LHSFNA Comments on FHWA Rule
Responding to a request for comments on a proposed Federal Highway Administration (FHWA) rule to require the use of high-visibility safety apparel in work zones, the LHSFNA’s Occupational Safety and Health Division offered several suggestions to improve the rule.
The FHWA found that most state departments of transportation now already require all highway workers to wear class 2 or class 3 garments. Currently, about 90 percent of workers are covered. The proposed rule would require universal coverage.
Currently, about 100 workers a year are killed in work zones and about 20,000 are injured. About half of the fatalities are due to impacts by equipment within the work area; the other half are due to intruding motorists. Because both types of garments would make workers more visible to traveling motorists as well as equipment operators within work zones, the LHSFNA supports adoption of this universal requirement.
However, the OSH Division pointed out that neither class 2 nor class 3 garments ensure good visibility at night. Both provide retro-reflectivity, meaning they reflect light that is shined on them. While this would likely be helpful to an intruding motorist, it would not necessarily help an equipment operator who might be backing and giving off little light. Thus, the OSH Division recommended requiring garments supplemented by active illumination (light emitting diodes or electroluminescence sewn into the material) for night work as well as days with rain, smoke or fog.
The Division also pointed out that motorists are more likely to slow down when they know workers are present, yet a nighttime worker wearing the typical reflective stripes of class 2 and class 3 garments could be misidentified as a barrel. Thus, the Division recommended that workers be required to wear some reflective material on the arms, legs and hands (gloves) that would move with the worker and prevent a stationary appearance.
Also for night work, the Division recommended that the FWHA go beyond its high visibility garment requirement and require a spotlight that shines directly on flaggers, the most vulnerable of work zone workers.
Finally, the Division pointed out that many of the backing injuries and fatalities that occur in work zones are due to the large blind spots of construction vehicles. Whether day or night, high visibility garments would have no effect on these incidents. Thus, the Division recommended that the FWHA also require the use of one of three systems: 1) back-up video cameras or radar systems on vehicles to check the blind spots, 2) the use of spotters for all backing vehicles (now required in Washington State) or 3) internal traffic control plans (ITCPs) to control traffic flow through the work zone and to minimize backing operations.
The LHSFNA has taken a very active role in promoting work zone safety. It collaborated with a number of partners in the highly-acclaimed Roadway Safety training program. It has also published the Internal Traffic Control Plan brochure which is available, along with other work zone safety publications, through our online Publications Catalogue.