Comment from Fitzgeorge, Barbara; Tyndale Company, Inc.

• Flame resistant clothing offers the "last line of defense" for workers. It is the best way to protect workers in the event that all other safety systems fail and there is an accident. This approach is consistent with how similar hazards are addressed in other industries. It is a cost-effective, proven approach that has helped to save lives and reduce worker injury rates. • NFPA 2112 offers an excellent guideline on the se of flame resistant garments to protect against flash fire. Chapter 4 - the provision that requires UL certification - is widely disregarded by impacted industries and should not be considered in this rulemaking. • NFPA 70E offers insight on how rulemaking related to FR clothing should be developed: 1) conduct hazard assessment based on common work functions, 2) assign hazards to 'protection-level' categories based on those work functions, 3) develop FR clothing requirements based on the hazard and level of protection, as determined by the engineering analysis - similar to NFPA 70E's Hazard Risk Categories (HRC 1 through HRC 4). • Using NFPA standards as the basis for the development of a combustible dust standard is a solid start. However, OSHA must recognize that the use of voluntary consensus standards results in much slower adoption, particularly as it relates to FR clothing. • FR clothing offers a cost effective solution that delivers the optimum protection to workers. •