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, and 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) and 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.
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).
What’s the difference between the three ANSI classes?
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 a reputable safety supplier that applies conformity assessment practices to ensure ongoing compliance is generally 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. The safest way to go is to use a Rental Service supplier, like UniFirst, to maintain the garments properly, to gain the most wear life from them, and to get replacements when their useful reflective life has passed.
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.