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Q & A with Ken Wood and Janice Bradley on High Visibility Clothing Requirements
Since the clearinghouse hosted the Complying with the New FHWA Regulation on High Visibility Garments Webinar on September 4, 2008, we have received a lot of follow-up questions related to the requirements on high visibility garments. We interviewed Janice Bradley of ISEA and Ken Wood of FHWA. Below is a list of questions we asked and answers they provided.
Q: What is the current standard for safety garments? When will it be in effect?
A: [Janice Comer Bradley] The current standards for high visibility apparel are ANSI/ISEA 107-2004 Standard for High Visibility Safety Apparel and Headwear and ANSI/ISEA 207-2006 Standard for Public Safety Vests. A Department of Transportation, Federal Highway Administration Regulation 23CFR634 took effect on November 24, 2008. This regulation requires the use of class 2 or 3 garments that meet ANSI/ISEA 107-2004 for Workers*.
*Workers are defined as people on foot whose duties place them within the right-of-way of a Federal-aid highway, such as highway construction and maintenance forces, survey crews, utility crews, responders to incidents within the highway right-of-way, and law enforcement personnel when directing traffic, investigating crashes, and handling lane closures, obstructed roadways, and disasters within the right-of-way of a Federal-aid highway.
Q: What colors are approved for safety garments? Will orange or green colored tee shirts, without retroreflective material, comply with the current standard?
A: [Janice Comer Bradley] No garment that does not provide conspicuity for both day and night can comply with the requirements of the ANSI/ISEA 107-2004 or ANSI/ISEA 207-2006 standards.
Q: Do garments for firefighters specified in the older standard, such as 107-1999, meet the 107-2004 standard?
A: [Janice Comer Bradley] Not automatically. ANSI/ISEA 107-2004 has very specific requirements and mandatory reporting forms for the testing and certification of materials and the end garment. The form can be downloaded free from http://www.safetyequipment.org/107.htm.
Q: Can we use the vests that meet ANSI/ISEA 207-2006 standard?
A: [Janice Comer Bradley] Officially not until the MUTCD is published in 2009. This will revise the regulation to recognize 207 vests and the requirements will extend to all roadways, not just Federal-aid roads.
Q: Are mesh type vests recommended or should only fabric type be used?
A: [Janice Comer Bradley] The standard includes criteria for both knot and woven background material.
Q: Does the current standard also apply to law enforcement personnel handling incident management and traffic control in work zones?
A: [Janice Comer Bradley] Yes.
Q: What kind of vests do firefighters need to wear?
A: See FHWA's Final Rule on Worker Visibility (23CFR 634).
Q: Do you have a detailed summary of the contents of the ANSI/ISEA Standard 107-2004 for High Visibility Apparel? Your site (http://www.safetyequipment.org/hivisstd.htm) provides a brief 1-page summary, but with little detail.
A: [Janice Comer Bradley] Individuals needing the entire standard can order it from the following website: https://www.safetyequipment.org/userfiles/File/orderform09.pdf.
Q: How is FHWA going to enforce the new ANSI/ISEA retroreflective clothing requirements once in effect?
A: [Ken Wood] Like any other federal regulation, we can withhold federal funds from states that fail to comply with the regulation. In this case, however, the requirement covers persons not normally under the control of a state agency. The concern for their exposure to tort liability for failure to comply with the regulation will be strong incentive for their organizations to comply.
Q: Do you have a list of approved suppliers for ANSI compliant garments?
A: [Janice Comer Bradley] No.