Moving to Compliance

Feb. 1, 2008
The National Highway Traffic Safety Administration reports that of the approximately 700,000 U.S. roadway workers in 2005, 1,074 lost their lives as a

The National Highway Traffic Safety Administration reports that of the approximately 700,000 U.S. roadway workers in 2005, 1,074 lost their lives as a result of motor vehicle traffic crashes occurring in highway construction and maintenance zones.

A National Highway Traffic Administration (NHTSA) report to Congress confirmed a clear link between struck-by-vehicle roadway crashes and poor worker visibility, and recommended that highway workers, emergency responders, law enforcement and other persons along a roadway be required to wear high-visibility safety apparel.

This subject has received considerable national attention, and the Federal Highway Administration Mandate 23 (CFR Part 634: Worker Visibility) addresses the issue directly. This regulation, which takes effect in November 2008, will require every worker within the right-of-way of a federal-aid highway who is exposed to traffic or construction equipment to wear high-visibility safety apparel that conforms with Performance Class 2 requirements of the American National Standard for High Visibility Safety Apparel and Headwear (ANSI/ISEA 107-2004), published by the International Safety Equipment Association.

ANSI/ISEA 107-2004 specifies the minimum amounts of component materials, colors and placement of elements required to sufficiently enhance worker visibility. It covers design, requirements for background and combined-performance retro-reflective materials, photometric and physical performance requirements for these retro-reflective materials and the specifics of care labeling.

Transportation safety officials in several states have taken early and pro-active measures to comply with FHWA worker visibility regulations and help improve the safety of their highway workers well in advance of the Federal Highway Administration Mandate 23 implementation date.

Worker comfort and convenience are high on the list of attributes that can lead to significantly improved worker participation in safety efforts. The universal objective is to have roadway workers in full compliance with visibility requirements from the time they leave home in the morning until they return at night. Use of traditional reflective vests alone often cannot satisfy this goal.

Early Steps in Missouri

Jean Endsley is the employee safety and health manager for the state of Missouri. She reports that concerns about the effectiveness and practicality of traditional reflective vests in her state led to a six-month pilot study in Missouri's 10 districts, and with Central Office Bridge Maintenance crews. The purpose of this test was to compare reflective vests with high-visibility T-shirts having reflective striping and made in accordance with ANSI Performance Class 2 standards.

“We were primarily interested in the potential for improved visibility and safety with high visibility fluorescent shirts compared to traditional vests,” she explained.

This Missouri pilot program consisted of specifying high-visibility fluorescent lime green T-shirts with reflective elements in accordance with the new ANSI/ISEA 107-2004 standard, and defining textile properties including moisture wicking and stain resistance. ?Vendor samples were tested in-house for reflectivity and other properties, and 1,100 shirts were purchased for field-testing.

“Acceptance of the high visibility shirts was overwhelming among MoDOT (Missouri Department of Transportation) crews, with visibility, comfort and overall safety each receiving high marks on the survey, “ Endsley said.

Positive feedback from contractors, emergency health workers, law enforcement and the general public reinforced the impression that the high-visibility fluorescent shirts improve worker visibility markedly compared to traditional vests. As a result, the Missouri safety management team recommended that fluorescent t-shirts be made available to all MoDOT field employees free of charge.

Maryland Implements a Full Garment Program

The state of Maryland has been an especially proactive leader in improving worker visibility. “Our safety management team is uncompromising when it comes to improving safety for the thousands of men and women working along Maryland roads, so we were very quick to embrace a new high-visibility garment policy,” said Maryland State Highway Administrator and Governor's Highway Safety Representative Neil J. Petersen.

Added Samuel P. Hall, a safety management consultant for the Maryland State Highway Administration (SHA): “Worker safety is the SHA's number one priority, because SHA does the majority of its road work at night to minimize impact on traffic flow. There have been fatalities and serious incidents related to inadequate worker visibility in past years.

“In 2006 a safety management team… conducted a review of work apparel worn by Maryland SHA employees and found that the only visibility aid in general use was the traditional orange clothing,” he said. “Other state-supplied garments such as shirts or jackets did not meet ANSI requirements, and provided insufficient visibility.”

Hall reports that the department set a goal of equipping workers for better compliance and optimum visibility. This process consisted of reviewing specific maintenance worker needs and offering garment choices that address ANSI standards requirements as well as worker preferences and varying weather conditions.

“The team evaluated apparel options with the assistance of visibility experts from 3M including fabric types, background colors and reflective materials and designs,” Hall said. “We then developed customized garment specifications for supplier bids. This process resulted in the development of a full line of visibility garments to meet the requirements of every season.”

According to Hall, the new policy requires SHA employees working on state highways and rights-of-way to wear a minimum of Class 2 apparel with a fluorescent yellow-green background material color as the outermost garment. Today all Maryland highway workers are equipped with a set of Class 2 ANSI/ISEA 107-2004 garments consisting of T-shirts, sweatshirts and Class 3 ANSI/ISEA 107-2004 jackets.

As a matter of policy, all non-SHA individuals working along all state right-of-ways also must wear approved Class 2 apparel that has either fluorescent orange-red or fluorescent yellow-green background material color as the outermost garment. These regulations give Maryland one of the strongest compliance programs of any state.

“It is our intent to be in full compliance with the mandate from day one, and that our safety goals be clearly communicated to SHA employees and to others who may be at risk of accidents in the roadway,” Hall continued.

“Since the implementation of Maryland's high visibility primary apparel program in 2005, there have been dramatic improvements in compliance and worker visibility compared to the days when orange clothing was the only garment requirement.”

Highway worker visibility activities in Maryland and Missouri clearly demonstrate the benefits of proactive safety administration and the support of departments of transportation and others in improved visibility. These states have achieved improved safety levels for highway workers by providing garments that meet ANSI standards and provide optimum visibility.

Moving Toward Compliance

Experience in these two states and elsewhere shows that the most effective approach is a consultative process, with a review of safety hazards by individual job category. It is important to select garment styles, designs and colors appropriate for the work environment. Visibility and garment applications expertise from specialists such as the 3M Company can be a valuable resource for safety managers and DOT officials in reviewing visibility conditions, apparel options and connecting with supply-chain resources.

Visibility garments once were specialty items available from only a few sources. Today, several of the work-wear garment manufacturers have joined the market with high-visibility clothing that make use of the latest fluorescent fabric and retro-reflective technologies with carefully conceived designs. As a result, safety managers who are working to meet the coming visibility mandate can chose from a wide range of effective clothing designs for all seasons - safety garments that offer visibility, seasonal functionality, comfort, style and safety.


Gary Pearson is marketing manager, 3M Visibility and Insulation Solutions, St. Paul, Minn. In addition to high-visibility products, the ISEA member company makes eye, face, head, hearing and respiratory protection, industrial first aid, instruments, and protective apparel. Reach Pearson at 651-737-4075 or [email protected].

Look for High-Visibility Products from ISEA Members

Protection Update readers are encouraged to specify high-visibility products from the following ISEA members:

  • Aearo Technologies
  • Avery Dennison Corp.
  • Blauer Manufacturing Co., Inc.
  • ERB Industries, Inc.
  • Ergodyne
  • Fechheimer Brothers Co.
  • Intex Corp.
  • Iron Horse Safety Specialists
  • Jackson Safety
  • M.L. Kishigo Manufacturing Co.
  • LaCrosse, Inc.
  • Lakeland Industries, Inc.
  • Logistical Services International, LLC
  • 3M Company
  • MCR Safety
  • Mine Safety Appliances Co.
  • NASCO Industries, Inc.
  • North Safety Products
  • OccuNomix International LLC
  • OK-1 Manufacturing Co.
  • Reflec-USA Corp.
  • Reflexite North America
  • Safe Reflections, Inc.
  • I. Spiewak & Sons, Inc.
  • Vizcon, LLC
  • Williamson-Dickie Manufacturing Co.

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