitution of garments in the event of inventory depletion or supply interruption.
The Impact of Both Standards on End Users
The adoption of either of these two standards will improve worker safety by providing employers with a simple, easy-to-use system for selecting chemical protective apparel. Employers also will benefit from the availability of product data required by these documents, making it easier to compare garments and fabrics and easier to change to an equivalent level of protection when required. The ISO standard will obviously have global application, as it is a requirement of the World Trade Organization that member nations adopt international standards wherever possible. Assuming the ISO committee is able to resolve the permeation issue to the mutual satisfaction of the United States and the European Union, an ISO standard would also have application within the United States. The ISEA document will only apply to the United States.
Aware of the consensus within these organizations favoring ensemble testing in addition to fabric testing, end users should evaluate their current chemical protective garments to determine whether the garment configuration is appropriate for the chemical challenges encountered in their work environments. Generally, European Norms and the ISO and ISEA draft documents will not allow serged seams in spray-tight or liquid-tight classifications. Spray-tight garments are likely to have storm flaps over the zipper to protect against penetration through the closure system, and liquid-tight garment configurations may go as far as double storm flaps and respirator fit hoods.
There is one caveat common to all of these documents: While the classification systems contained in each will aid in selection of appropriate chemical protective garments, these classifications set only minimum requirements for chemical challenges based on the physical state of the chemical and the quantity encountered. These classifications systems do not indicate suitability of garments for use against any specific chemical other than the limited testing required to verify minimum fabric performance. End users still will have to develop or acquire specific chemical barrier data for the specific chemical(s) to which their workers will be exposed.
It is important for readers to note that the limited details of the draft standards discussed in this article are offered to provide insight into the direction that these standards-writing organizations are taking in their efforts to improve worker safety. Both the ISEA and ISO documents are still in development and are subject to change as these committees attempt to develop consensus.
This article appeared in the August 2006 issue of Occupational Health & Safety.
References
1. 29 CFR 1910.132(d)(1)
2. 29 CFR 1910.132(d)(1)(i)
This article originally appeared in the August 2006 issue of Occupational Health & Safety.