High Visibility Clothing Updated Standards
OSHA Interpretation Statement – Aug. 5, 2009
The Occupational Safety and Health Administration (OSHA) explained in 2009 where workers are required to wear high visibility apparel: “Road and construction traffic poses an obvious and well-recognized hazard to highway/road construction work zone employees. OSHA standards require such employees to wear high visibility garments in two specific circumstances: when they work as flaggers and when they are exposed to public vehicular traffic in the vicinity of excavations. However, other construction workers in highway/road construction work zones are also exposed to the danger of being struck by the vehicles operating near them. For these workers, the General Duty Clause, requires similar protection.” The clause states high visibility apparel is required for “…employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees…”
American National Standards Institute/International Safety Equipment Association (ANSI/ISEA) 107 is recognized by both OSHA and the U.S. Federal Highway Administration (FHWA) as the industry standard for the performance requirements of high-visibility workwear.
ANSI/ISEA 107-2015 – Published Statement Feb 1, 2016
ANSI/ISEA 107-2015 combined two previously recognized high visibility apparel standards – ANSI/ISEA 107-2010 & ANSI/ISEA 207-2011 into one. ANSI/ISEA 107-2010 covered high visibility garment requirements for non-public safety workers, whereas ANSI/ISEA 207-2011 covered public safety workers. Although the two previous standards were similar, the fundamental difference was that the public safety worker standard allowed for less fluorescent background material to be used. This distinction was necessary due to the identification panels & belts required for public safety personnel.
ANSI/ISEA 107-2015 describes high-visibility apparel by 3 “Types” and 5 “Performance Classes” that apply to the type of work – off-road, roadway, or public safety. Therefore, the type of environment, worksite, or activity decrees the type selected. The performance classes provide an assortment of design preferences that match the risk level associated with the user and the visual awareness needed in order to be safe on the job.
The standard establishes three types:
- Type O “OFF ROAD”
- Type R “ ROADWAY”
- Type P “PUBLIC SAFETY“
Type O apparel as defined by ANSI “provides daytime and night-time visual conspicuity enhancement for workers in occupational environments which pose struck-by hazards from moving vehicles, equipment and machinery… but do not not include exposure to traffic on public access highway rights-of-way or temporary traffic control (TTC) zones.” Type O workers are usually recommended to wear a minimum amount of visibility as opposed to other Types. For example:
- Parking lot attendants who retrieve shopping carts
- Warehouse workers exposed equipment, machinery & traffic
- Oil and gas extraction, refineries and mine workers
Type R apparel is for workers in environments where “daytime and night-time visual conspicuity enhancement” is needed, especially for those in work environments where there is “exposure to traffic on public access highway rights-of-way, or roadway Temporary Traffic Control (TTC) zones.” For example:
- Roadway construction workers
- Utility workers
- Survey crews
- Railway workers
- Forestry workers
- Parking/toll gate personnel
- School crossing guards
- Towing operators
- Airport baggage handlers/ground crew
- Emergency Response Teams
- Accident Site Investigators
- Roadway Maintenance
- Flagging crews
Type P apparel “provides daytime and night-time visual conspicuity enhancement for emergency responders and law enforcement personnel.” These work environments usually pose “struck-by hazards” from moving vehicles and may include “exposure to traffic from public access highway rights-of-way, TTC zones, or from work vehicles and construction equipment within a roadway TTC zone or activity area.” Overall, the main purpose of Type P is to offer more options for emergency responders and law enforcement personnel that have challenging hazards or require more specialized safety apparel. For example:
- Law enforcement
- Emergency response
- Road closure
- Accident site investigators
ANSI/ISEA 107-2015 comprises 5 performance classes:
- Performance Class 1 Type “O”
- Performance Class 2 Type “R” or “P”
- Performance Class 3 Type “R” or “P”
- Supplemental Class E
- Optional High-Visibility Accessories
Every class has explicit minimum design requirements regarding the fluorescent background materials, retro-reflective materials and the width of materials used.
Performance Class 1 – Proposes a minimum amount of high visibility materials to differentiate the wearer from non-complex work environments. This class is only appropriate for off-road – “Type O” environments.
Performance Class 2 – Proposes that additional amounts of high visibility and/or reflective materials are to be used for Type R or P workers where more visibility of the human body is needed for those exposed to TTC zones and public access rights of way. Class 2 is considered the minimum class of protection for those exposed to this type of work.
Performance Class 3 – Proposes an even higher level of visibility and materials for Type R or P workers compared to that of Class 2. This class offers more or specialized visibility to the wearer in multifaceted and complex background situations. This is possible through the placement of retro-reflective and background materials as well as additional or other materials on the pant legs or sleeves.
Please note the distinction between a Type R or P rating is due to the required minimum levels for background material. A Class 2, Type R apparel requires a minimum of 775 sq. in. of background material while a Type P requires a minimum of 450 sq. in. A Class 3, Type R apparel requires at least 1240 sq. in. of background material while Type P requires 775 sq. in.
Class 3 Exception – An exception is made to the Type R apparel minimum background requirements for the smallest sizes offered under Class 2 and Class 3. This is to safeguard that smaller workers who require smaller apparel can still wear the apparel without creating an additional safety hazard due to oversized clothing. The smallest Type R Class 2 size is 540 sq. in. of background material and the smallest size Class 3 is 1000 sq. in. of background material.
Class E – This category applies to high visibility apparel such as trousers, bib overalls, and shorts that meet all minimum requirements for background material and retro-reflective striping. These items do not meet the standard when worn alone. However, when a Class E item is worn with Class 2 or Class 3 apparel, the overall classification is Performance Class 3.
Flame Resistant High Visibility Apparel
Action Apparel provides a vast selection of FR/ARC rated High Visibility apparel from the leading manufacturers. According to the ANSI/ISEA 107-2015 standards, flame resistant apparel must be marked on the item in one of the following ways:
- The label must include the letters FR followed by the designation of the specific ASTM standard used to evaluate flame resistance; or
- A separate label indicating certification to NFPA 1977 or 2112 must be attached.
Clothing not tested to meet Flame Resistant performance criteria listed in ANSI are required to have Non FR labeling. ASTM D6413 and NFPA 701 are not permissible as they allow for the material to melt. If the clothing does not meet any of the FR standards referenced in 107-2015, the garment must be marked with the following:
- This garment is not flame resistant as defined by ANSI/ISEA 107-2015 Section 10.5.