It is a well known fact that construction workers are at risk of being struck by vehicles when working near roadways, as well as by construction vehicles and equipment entering and leaving the work zone. What many people don’t realize is that workers are just as likely to be struck by vehicles and construction equipment inside the work zone. In fact, a NIOSH study concluded that 55 percent of the vehicle- and equipment-related struck-by fatalities in and around work zones occurred inside the work zone.

It isn’t difficult to understand why this should be the case. A number of things work against the goal of making workers visible to truck drivers and operators of excavators, bulldozers, backhoes, etc. Work areas are typically congested. Workers tend to wear clothing that blends in with the surroundings. Add to that inclement weather and/or night work, and worker visibility becomes an even bigger issue.

Regulations

Utility construction contractors and others responsible for work zone safety face the challenge of providing for not only the safe movement of vehicular traffic through the work zone, but also the safety of their workers. The Manual of Uniform Traffic Control Devices Part 6 (see mutcd.fhwa.dot.gov/HTM/2003/part6/part6-toc.htm) provides guidelines for the design and setup of temporary traffic control plans for work zones, but does not address the problem of workers being seen inside the work zone. (Section 6E.02 covers only the need for flag persons and law enforcement personnel directing traffic to wear high-visibility clothing.)

This oversight was addressed on Nov. 24, 2008, when the Federal Highway Administration (FHWA) mandated that “all workers within the right-of-way of a federal-aid highway who are exposed to traffic (vehicles using the highway for purposes of travel) or to construction equipment within the work area shall wear high-visibility safety apparel.” In so doing, the FHWA acknowledged that “the need to be seen [high-visibility apparel] is a critical issue for worker safety” and therefore a key element in decreasing the likelihood of worker injuries and fatalities caused by motor vehicles and construction vehicles and equipment.

High-Visibility Safety Apparel

The regulation 23 CFR Part 634 defines high-visibility safety apparel as “personal protective safety clothing that is intended to provide conspicuity during both daytime and nighttime usage and that meets the performance Class 2 or 3 requirements of the ANSI/ISEA 107-2004 publication entitled American National Standard for High-Visibility Safety Apparel and Headwear.”

High-visibility safety apparel is a black and white issue — so be sure to purchase and wear vests, shirts, sweatshirts, jackets, winter coats and more.

High-visibility safety apparel is readily available in many forms. For example, contractors can purchase vests, shirts, sweatshirts, jackets, winter coats and more. One important thing to remember is that it is not rated as Class 2 or 3 just because it is orange or lime green. ANSI Class 2 or 3 apparel will be tagged with the classification by the manufacturer.

The FHWA estimates that the average cost of an ANSI Class 2 garment is approximately $25. The price for vests and other garments will vary based on manufacturer, type, volume purchased and any stenciling that may be required. They also estimate that a garment (most likely a vest) will last approximately six months if worn every day by the worker. It may last longer or not as long depending on the climate, how soiled it gets, how often it is washed, how it is stored and otherwise cared for.

The American Traffic Safety Services Association offers the following criteria for determining when apparel should be replaced.

Acceptable apparel has excellent color contrast, excellent reflectivity and is not soiled.

Marginal apparel has some soiling and light fading of the material.

Unacceptable apparel has poor color contrast, low or no reflectivity, significant fading or soiling and deteriorated reflective stripes.

What color is best? Either orange or lime green will meet the requirement. If you can afford to go the extra mile in making workers more conspicuous in their environment, consider having them use bright lime/safety green garments in an environment of orange-colored vehicles, signs and construction barrels and bright orange/safety orange garments in predominantly green areas. Vests that combine both colors are also available.

When issuing garments make sure that each worker receives the proper size or that the garment is adjustable and can be adjusted to fit the worker properly. Garments that don’t fit properly can be both cumbersome and dangerous. With loose fitting garments especially there is the risk of its getting caught or tangled in machinery or equipment.
How many times have you observed a worker standing on the side of the road with an old, worn out, wide open vest and asked yourself why he or she is bothering to wear it at all? In addition to addressing the periodic need for replacement, be sure to instruct workers to wear the vests closed around their torso because they will not provide adequate visibility when viewed from different angles if worn wide open.

Last but not least, be sure to tell all employees when, where and why they are expected to wear the high-visibility apparel and how to properly use and take care of it.

Summary

All workers within the right-of-way on federally-funded construction jobs must wear high-visibility safety apparel. This includes construction and maintenance crews, flaggers, inspectors, engineers, surveyors and visitors to the jobsite.
Many states also have requirements for high-visibility garments, so be sure to check your state’s laws and regulations. Many contractors are voluntarily requiring workers on all jobsites to wear high-visibility apparel whenever they are working in close proximity to construction vehicles and equipment.

Although wearing high-visibility safety apparel is no guarantee that the driver/operator will see the worker, especially if the worker does not make an effort to be seen, it is my opinion that it does in fact help reduce the number of struck-by incidents at construction sites. So, think of high-visibility safety apparel as another piece of safety equipment that helps keep workers safe so they can go home at the end of the day (or night) uninjured. Make them visible!

Resources: NUCA members have access to two toolbox talks related to the subject of this article — Working around Equipment and Work Zone Safety.

George Kennedy is NUCA Vice President of Safety.