OSHA Hi VIsibility Requirements for clothing

As a business owners, small and large, we know that you are aware that your workers must wear ANSI compliant Hi-Vis clothing. Yet many do not know the specifics of the regulation behind the wearing of that clothing. The goal of this article is to be informative and cover the OSHA visibility requirements in detail. It will be a refresher for some and educational for the new business.

The OSHA Standards

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If your employees work on highway or road construction, the Occupational Safety and Health Administration requires they wear clothing to make them easily visible to drivers. And beyond the highway and road construction workers, OSHA has specific rules requiring flaggers and workers on excavation sites wear high-visibility clothes and also requires other workers to wear the clothes as a general safety principle.

Daytime vs. Nighttime Requirements

The OSHA manual states that for daytime work, flaggers must wear a vest, shirt or jacket colored orange, yellow or strong yellow-green. It can be fluorescent. For night work flaggers must wear a “retroreflective” vest, shirt or jacket that reflects back a high percentage of headlight beams. The retroreflective material must be orange, yellow, white, silver or strong yellow-green and also can be fluorescent.

The night-time warning clothes must be visible at 1,000 feet, minimum. Drivers must be able to recognize the wearer as a human being and make out the workers body motions.

General Requirements

The federal worker-safety “general duty clause” states that a business owner must provide a workplace that’s free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees. Various legal cases have interpreted this duty as grounds for applying the visibility rules to any construction workers exposed to either traffic or construction vehicles. If you employ surveyors, landscapers, towers, utility or paving workers operating alongside traffic, they must also wear protective gear.

What is The Federal Highway Worker Visibility Rule?

"The Federal Highway Worker Visibility Rule (23 CFR Sec. 634) was the first step in the creation of the U.S. comprehensive worker high visibility regulation. It initially applied to anyone on or near Federal Aid highways. 23 CFR Part 634 was incorporated into the 2009 Federal Highway Administration (FHWA) Manual on Uniform Traffic Control Devices (MUTCD). It now applies to workers on all public access roadways. It is enforceable by OSHA inspectors. Examples include, but are not limited to, construction, maintenance, survey, landscaping, towing, paving, flagging, emergency, and utility workers."

Warehouse workers, too should have a warehouse safety vest policy in warehouses and truck yards where there is high internal traffic and frequent loading operations.

Reflective Vest Standards

Reflective vests come in three safety standards: one, two and three. Category three offers the highest level of protection and is intended for workers who are at risk of being run over on the road. Category three offers the least protection and may be appropriate for warehouse workers. 

What garments meet the specified High Visibility requirements?

Only garments certified and labeled as ANSI/ISEA 107 and ANSI/ISEA 207, or in some cases certain firefighter standards, meet standard specifications for high visibility personal protective safety apparel in the U.S. On or near roadways, performance Class 2 or 3 ANSI/ISEA 107 garments are required for compliance with the worker high visibility regulation in the Federal Highway Administration (FHWA) Manual on Uniform Traffic Control Devices (MUTCD) Section 6D.03. The FHWA recognizes ANSI/ISEA 107 and 207 revisions starting in 2004 and going through the current ANSI/ISEA 107-2015 revision.

What is ANSI 107?

The ANSI/ISEA 107 American National Standard for High Visibility Safety Apparel and Accessories is a voluntary standard with guidelines that provide practical instruction regarding both reflective material and garment design to enhance worker visibility. ANSI/ISEA 107 presents three performance classes of garments and identifies garment types based on expected use settings and work activities being performed. These are designated as off-road (type O), roadway and temporary traffic control (type R), or public safety activities (type P).

Understanding the differences between the three ANSI classes

OSHA Hi Visibility Requirements ANSI Standards Chart

The classes are defined by the minimum amount of background and retro-reflective material, the configuration of the retro-reflective material, as well as other technical garment design requirements. A wearer shall select which class they wear based upon their own risk assessment.

ANSI Type O, Class 1 - Performance Class 1 offers the minimum amount of high visibility materials to differentiate the wearer from non-complex work environments and is only appropriate for off-road environments.

ANSI Type R or P, Class 2 - Performance Class 2 is considered the minimum level of protection for workers exposed to roadway rights-of-way and temporary traffic control (TTC) zones. Garments will have additional amounts of high visibility materials that allow for better definition of the human form.

ANSI Type R or P, Class 3 - Performance Class 3 provides more visibility to the wearer in both complex backgrounds and through a full range of movement by the required placement of background, retroreflective, and combined performance materials on the sleeves and pant legs (if present). Garments have an even a greater minimum level of high visibility material the apparel must contain. A garment or vest without sleeves worn alone is NOT considered Class 3 protection.

ANSI Class E - High visibility garments that do not qualify as meeting the requirements of the standard when worn alone, but when a Class E item is worn with a Class 2 or Class 3 garment, the overall classification of the ensemble is Class 3.

What is enhanced visibility? Is it the same as High Visibility?

No. The term enhanced visibility can be used for any garment of any color that has retro-reflective striping added to it in any configuration. These garments are not typically ANSI compliant and are for workers in lower risk environments. These workers can still benefit from the extra security of heightened visibility, particularly in low light conditions.

Is ANSI/ISEA 107 a law mandated by OSHA or other governmental agency?

NO. ANSI 107 is voluntary CONSENSUS standard. It is a specification for the construction of effective high visibility safety apparel. ANSI/ISEA 107 garments may be used to comply with Federal Regulations when properly applied, or may be specified voluntarily in work environments in response to the presence of struck-by hazards even when Federal regulations do not call it out.

I already have a uniform program, can I just add reflective stripes to these garments to get my employees into ANSI compliance?

NO. Reflective striping creates retro-reflectivity for darkness, but ANSI ISEA 107 clearly states that acceptable visibility must occur during daylight hours as well. Therefore, the ANSI standard dictates garment background colors to be specified Lime Green, Orange, or Red (colors considered fluorescent). Simply adding reflective striping to existing garments makes that garment “enhanced” visibility… but not ANSI/ISEA 107-compliant “high” visibility.

Can I be in ANSI compliance if I purchase reflective safety vests at my local discount retailer?

Possibly. But remember, retro-reflective and background materials must be certified to verify safety performance. Purchasing your safety PPE from The Man Store, where we apply conformity assessment practices to ensure ongoing compliance is best. As is often said, “You get what you pay for.”
How long will High Visibility/enhanced visibility garments last and remain ANSI compliant?
The service lifetime of the garment varies depending upon exposure to wear and tear, how long it is in use, and in what manner the items are maintained and laundered. Certified ANSI compliant retro-reflective garments that use 3M Corporation reflective tape products are of the highest quality. 

And for our Canadian Customers… What is the difference between ANSI/ISEA 107 and CSA Z96?

The Canadian Standards Association (CSA) created their own standard, CSA Z96 – High Visibility safety apparel, based on ANSI 107. While there are similarities in test methods used and photometric and retro-reflective performance of the materials used, there are significant differences in configuration of retro-reflective material and garment design requirements. This being said, although it is possible, a garment which is ANSI 107 compliant is not necessarily CSA Z96 compliant and vice versa.

Who Pays?

OSHA requires your employees wear protective equipment, but not that you pay for it. If you require workers to provide their own high-visibility clothes, you are responsible for ensuring they meet OSHA requirements and that they remain in usable condition after repeated wearing. You must also check that your workers actually wear the outfits

Tax Deductible

If your workers buy their own clothes, they may be able to deduct the cost on their taxes if they itemize deductions. They should check with their tax advisor or accountant to ensure proper claiming of these employee expenses. 

The Man Store has been the #1 in Industrial Safety Supplies since 2003. Visit our website to see why we say that “We help send the American worker home safely.”

For more information, please complete this contact formemail or call us:  (931) 651-1044

Note: This article contains information obtained from OSHA and various manufacturers, suppliers, and vendors.

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