3M’s five steps to MUTCD compliance
3M offers this formula for compliance to the recently updated Manual on Uniform Traffic Control Devices (MUTCD) regulations:
Step 1: Understand Your Obligations Under Federal Regulations
- The 2009 MUTCD is the primary regulatory document mandating the use of high-visibility apparel for all affected workers on roadways in the U.S. and will cover all roads “open to public travel.”
- All workers within the right-of-way are required to wear high-visibility safety apparel that meets performance Class 2 or 3 of ANSI/ISEA 107-2004, or equivalent revisions.
- For in-depth legislation updates review: MUTCD, OSHA General Duty Clause, OSHA Letter of Interpretation, #20080829-8611, which points to ANSI 107.
- See special options for Law Enforcement, and Emergency Responders to comply with gear meeting ANSI 207, and NFPA standards (such as NFPA1971).
Step 2: Complete a Risk Assessment for Each Job Function
- Determine the low-visibility hazards for each job description at your worksite, including the following:
- Workzone Hazards: Roadway traffic speeds, workers’ proximity to traffic and workzone equipment, task load.
- Environment Background: Time of day, seasons, weather, temperature exposure, equipment.
- Additional Considerations: Workplace exposure, garment appearance, laundry protocol.
Step 3: Identify Garment Options for Each Job Function
- Based on risk assessment choose Class per ANSI 107- 2010 (or 2004).
- Choose apparel types such as jackets, rainwear, tee-shirts, or vests.
- Conduct an onsite visibility demonstration and/or wear test to confirm choices
Step 4: Create Garment Specifications
- Prepare a specification that ensures that the garments you purchase comply with high visibility standards.
- Specify certified product only.
- Ensure the performance, color, sizing, customization, features, care guidelines, comfort, style and durability desired is received.
Step 5: Implement Garment Program
- Implement garment program, issue garments to workers.
- Continuous education and training.
- Importance of wearing garments in the workplace environment.
- How to wear and maintain the garments, and when to replace.
- Repeat assessments as needed and adjust program as necessary
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