By Mark Stromme, Contributor
Employees are valuable assets to your company, and you’re required to protect them from hazards. Many hazards are obvious, such as getting electrocuted from exposed wiring or falling off a mezzanine or loading dock.
However, some hazards may not be as evident. One example would be employees who might not see a so-called, “struck-by” hazard. A common instance would be construction employees working in a highway work zone, where traffic is passing near them through the work zone at high speeds.
What is Hi-Visibility Apparel?
OSHA’s construction standard refers to hi-visibility apparel for workers performing flagging in work zones. The 1926.201(a) standard states the apparel must conform to the Manual on Uniform Traffic Control Devices (MUTCD) section 6E.02. This section explains the classes of hi-visibility apparel needed—specifically Class 2 or Class 3. The class is determined by the amount of retroreflective material on the garment.
Construction workers are not the only ones that can be affected by not being visible to vehicle and equipment operators. Employees working in general industry environments can also be exposed to struck-by hazards.
What Does OSHA Require?
General industry employers are required by OSHA to perform a hazard assessment and personal protective equipment selection per 1910.132(d). Even though hi-visibility apparel is not specifically mentioned in OSHA’s 1910 Subpart I, the hazard assessment could turn up the requirement for it. It’s important to remember that OSHA’s standards are only the base level of compliance; employers must go above and beyond them, as needed, to protect employees.
Application in General Industry
It makes sense that construction workers performing certain tasks might need to wear hi-visibility apparel. But, what about employees working in general industry environments?
What types of hazards could they be exposed to by not being readily visible to others?
Plenty of facilities have employees on foot working in and around moving equipment, such as powered industrial trucks, aerial lifts and golf cars. For example, employees may be in a warehouse or on a loading dock where illumination levels may not be the best, putting them in danger of being struck by the equipment. This is where the hazard assessment mentioned earlier becomes critical in identifying these hazards.
The hazard assessment requires the employer to select—and have affected employees use—hi-visibility apparel. In the case of the warehouse or dock worker, the employee must determine the amount of retroreflective material that is needed on the garment (i.e., the Class).
Most of the time, a safety vest with retroreflective material will be enough to ensure high visibility. This could include a Class 2 vest; or, maybe what is known as a “non-certified safety vest” will provide enough protection. The non-certified safety vest is not as visible as a Class 2 vest but might still provide enough protection. Rarely would a Class 3 safety vest need to be used in a general industry environment.
Other options for making employees visible in the workplace include lime green or orange t-shirts, retroreflective pants and hi-visibility hard hats.
What Employees Need to Know
Now that the employer has determined the need for, and selected the appropriate hi-visibility apparel, employees need to be trained on how to protect themselves in these types of hazardous environments.
Have employees follow these tips for staying safe when working around moving equipment:
- Face the equipment and make eye contact with the operator.
- Stay as far away from moving equipment as possible.
- Stay out of the equipment “blind spots.” If the employee can’t see the operator, the operator can’t see the employee.
- Be alert to equipment backup alarms, but remember some alarms may not provide enough warning.
- Approach equipment only after the operator acknowledges the employee’s presence and indicates it’s safe to approach.
- On a construction site, follow internal traffic controls, including instructions from spotters, signalers, flaggers or observers.
Being struck by equipment is a hazard that is sometimes overlooked at workplaces. One way to prevent this from happening is to assess the workplace and provide the necessary hi-visibility apparel—and to require employees to wear it. Keeping employees safe at work can be a challenge, but being proactive can reduce injuries and fatalities. WMHS
About the Author:
Mark Stromme joined JJ Keller & Associates, Inc. in 1994. With a background in monitoring OSHA, EPA and DOT regulations, he specializes in the OSHA 1926 construction and 1910 general industry regulations. His focus is on oil & gas safety, construction safety, electrical safety, mobile cranes, scaffolding, excavations & fall protection. An authorized OSHA Construction Outreach Trainer, Stromme is responsible for monitoring, analyzing and summarizing 1910 and 1926 regulations for various J. J. Keller guides, manuals and newsletters. (www.jjkeller.com/osha and www.jjkellerlibrary.com)