High-Visibility Clothing Standard
The need to be seen is critical for worker safety. This is especially true for employees who work around moving vehicles or equipment. In an effort to prevent injuries and fatalities from “struck-by” hazards, workers wearing high-visibility garments help alert vehicle operators of their presence, especially in low-light environments.
In an Aug. 5, 2009 Interpretation Statement, the Occupational Safety and Health Administration (OSHA) clarified where workers are required to wear high-visibility garments: “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 (29 CFR 1926.201(1)) and when they are exposed to public vehicular traffic in the vicinity of excavations (29 CFR 1926.651(d)). 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 such workers, section 5(a)(1) of the OSH Act, 29 U.S.C. §654(a)(1), also known as the General Duty Clause, requires similar protection (...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...).”
Both OSHA and the U.S. Federal Highway Administration (FHWA) recognize the American National Standards Institute/International Safety Equipment Association (ANSI/ISEA) 107 standard as the industry consensus standard for the performance requirements of high-visibility work wear.
ANSI/ISEA 107-2015: American National Standard for High-Visibility Safety Apparel and Accessories
Published on Feb. 1, 2016, ANSI/ISEA 107-2015 combined two previously recognized high-visibility apparel standards (ANSI/ISEA 107-2010 and ANSI/ISEA 207-2011) into one. ANSI/ISEA 107-2010 covered high-visibility garment requirements for non-public safety workers; ANSI/ISEA 207-2011 covered public safety employees. While the two previous standards were very similar, the key difference was that the public safety employee standard allowed for less fluorescent background material to be used. This distinction was necessary to accommodate the equipment belts and identification panels required of public safety employees.
ANSI/ISEA 107-2015 breaks down high-visibility apparel into Types and Performance Classes. The environment in which the worker is wearing the garment dictates the type selected. The performance classes provide a range of design options that correspond with the level of risk and the visual conspicuity needs of the wearer.
The standard establishes three types:
- Type O (“off-road”)
- Type R (“roadway”)
- Type P (“public safety”)
Type O is defined as apparel that “provides daytime and nighttime visual conspicuity enhancement for workers in occupational environments which pose struck-by hazards from moving vehicles, equipment and machinery, but which will not include exposure to traffic on public access highway rights-of-way or roadway temporary traffic control (TTC) zones.” Examples of those who may need Type O apparel include:
- Workers retrieving shopping carts from parking areas
- Workers exposed to the hazards of warehouse equipment traffic
- Workers in oil and gas extraction, refineries and mines
Type R apparel “provides daytime and nighttime visual conspicuity enhancement for workers in occupational environments which include exposure to traffic (vehicles using the highway for purposes of travel) from public access highway rights-of-way, or roadway TTC zones or from work vehicles and construction equipment within a roadway TTC zone.” Examples of workers who may need Type R apparel include:
- Roadway construction workers
- Parking and/or toll gate personnel
- School crossing guards
- Towing operators
- Airport baggage handlers/ground crew
Type P apparel “provides daytime and nighttime visual conspicuity enhancement for emergency and incident responders and law enforcement personnel in occupational environments which include exposure to traffic (vehicles using the highway for purposes of travel) from public access highway rights-of-way, or roadway TTC zones, or from work vehicles and construction equipment within a roadway TTC zone or from equipment and vehicles within the activity area.” The purpose of this type is to offer additional options for emergency responders and law enforcement that have competing hazards or require access to special equipment. Examples of workers who may need Type P apparel include:
- Law enforcement personnel
- Emergency response personnel
- Firefighting personnel
- Road closure personnel
- Accident site investigators
ANSI/ISEA 107-2015 contains five 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
Each performance class has specific minimum design requirements regarding the background materials, retroreflective/combined performance materials and width of reflective materials used in the garments.
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 (Type O) environments.
Stepping up to Performance Class 2, the garment will have additional amounts of high-visibility materials that allow for better definition of the human form. Performance Class 2 is considered the minimum level of protection for workers exposed to roadway rights-of-way and TTC zones.
Performance Class 3 has an even a greater minimum level of high-visibility material the apparel must contain. This class 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). A garment or vest without sleeves worn alone is NOT considered Class 3 protection.
Both Performance Class 2 and Class 3 garments can be rated for either Type R or P environments. The distinction between a Type R or P rating lies under the required minimum levels for background material. A Class 2, Type R garment must contain a minimum of 775 square inches of background material while a Type P needs a minimum of 450 square inches. A Class 3, Type R garment needs at least 1240 square inches of background material while the public safety version needs 775 square inches.
An exception to the minimum background material requirement is made for the smallest sizes offered under Class 2 and Class 3, Type R apparel. To help ensure that smaller workers can wear high-visibility garments without creating additional safety hazards posed by oversized clothing, the smallest sized Class 2, Type R only needs 540 square inches of background material. The smallest Class 3, Type R needs a minimum of 1000 square inches.
Supplemental Class E is comprised of high-visibility garments such as pants, bib overalls, shorts and gaiters. These items do not qualify as meeting the requirements of the standard when worn alone, but when a Class E item is worn with a Performance Class 2 or Class 3 garment, the overall classification of the ensemble is Performance Class 3.
Optional high-visibility accessories are items such as headwear, gloves and arm or leg bands. These accessories are not intended to be used alone as high-visibility personal protective equipment and do not contribute to minimum area calculations that designate Performance Classes 1, 2 or 3.
Under ANSI/ISEA 107-2015, flame resistance must be addressed on the garment’s markings. If the garment meets one of the flame resistance test methods identified in 107-2015, the product needs to be marked in one of the following two ways:
- The garment 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.
If the garment does not meet any of the flame resistance 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.
Another key area covered in ANSI 107 is service life. It notes all high-visibility items have a limited lifetime that varies with use. It is the responsibility of the issuing entity, authorized on-site person, employer or wearer to periodically evaluate the minimum required visibility. Garments should be replaced or repaired when they are torn, noticeably faded, soiled, cracked, burned, heavily abraded or damaged.
The non-mandatory Appendix F addresses service life with more specificity: “The useful life of garments that are worn on a daily basis (is) six months. Garments that are not worn on a daily basis are expected to have a useful service life of up to three years.”
ANSI/ISEA 107-2015, American National Standard for High-Visibility Safety Apparel and Accessories
Occupational Safety and Health Administration (OSHA), High-Visibility Garment Interpretation Letter, Aug. 5, 2009
Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.
Think Safety. Think Grainger.®
Grainger has the products, services and resources to help keep employees safe and healthy while operating safer facilities. You’ll also find a network of safety resources that help you stay in compliance and protect employees from hazardous situations. Count on Grainger for lockout tagout, fall protection equipment, confined space products, safety signs, personal protective equipment (PPE), emergency response and so much more!
The information contained in this publication is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This publication is not a substitute for review of the current applicable government regulations and standards specific to your location and business activity, and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.
©2016 W.W. Grainger, Inc.