NOTE: I have never managed a facility/workforce where we required Hi-Vis garments, except for Fire Watches and PRCS Entry Attendants, but those requirements were not for the user's safety, so we did not get into all the ANSI requirements for these vests. However, I do equate this Hi-Vis effectiveness concern to what I dealt with regarding Flame Retardant Clothing (FRC) and its continued effectiveness. Just wearing the PPE is NOT all that matters - wearing PPE that will provide the level of protection we expect is KEY to protecting the user. ALL PPE will lose its effectiveness over time, and it is incumbent upon us to establish this time (with a safety margin included) to ensure the PPE can provide the level of protection we intended when specifying the need for said PPE.
I spent last night and this morning assisting with an industrial accident. The facility requires Hi-Vis clothing/vests and specifies they must be TYPE-R ANSI Class 2. I loved that they DEFINED and QUANTIFIED their requirements using an ANSI standard. I looked at the label in my assortment of Hi-Vis PPE and found a vest meeting this requirement. My Safety Helmet is also "Hi-Vis" with reflective stripping, but I got no credit for my HH. For the record, a TYPE-R ANSI Class 2 vest must have at least:
- 775 square inches of safety yellow or safety orange background material
- 201 square inches of reflective striping
- 1.38” width Minimums of Retroreflective Materials
This standard establishes the following properties for these functions of Hi-Vis garments:
- Color, Fluorescent Background Material
- Color, Bright Background Material
and
- Chromaticity Coordinates
- Minimal Luminance Factors
So, the standard has provided us a means to QUANTIFY these performance factors, but how do we go about testing these standards to ensure the garments still perform within these performance factors or at some lesser level, which we have declared acceptable?
Of the 20 or so people I came across during my 5-6 hours on site, only three (3) of us had on vests/uniforms that functioned as ANSI Class 2 High-Visibility garments with functioning reflective stripping: me, the safety manager, and the plant manager. All the field personnel who spent most of their time in the plant (safety committee members helping with the investigation, department supervisors, and maintenance personnel) had on vests or uniforms that were so worn out, torn, dirty, and missing most of the reflective stripping that these vests and uniforms were nowhere near meeting a TYEP R Class II Garment. This became VERY apparent in some of the investigation photos taken outside in poorly lit areas. (lighting was a contributing factor in this accident)
These hi-vis vests/uniforms had no impact on the accident. Still, we discussed their condition as they are being worn around rotating equipment and their ineffectiveness for PIT traffic within the facility grounds (i.e., the primary reason for the requirements).
This morning, the PM ordered 300 new vests and was embarrassed to learn that the inventory level was five (5) vests for ~210 people who wear them 12 hours/day in a “dirty process.” This inventory level has been at this for the past three (3) years (since Covid cost cutting). There is no means to launder these vests (some labels stated they could be laundered). As for the uniforms, most were severely faded, and more than half of the reflective stripping was missing or just no longer reflective.
This has become a sore spot for me as I see many of these high-visibility requirements as nothing more than a “safety parade.” The next time you pass through a road construction work zone, just look at the garments the workers wear on the road construction crews. Those crews are even REGULATED by OSHA under the Federal Highway Administration’s Manual on Uniform Traffic Control Devices (MUTCD) standard.
But all of this got me thinking:
Does ANSI have a means to functionally “test” the high-vis and reflective properties to determine when they continue to provide the level of safety intended by the original design standard? Is there a "testing frequency" or a means by which the user or employer can declare they are no longer effective and some actions are needed?
Or are these vests so cheap that "testing" would be too costly, and therefore, we simply need to establish a lifespan for these garments based on the environment(s) they are used in?
Does the same go for high-visibility and reflective uniforms? They, too, lose their effectiveness over time. But their replacement will likely be more costly than a $5-7 vest.
These vests/garments are indeed the responsibility of the employer under 1910.132(h) Payment for protective equipment.
I love the requirement of hi-vis, but when you're making a contractor wear some specific TYPE and CLASS of a garment on an accident scene where everything is shut down and isolated from the hazards requiring this specific PPE. Yet, those who work around it daily for 12 hours at a time can wear garments that do not even come close to meeting those same specifications; this is what I call a "safety parade." This damages the TRUST and CREDIBILITY of the safety efforts. It's nothing more than safety virtue signaling by requiring the special PPE in the name of safety but NOT maintaining that level of safety. And this is a HIGHLY VISIBLE (no pun intended) slap in the face to safety, meaning everyone at the discussion (except the PM) recognized the condition of the vests and uniforms and knew the inventory was ALWAYS OUT and the uniform complaints fell on "deaf ears."
1910.132(e) Defective and damaged equipment. Defective or damaged personal protective equipment shall not be used.
At what point do Hi-Vis garments become "defective/damaged"?
1910.132(f)(1)(v) The proper care, maintenance, useful life, and disposal of the PPE
This is one of the specific training requirements. For us to communicate the "useful life" of this hi-vis PPE, we first have to establish MINIMUM performance requirements and then provide a means/method for the user to establish when their uniform/vest no longer meets this performance level (e.g., it's useful life" has expired).
These are OSHA minimums! We can and must do better in the Year 2024!
