March 9, 2010
The November 24, 2008 Code of Federal Regulations 23 CFR – Part 634 requires “All workers within the right-of-way of a Federal-aid highway who are exposed to traffic (vehicles using the highway for purposes of travel) or to construction equipment within the work area shall wear high-visibility (hi-vis) safety apparel.”
This regulation applies to many groups of workers including construction workers, survey crews and utility workers. It also includes EMS responders to accidents and even law enforcement personnel who are on the scene to direct traffic and maintain order.
On October 20, 2009, OSHA issued a letter of interpretation stating that all highway and road construction workers must wear high-visibility apparel regardless of whether the Manual on Uniform Traffic Control Devices (MUTCD) requires them to wear it or not. So OSHA’s stance is simple â€” hi-vis apparel is mandatory for workers in these roadway danger zones.
The 2004 edition of ANSI/ISEA 107 specifies the performance requirements for high-visibility safety apparel. These include the physical properties of the background fabric and reflective bands as well as various configuration requirements for the garments and reflective tape. It also specifies the minimum amounts, approved colors and placement of these materials.
The purpose of this standard is to provide conspicuity to the wearer in hazardous situations under any light condition by day and under illumination by vehicle headlights at night. It’s all about making workers safe in roadway conditions where they may be otherwise hard to see.
Four classes of hi-vis apparelWorkers near roadways need to wear the proper class of the four classes of hi-vis apparel as laid out in the standard. The standard describes the performance requirements for each and provides suggested guidelines for when to use each class. Ultimately it is the user’s responsibility to determine which class of hi-vis apparel is right for his or her situation.
- Class 1: This is the lowest class and requires the least amount of background material and reflective tape. It also does not require a moving body part (i.e. arms or legs) to be part of the garment. A typical application is when the worker is well separated from the traffic, and the vehicle or equipment speeds are less than 25 mph such as in parking lot and warehouse environments. The Class 1 garment is typically a vest.
- Class 2: This class provides a medium level of visibility and requires more material and tape. It still does not require a moving body part to be included. The typical application for Class 2 is for workers on or near a roadway with a higher level of traffic and congestion and with traffic speeds of over 25 mph. This could apply to construction crews, utility and survey workers and traffic police. The Class 2 garment can be a vest, shirt or jacket.
- Class 3: This class provides the highest level of visibility and requires the most material and tape. The requirements also include having material and reflective tape on arms and/or legs. A sleeveless garment or vest alone cannot be considered a Class 3. This class would typically apply to those working in situations featuring higher traffic speeds (greater than 55 mph) and reduced sight distances. (Workers must be visible at a minimum distance of 1,280 feet). Class 3 would likely include highway workers, utility and survey crews and emergency response personnel.
- Class E: This class applies to trousers and shorts and is not a required class. However, Class E trousers or shorts can be worn with a Class 2 garment and the ensemble will be considered Class 3. Class E cannot be worn alone and meet any of the required classes.
Consider flame-resistanceThere are other issues to think about when someone like a utility worker wears a hi-vis garment while doing work on power lines near a roadway. In this situation, the hi-vis garment should also be flame resistant (FR) because not only are the workers exposed to traffic hazards, they are also exposed to a potential arc flash hazard.
In the case of arc flash protection, the outermost garment should always be FR. Therefore, when hi-vis and arc flash protection are required, the outermost garment would be the hi-vis. In the case of FR hi-vis for utility workers, the garment should have the proper arc rating (cal/cm2), and meet the requirements of the National Electrical Safety Code.
Not only should the garment itself be FR, but the reflective tape should be FR as well. Because of the large amount of reflective tape required, if the tape were not FR, it could ignite and continue to burn when exposed to an arc flash. So for utility workers and others who need arc flash protection as well as hi-vis, just meeting ANSI 107 is not enough to provide the needed protection.
Provide appropriate protectionThere is a lot more to being hi-vis than just looking hi-vis. Choose the hi-vis class of garment that best fits your situation and check to see if it meets the standard by being labeled as an ANSI 107-2004 garment. And for hi-vis FR, look for ANSI 107- 2004 on the label, check for the arc rating on the label and make sure the reflective tape is also FR.
There are a lot of choices in the market for hi-vis workwear that are not flame resistant, but hi-vis FR is becoming increasingly more available. Whatever apparel you choose, be sure it complies with both OSHA and Federal Highway Administration requirements.