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Can you see me now?

By Wayne Etchells
March 5, 2010


If you are involved with highway construction work, you should be familiar with the November 2008 Federal Highway Administration requirement that you wear ANSI 107-2004 Class II or III high-visibility safety apparel — and presumably, you are fully compliant.

Based on that mandate, the 23 CFR Part 634 standard, workers and public safety professionals working on or near federally subsidized roadways must be wearing high-visibility safety apparel or else face penalties or loss of grant funding. On December 16, 2009, the MUTCD (Manual on Uniform Traffic Devices) Section 6D.03 replaced 23 CFR Part 634. Mandatory usage of high-visibility safety garments has been expanded to cover all roads “open to public travel,” i.e., any road where you can drive a car without passing through a traffic control gate, including private property. Workers on federally subsidized highways must be compliant now; however, there is a two-year, phase-in period for compliance on public roads that are not federally subsidized.

Note: the MUTCD also recognizes the ANSI/ISEA 207-2006 standard for High Visibility Public Safety Vest as a compliant option for public safety professionals.

The financial threat for non-compliance notwithstanding, increasing workers’ nighttime visibility is more valuable than it is daunting — or costly. But once the hurdle of manufacturing compliant garments is met, implementation has a whole new wrinkle: workers must wear the apparel at all times and wear it properly.

ANSI compliance — an overview
Two types of products that meet the latest ANSI standard are heat-applied transfer reflective materials and sew-on reflective fabrics. Depending on the wearer’s occupation and intended use, specific properties may be required of the reflective material such as flame-resistant features for electrical workers. For those whose work is especially dirty, industrial-wash materials versus home washing alternatives exist. The selected laundering alternative is also available, with or without flame resistance. And while additional product attributes increase the cost, buyers select only what they need.

Safety garment manufacturers increase nighttime visibility for construction workers, servicemen and law enforcement officials by applying reflective material directly to their garments. In order to add aesthetic value, many garment manufacturers will add various colored webbing and ribbons that have the reflective material laminated to them.

In many cases, the webbing and ribbons are ANSI-certified fluorescent colors; however, they can also be just plain black, blue, etc. Often contrasting colors are used, such as an ANSI-certified fluorescent orange ribbon on a yellow vest, or vice versa. Pressure-sensitive adhesive material applied to accessories, such as helmets, also offers workers added nighttime protection.

Whether by heat-applied laminates to polyester, cotton, poly/cotton blends, urethane, fabrics, etc. or by sewn-on reflective material, manufacturers and employers have an array of choices.

Success depends on worker compliance
Making the apparel ANSI-compliant is key, but it is only the first step. The ANSI/ISEA 107-2004 Standard booklet is replete with detailed measurements, illustrations and charts. In addition, the total number of square inches and recommended placement for 360 degrees of visibility required on each coat, vest, or pair of pants is clearly stated for the apparel manufacturer, uniform shop and purchasing agent.

In the field, however, worker behavior is the key issue affecting implementation of the mandate. At the jobsite, where daily comfort matters more than style, it is the weight and wearability of the safety apparel that counts.

The ANSI-compliant vest should typically be worn over shirts, sweaters or other garments. In reality, construction workers laboring in hot climates are disinclined to wear a vest over a shirt. Anecdotal information indicates that in many cases, the vest remains in the truck or on the sidelines, leaving the worker vulnerable and his safety greatly compromised.

A workable solution: primary apparel
ANSI-compliant primary apparel such as shirts, sweatshirts or jackets avoids the problem of adding — or possibly removing — a vest. This solution is both practical and simple. In winter, workers wear ANSI-compliant sweatshirts as primary apparel. To combat winter’s chill at the construction site, workers wear an ANSI sweatshirt plus an ANSI-compliant heavy coat for warmth. Coat removal does not sacrifice compliance in this case.

In summer and in generally warm climates, T-shirts are the best answer. A segmented, heat- applied reflective material used on T-shirts, polo shirts, hooded shirts and other lightweight garments improves vapor transmission, thus keeping the wearer cooler. It also improves the drape of the garment making it more comfortable to wear. Since most workers wear T-shirts anyway, there is no need to contend with the additional warmth or weight of a vest.

Be compliant 24-7 To truly achieve the safety goals set by ANSI, compliance must be met day and night, in all weather and in all seasons. Primary high-visibility apparel represents the single best chance of always maintaining the standard.

As with all safety practices, ANSI compliance demands that the foreman or site supervisor be vigilant in enforcement. Integrating comfort, perhaps with a touch of design or even a bit of style, increases exponentially the likelihood that wearers might actually want to comply.

Additional resources
The Federal Register entry for the MUTCD Revision can be viewed at http://edocket.access. gpo.gov/2009/pdf/E9-28322.pdf.

The full text of the 2009 MUTCD can be viewed at http://mutcd.fhwa.dot.gov/pdfs/2009/ mutcd2009edition.pdf

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Wayne is executive vice president of Metlon Corporation, an authorized distributor of 3M™ Scotchlite™ Reflective Material, Cranston, RI. For more information, please log on to http://metlon.com or call (401) 467-3435.

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