High visibility clothing and apparel are regulated by standards which help to define minimum requirements to ensure worker safety. Selecting the appropriate high visibility garment depends upon having knowledge of the applicable standards and properly matching up the guidelines with the wearer’s needs (i.e., work environment, job duty, desired level of visibility, etc.). Listed below is a brief overview of the regulating bodies and their standards which dictate the appropriate level of visibility, in relation to worker safety.
MUTCD
In December 2003 the Federal Highway Administration published the most recent Manual on Uniform Traffic Control Devices (The MUTCD). For the first time, the MUTCD specified the ANSI-ISEA 107-1999 “or subsequent revisions” as the standard for High Visibility Apparel in work zones that include traffic, and gave all states a 3-year period from December 2003 to December 2006 to “codify” the Standard into State Law. Specifically, the MUTCD section 6E and 6D deals with High Visibility Safety Apparel use for Workers exposed to Roadway and Construction Hazards. Flaggers are to wear a minimum of a Class 2 garment at all times, and “should” wear Class 3 for night time and inclement conditions. The General Worker Safety Provisions covers all workers exposed to traffic of any kind. This section references the ANSI standard by name as Best Practices, with a Competent Person assigned to determine the minimum ANSI Class 1, 2, or 3 garment that is most appropriate as part of the Employers Hazard Assessment and Worker Safety Plan. The ANSI standard is now used to provide guidance to employers to determine the Best Practices in high visibility apparel.
OSHA General Duty Clause
Under Section 5 of the Occupational Safety and Health Act, all companies are required to provide a safe and healthy work environment. The employer is responsible for identifying hazards and for implementing appropriate (Best Practices) remedies such as Personal Protective Equipment (including ANSI Class 1, 2, or 3 High Visibility Apparel). Like the MUTCD, OSHA General Safety and Health Provisions 29CFR requires employers to conduct a Hazard Assessment each year to identify and mitigate Hazards. Since 1999, the first year of the ANSI standard for High Visibility Apparel, OSHA inspectors have begun referencing the ANSI standard as Best Practices, and under OSHA regulation 1926.28, fines as high as $7000 per incident have been issued. Taken together, The MUTCD and the OSHA General Duty Clause both now use ANSI 107-2004 or ANSI Public Safety 207-2006 High Visibility Class 1, 2, and 3 as the standard.
ANSI 107-2004 Standard
In late 2004, the American National Standard Institute (ANSI) updated the High Visibility Safety Apparel standards for the first time in 5 years. Based on recommendations presented by the International Safety Equipment Standards Association (ISEA), the new ANSI Standard maintained minimum background material and reflective tape, but strengthened design and test requirements for Class 1, 2, and 3 garments. Independent 3rd party fabric and reflective tests must now be conducted by USA accredited test labs to avoid mis-representation as “ANSI”. Apparel Manufacturers must then verify ANSI Class 1, 2, or 3 design requirements are met.
ANSI Class 1 garments are suited for workers well separated from traffic and therefore have lower visibility requirements (Material Requirements: background – 217 sq. in.; retroreflective – 155 sq. in.). ANSI Class 1 garments are to be utilized in work areas where vehicle and equipment speeds are under 25 mph. ANSI Class 1 garments must have reflective which completely encircle the body to meet the clarified encirclement requirement.
Examples of workers who use ANSI Class 1 apparel: parking lot attendants, people retrieving shopping carts from parking lots, workers exposed to warehouse equipment traffic, roadside “right of way” or sidewalk maintenance workers.
ANSI Class 2 garments are intended for use in activities where greater visibility is necessary during inclement weather conditions or in work environments with risks that exceed those for Class 1 (Material Requirements: background – 775 sq. in.; retroreflective – 201 sq. in.). Garments in this class also cover workers who perform tasks that divert their attention from approaching traffic, or that put in close proximity to passing vehicles traveling at 25 miles per hour of higher. ANSI Class 2 garments have the option of any combination of yellow or orange fabrics; combined with yellow, orange, white, or silver reflectives. Class 2 allows the greatest flexibility in design. As the MUTCD and OSHA General Duty clause suggests, most employers will use ANSI Class 2 as the “Best Practices” minimum, and select fabrics, reflective, and pocket configurations designed specifically for their work requirements.
Examples of workers who use Class 2 apparel: Forestry operations, ship cargo-loading operations, roadway construction, utility and railway workers, survey crews, school crossing guards, high-volume parking and/or toll gate personnel, airport baggage handlers/ground crew, emergency response and law enforcement personnel, trash collection and recycling operations, accident site investigators, railroad inspection and maintenance crews.
ANSI Class 3 garments are designed to offer greater visibility to the wearer in complex backgrounds and through and full range of body motions. Class 3 visibility is enhanced beyond Class 2 by the addition of background and retro-reflective reflective material to the arms and/or legs – where vehicle or equipment speeds exceed 50 mph. ANSI Class 3 garments now require both background fabric and reflective on arms or legs to fully define the body (Material Requirements: background – 1,280 sq. in.; retroreflective – 310 sq. in.). This new ANSI Class 3 standard defining body requirement is in support of the MUTCD definition of night time and inclement conditions. Anyone who has suddenly come upon a pedestrian at night knows the importance of increased response time. To meet the new defined body requirement, there are 2 options for customers to choose from as follows: First, ANSI Class 2 vests may be combined with ANSI Class E (Ensemble) shorts or pants to obtain ANSI Class 3 combination. This option allows employers and their workers to choose ANSI Class 2 for their normal hazards, and add pants or shorts for ANSI Class 3 compliance in the night time or inclement weather conditions per the MUTCD. As a second option, where a Competent Person has identified an ANSI Class 3 garment is needed at all times, a standalone ANSI Class 3 vest with short sleeve shirt design meets the new standard.
Examples of workers who use ANSI Class 3 apparel: Roadway construction personnel and flaggers, utility workers, survey crews, emergency response personnel.
ANSI 207-2006 Standard
In January 2006, The Federal Highway Administration published the most recent Manual of Uniform Traffic Control Devices (The MUTCD). This MUTCD revision accepted and coded into law for the first time the ANSI 107-1999 High Visibility Apparel Standard “or subsequent revisions”. The acceptance of the ANSI 107-2004 Standard (the current revision) in the MUTCD was a distinct advancement for highway workers. However for “Public Safety Workers” such as Police, Fire, State Patrol, Emergency Personnel, and other “First Responders” the circumstances and use of High Visibility Apparel on the job was unclear. Many Public Safety workers were exempted from using high visibility apparel, and/or were only partially covered by the ANSI 107 standard and the MUTCD.
In 2006 the Federal Highway Administration announced in a written statement that effective November 2008; all workers working on any highway that received federal funds must wear high visibility ANSI apparel. The new rule now included all public safety personnel; such as law enforcement, emergency workers, fire, EMS, public maintenance, utility crews, and “first responders”. This new requirement applied when performing duties of directing traffic, investigating crashes, handling lane closures, clearing obstructed roadways, and all other disasters within the right of way of federal highways. For practical purposes, any public safety workers on any highway that received federal funds are required to use either ANSI 107 or ANSI 207 high visibility apparel.
Public safety workers acknowledged the risks of on-the-job traffic accidents related to visibility. However, there was also an understanding that competing hazards such as heat/flame exposure for Fire Departments, use of stealth and/or weapons by law enforcement, and fire/chemical/electrical exposure in emergencies required judgment in the use of high visibility apparel. In addition, nontraditional colors were needed such as Police Blue, EMS White, Fire Red, to differentiate public safety personnel from highway workers. The ISEA, working in conjunction with select ‘Public Safety” organizations, began work on a new consensus standard. The result was the publication of the ANSI 207 Public Safety High Visibility Standard, a consensus approved by the canvas method and published in late 2006. The ANSI 207-2006 accepted as “Best Practices” much of the high visibility apparel criteria as defined by the already published ANSI 107-2004 standard for workers exposed to traffic. ANSI 107-2004 definitions of fluorescent fabrics, retro-reflective tapes, 3rd party independent tests of both fabrics and reflectives for color fastness, cleaning, tear, abrasion, flexing, temperature variation, care labels, marking, labels, bursting strength, reflective photometric and physical performance requirements apply to the ANSI 207-2006 standard as well. In all the technical requirements, the ANSI 107-2004 American National Standard for High Visibility Safety Apparel; and ANSI 207-2006, American National Standard for High Visibility Public Safety are nearly identical.
The major difference between the ANSI 107 Highway Workers Standard and the ANSI 207 Public Safety Standard is garment design; ANSI 207 Class 2 has less (450 sq inches) of background fabric and recommends a 5 point break-away design. Law enforcement could now combine Police Blue fabrics with fluorescent orange or yellow fabrics. Fire Service could use traditional orange, red or yellow fabrics; but may also need “Fire Resistant” fabrics per the (NFPA 701) and or (ASTM F-1506) standards as the primary danger may be fire. EMS personnel traditionally used white. Finally the National Incident Management System (NIMS) encouraged the use of color coding response personnel and/or the use of ID panels. The result is new vest designs that combine non-traditional color fabrics with traditional fluorescent fabrics to create entirely new designs for “Public Safety” and “First Responders”. Some of these designs are “One Size Fits Most” to allow for variation in personnel likely to wear these vests in an emergency. Clear and Velcro removable ID panels allow for fast changes in assignments during Incident Management. Velcro 5-Point “Break-away” sides and shoulder designs on select products provide an extra level of Safety. Taken together, the new ANSI 207-2006 standard allows “Public Safety” personnel to maintain their identity as First Responders while using high visibility apparel.
NFPA & ASTM for Fire/Flame/Arc
The forward section of the ANSI 107-2004 acknowledges fluorescent dye may be incompatible with National Fire Protection Association (NFPA) and American Society for Testing and Materials (ASTM) Fire/Arc Resistant fabrics and reflectives. Examples of workers that may need “FR” fabrics include Fire, Emergency, Utility, Metals and Petroleum industry. “FR” and “Arc” ratings will vary depending on the fabric and industry needs. Combined ANSI & FR “Best Practices” may include NFPA FR fabrics, ASTM FR fabrics, and 70E arc fabrics. FR reflective, Velcro, and dielectric snaps are then added.
High visibility apparel must also have multiple garment labels to protect workers from misrepresentation. Labels will include “ANSI” labels, “FR” labels, “Warning/Instructions for Use” labels, and “Country of Origin” labels. Each of these labels is required, and protects you, the user, from purchasing non compliant high visibility apparel. ANSI labels will include information on the Fabric, Reflective, Design, Class, Level, Size, Number of washings, and Washing/Care instructions. An additional label is required if an ANSI garment is Fire Resistant. The ANSI label may state ANSI or ANSI Style based on FR coating compatibility. Specific “FR” labels will clearly identify the Garment as meeting Fire Resistant NFPA 701, the higher Fire Resistant ASTM standard; and/or NFPA 70E Arc.
These governing agencies have all played a pivotal role in defining appropriate levels of worker visibility and benchmarking guidelines that also ensure the garment matches up with the wearer’s job function. By far, ANSI has become the definitive standard by which all high visibility clothing and apparel is designed. This information is presented by HiVis Supply, an affiliate site for Summit Sign and Safety, to aid in the decision process for selecting the appropriate garment style for your specific work environment. To view available ANSI approved apparel, you can visit us online at www.HiVisSupply.com.
