NFPA 70E PPE Inspection and Issue
Purpose
The arc flash SOP decides what arc rating the job needs. This one guarantees that the garment answering that call is actually serviceable, is the one issued to the person wearing it, and has a condition history somebody can read. Those are different guarantees and a shop that only does the first one has a truck full of gear nobody can vouch for.
Arc-rated clothing fails quietly. A coverall with a worn-through elbow, a hole from a hot chip, a grease-soaked cuff or a washed-illegible label still looks like PPE, still comes out of the bag, and still gets counted when a tech says "I was in my arc gear." The rating on that label was measured on undamaged fabric, and none of those four conditions were part of the test.
The register turns "we issue PPE" into a dated record naming which garment, at what arc rating, to which person, in what condition. That is what a shop has when somebody asks what the tech was wearing, and the answer needs to be a number in cal/cm2 rather than a recollection.
Scope
Covers arc-rated clothing and the head, face and eye protection worn with it, for residential and light commercial electrical work: coveralls, shirts and pants, balaclavas, hoods, face shields, hard hats and safety glasses. Covers issue, pre-use inspection, laundering, repair, retirement and the register that tracks all of it.
Does not cover selecting the arc rating for a given task, which the arc flash boundary SOP owns and which this procedure consumes as a number. Does not cover rubber insulating gloves and sleeves, which carry their own electrical test interval and removal-from-service rules; the glove testing and rotation SOP owns those, and this register only carries the class and test date it is handed.
Roles and responsibilities
| Role | Owns | Hands off |
|---|---|---|
| Shop owner or safety lead | The written hazard assessment, the register, purchase of replacements | Names the replacement date when an item is condemned, not "we will order some" |
| Issuing supervisor | Steps 1, 2, 7, 8 and 9; the sizing fit check at issue | Hands over the item with its arc rating spoken aloud and written on the register |
| Technician | Steps 3 to 6 before every use, and the condemn call on their own gear | Reports a defect the same day, in writing, before the item goes back in the bag |
| Whoever launders | Wash method per the garment's own instructions | Returns the item with its label legible or flags it as unreadable |
A technician may condemn any item. Nobody may un-condemn one except by replacing it.
Procedure
Confirm the written hazard assessment that drives what gets issued exists and is current. Acceptance: a certification exists identifying the workplace evaluated, the person certifying the evaluation, and the date, as 29 CFR 1910.132(d)(2) requires in general industry, with the construction-site PPE duty at 29 CFR 1926.95 and 1926.97 in Subpart E, and it names the task classes this shop actually runs and which Part they fall under. Wrong looks like a generic sheet downloaded once, naming equipment the shop never touches. Stop rule: no assessment, no issue; the supervisor writes one before any gear leaves the shelf, because the assessment is what makes the rating defensible. Hazard: none at this step, it is a desk decision made away from equipment, and doing it at a desk is the point.
Open the register and confirm every arc-rated item has an ID, an owner, an issue date and an arc rating read off the garment's own label. Acceptance: each row carries a value in every one of those four fields, and the arc rating is transcribed in cal/cm2 with the ATPV or EBT label wording it was printed with, not rounded. Wrong looks like a row reading "coveralls, blue" with no rating. Stop rule: an item whose rating cannot be read off its own label is condemned at step 8, not estimated from the catalogue it was bought from. Hazard: none at this step; the hazard it prevents is a tech being handed an unrated garment for a rated task.
Inspect the outer arc-rated layer before each use, in daylight or under a work light, both sides. Acceptance: no hole, tear, burn, char or worn-through area of any size in the outer layer, no missing or broken closures, seams intact, and the manufacturer's label legible. Wrong looks like a pinhole from a hot chip that the tech remembers and works around. Stop rule: any breach of the outer layer condemns the garment for arc work; there is no repair threshold a technician gets to judge in a van. Hazard: reaching into a bag of gear that has been sharing space with tools puts a hand onto whatever cut the fabric, so empty the bag rather than feeling through it.
Check the garment for flammable contamination and for what is worn underneath it. Acceptance: no grease, oil, solvent or fuel staining, and every layer under the arc-rated outer layer is either arc-rated or untreated natural fiber. Wrong looks like a polyester athletic shirt under a rated coverall, or a cuff soaked from an earlier job. Stop rule: contaminated garment out of service until industrial laundering restores it; synthetic underlayer changed before the tech goes near the equipment, no exceptions for a short call. Hazard: meltable synthetics melt to skin under an arc-rated layer and turn a survivable exposure into a graft, and a fuel-contaminated garment ignites and keeps burning after the arc is over.
Inspect the face, head and eye protection as a set, not item by item. Acceptance: the arc-rated face shield or hood carries a stated arc rating at or above the exposure, the shield window is free of crazing, deep scratches and delamination, the hard hat is inside the service life its own manufacturer states and shows no cracking or chalking, and safety glasses are worn under the shield rather than instead of it. Wrong looks like a shield stored face-down in a truck bed for a year and now hazy. Stop rule: a crazed or delaminated window is condemned; hazy plastic scatters light and the tech cannot see the thing that is about to hurt them. Hazard: handling a cracked shield or a shattered lens cuts hands, so bag it rather than carrying it loose to the bin.
Check the closure geometry with the tech in work posture, not standing straight. Acceptance: with arms extended forward as if reaching into a panel, the sleeve still covers the wrist and overlaps the glove gauntlet, the hood or balaclava leaves no bare neck, and trouser cuffs stay over the boot. Wrong looks like a coverall that fits at the counter and opens a band of bare forearm at full reach. Stop rule: a gap that opens under reach is a sizing failure, and the item is reissued in the correct size before the tech is dispatched. Hazard: the exposed strip is exactly where the arms are during the work, which is nearer the source than the torso.
Issue the item to one named person and say the arc rating out loud as you hand it over. Acceptance: the register row carries the person's name, the date, the item ID and the rating, and the receiving tech repeats the rating back. Wrong looks like a shared bin nobody owns, which is how a size-large coverall ends up on a size-small tech with the sleeve gap at step 6. Stop rule: no shared arc-rated clothing between techs unless it is re-fit-checked at every handover. Hazard: none at this step; the read-back is what stops a tech assuming the number rather than knowing it.
Retire condemned items by destroying them, on the spot, in front of the person who condemned them. Acceptance: the garment is cut across the back panel or the shield is snapped, and the register row is closed with the date and the defect stated in words. Wrong looks like a condemned coverall folded onto the shelf "for dirty work," which is where it gets grabbed on a busy morning. Stop rule: a condemned item that leaves the shop intact has not been retired. Hazard: cutting fabric with a blade toward the body is how this step injures people, so cut on a bench away from the body, not while holding the garment up.
Audit the whole register quarterly and reconcile it against physical items. Acceptance: every open row has a physical item found and inspected, every physical item found has a row, and the count matches in both directions. Wrong looks like a register with more rows than gear, which means items left without being closed out. Stop rule: an unreconciled item is treated as missing and its row closed as unknown, so nobody plans a job around gear that is not there. Hazard: none at this step, it is a bench count.
The record this produces
One register, one row per item, kept where the dispatcher can see it rather than in a truck. Fields: item ID, item type, arc rating in cal/cm2 as printed, standard the rating is stated under, purchase date, issue date, issued-to name, size, last pre-use inspection date and result, laundering events, condemn date, and the defect in words.
The dispatcher reads it before assigning a panel job, because a job needing a rating higher than anything currently issued is a scheduling problem better found at the desk than at the panel. The owner reads the condemn column quarterly, because a garment type failing early and repeatedly is a purchasing decision, not a technician problem.
One quarterly audit, run
A three-tech residential shop, quarterly reconcile. The register carries 12 open rows: each tech has a rated coverall, a balaclava, an arc-rated face shield and a hard hat.
Step 2 passes on 11 rows. Row 7, a coverall issued 14 months ago, carries the rating field blank. The physical item is found and the label is present but washed to the point where only the fabric weight is readable. Under step 2's stop rule the value is not recovered from the purchase paperwork, so the item routes to step 8.
Step 3 on the remaining items: nine pass with no breach. The tenth, a coverall, shows a worn-through patch at the right elbow roughly the size of a thumbnail, with the underlayer visible. Step 3's acceptance is "no worn-through area of any size," so this fails. The tech had been working around it. Stop rule fires: condemned, no repair judgment made in the van.
Step 5 on three face shields: two pass. The third carries fine crazing across the lower third of the window from a solvent wipe. Crazing is a named condemn condition, so it fails and joins the two coveralls at step 8.
Step 6 on the surviving gear: the third tech's coverall passes standing but opens roughly two finger widths of bare forearm at full forward reach. That is a sizing failure, not a defect, so it stays in service and is reissued one size up rather than condemned. The register has to show which outcome was which.
Result: 12 rows in, 3 items condemned, 1 reissued for size. Nine of twelve pass unchanged, 75 percent. The shop is now down one rated coverall against three techs, so step 8's stop rule sets the consequence: that tech takes no panel entry ticket until the replacement lands, and the dispatcher hears it the same day rather than on the morning it matters.
Checking the run against step 8's acceptance: three rows closed, three defect descriptions written in words. The step 6 item is not among them, because a sizing failure closes no row.
References
- 29 CFR 1910.132, PPE general requirements, including the written hazard assessment certification at 1910.132(d)(2) and the employer payment provisions at 1910.132(h).
- 29 CFR 1910.335, PPE for electrical work practices in general industry; 29 CFR 1926.95 and 1926.97 in Subpart E carry the PPE duty on construction sites, with the electrical work practices at 29 CFR 1926 Subpart K, and the record should say which Part the job fell under.
- NFPA 70E, in the edition your shop's electrical safety program names, for arc-rated clothing selection and care. It is on a three-year cycle and its numbering has moved between editions, so pull the edition your program cites rather than a remembered section. OSHA does not adopt 70E by reference; it is the recognized industry practice a hazard assessment gets measured against.
- The garment manufacturer's own care instructions, which govern wash method, bleach and softener restrictions, and repair materials.
- See related: the arc flash boundary and PPE selection SOP, which produces the arc rating this procedure verifies; the rubber insulating glove testing and rotation SOP, which owns rubber goods.