The same rules apply to high visibility (hi-vis) clothing as to other personal protective equipment (PPE): it should be used only if other measures are not feasible or do not provide adequate protection.
After the Health and Safety Executive's (HSE) announcement in 2017 that "being hit by a vehicle" was again one of the top three causes of a workplace fatality, I analysed every case HSE inspectors had taken earlier that year. Unsurprisingly, the biggest single fault mentioned was failure to segregate: to keep apart people and moving vehicles. However, the second biggest failing was "not having a safe system of work".
Hi-vis clothing is likely to be an important element of any safe system to minimise the risk of being hit by vehicles. As a result, anyone working in manufacturing, construction, logistics, waste management (or any other sector with moving vehicles) needs to know the essentials of choosing and using hi-vis correctly.
Selection
Choosing the correct garment requires care. Hi-vis should be made to a recognised standard and be suitable for both the wearer and the circumstances. The EN ISO 20471:2013 standard provides for three classes. Class 3 garments are the most conspicuous, having twice the reflective area and more than four times the fluorescent material area of a class 1 hi-vis. The type of garment also varies: class 1 will tend to be waistcoats (vests) whereas class 3 will tend to be sleeved jackets and coveralls.
The HSE's L25 guide, Personal Protective Clothing at Work, largely leaves the decision on which class of garment to wear to the individual employer's risk assessment. However, for road works, UK Department for Transport guidance sets the minimum as class 2, with class 3 recommended for motorways and other high-speed roads. Both workforce and site supervisory staff should wear hi-vis clothing at all times when on site. Workers who have to carry large items of equipment, or who are engaged in other work that may obscure their jacket/vest, should wear hi-vis trousers. Jackets should have full-length sleeves. However, should these present a risk in themselves -- say, from entanglement in moving tools or machinery -- three-quarter-length sleeves are acceptable.
Workers who have to carry large items of equipment should wear hi-vis trousers
The most common hi-vis colours are red, orange and yellow (seen by many as lemon green). In rail operations, orange is used to avoid confusion with signals or flags and because it stands out well against trackside greenery. Rail hi-vis should comply with RIS-3279-TOM, Rail Industry Standard for High Visibility Clothing.
Drivers
A category of user that is often forgotten on hi-vis provision is people who drive on business, whether or not they are in a company vehicle. For breakdowns, the Highway Code recommends drivers help other road users by "wearing light-coloured or fluorescent clothing in daylight and reflective clothing at night or in poor visibility". Many firms now provide a vest along with a basic first aid kit, ice scraper and tyre pressure/tread gauge in a simple vehicle safety pack. If you do this, advise employees to keep the vest handy inside the vehicle, say in the driver's door pocket. They can then don it as soon as they exit the vehicle.
Management issues
For people who work outside in all weathers, different hi-vis may be needed according to the seasons so that the worker is neither too cold nor too hot. In summer, the danger is of a token compliance with hi-vis rules (as when a vest is loosely tied around the waist, greatly reducing the material exposed and hence the conspicuity). Conversely, in winter, workers may be tempted to wear warm clothing that conceals the hi-vis, negating its value.
Solutions include larger sizes so that the vest can be worn comfortably over all other layers, or a winter jacket or suit that combines weather protection with hi-vis performance. Whatever the season, the guiding principle is to select the right garment for the circumstances, recognising that user acceptability is just as important as compliance with the technical standards: after all, what is not worn cannot protect. This is especially true in situations where most workers wear hi-vis: anyone who does not becomes invisible to vehicle drivers and mobile plant operators.
Maintenance
As with other items of PPE, hi-vis garments should have a regular check to make sure their conspicuity is maintained. Two key issues to look for are physical damage, especially to reflective strips, and general cleanliness: dirt can greatly reduce the garment's visibility and therefore its overall effectiveness. The garment should be cleaned according to the manufacturer's instructions and repaired. However, in the case of damage, replacement is often the only option.
Managers' responsibilities
Many employers think the duty is on them to provide hi-vis and on the employee to wear it. Although both are true (Personal Protective Equipment at Work Regulations 1992 as amended, regs 4 and 10), this is not the full picture. Regulation 10(1) is clear that the employer's duty goes well beyond "providing": they have a specific statutory duty to "take all reasonable steps" to ensure that the PPE is used properly. The guidance to reg 10 states that three such reasonable steps are:
- Give employees clear information and training so that they know when and where to use hi-vis
- Supervise use
- Carry out spot checks, whether the employees work on site or off site.
In a sound safety culture, it is not just managers and supervisors who challenge non-compliance. In one firm I worked for, a very junior engineer famously stopped a visitor to tell him he should be wearing hi-vis while walking along a particular site roadway. The visitor turned out to be none other than the UK chief executive. It would have been easy for him to reply along the lines of, "Do you know who I am?", but instead he graciously accepted the challenge, thanked the engineer and went to get his hi-vis. I say "well done" to both.
