OSHA and ANSI: How Do They Affect a Workwear Purchase?

How OSHA, the MUTCD and ANSI fit together

Each document answers a different question. Start with the work, then check which rules apply to it.

What OSHA requires of the employer

In general industry, 29 CFR 1910.132 requires employers to assess workplace hazards, select PPE to match them and certify the assessment in writing. Employers generally pay for the PPE they require. In construction, 29 CFR 1926.95(c), effective January 13, 2025, requires PPE of safe design and construction for the work, selected to properly fit each affected employee. Fit matters for high-visibility apparel. A vest that rides up, hangs open or sits under a jacket shows less of its material. Plan a size range that covers the whole crew, including smaller and women’s sizes, worn over the layers used on the job.

Where the MUTCD comes in

OSHA’s signaling rule, 29 CFR 1926.201(a), says flagger signaling, including the warning garments flaggers wear, must conform to Part 6 of the Manual on Uniform Traffic Control Devices (MUTCD). The MUTCD itself reaches beyond flaggers. Section 6C.05 of the 11th Edition says all workers within the right-of-way in a TTC zone, including emergency responders, shall wear ANSI/ISEA 107 Performance Class 2 or 3 apparel. The background must be fluorescent orange-red, fluorescent yellow-green or a combination. Flaggers should wear Class 3 at night. Firefighters exposed to flame, heat or hazardous materials may wear retroreflective turnout gear instead. OSHA has also issued an interpretation on high-visibility apparel in work zones.

Type O, R and P explained

ANSI/ISEA 107-2020 sorts garments by where they are worn, then by performance class. Type P is equivalent to the former ANSI/ISEA 207.

Is ANSI/ISEA 107 a legal requirement?

Not on its own. ANSI/ISEA 107 is a voluntary consensus standard, first published in 1999. It becomes mandatory when a regulation, agency or contract references it, as the MUTCD does for TTC zones. The standard defines garment types, performance classes, minimum material areas, background colors and labeling. The 2020 edition added criteria for single-use disposable coveralls and an option to measure nighttime luminance. Garment labels identify the standard, the garment type and the performance class. The standard does not decide which class a crew needs. That comes from the rule, contract or hazard assessment that applies to the job.

Who decides which class a crew wears?

The employer decides, through the hazard assessment, within any floor set by the MUTCD, an agency or a contract. A garment supplier does not choose the class. It builds the garment to the type and class the buyer specifies, and the finished configuration is confirmed for that order. Factors that shift the decision include traffic speed and volume, light level and shift timing, weather, background clutter, distance from moving vehicles and tasks that hold the worker’s attention. Record the decision and the reason for it, so later orders follow the same requirement rather than a remembered catalog name.

What the purchase specification should state

A clear specification lets every supplier quote the same garment and lets the receiving team check it.

• Standard and edition: ANSI/ISEA 107-2020.
• Garment type (O, R or P) and performance class.
• Background color allowed on site, plus tape color and layout.
• Size range, including the smallest size and women’s fits.
• Logo method, position and maximum size.
• Label content and documents expected for the finished garment.

Treat custom changes as a new configuration

Custom programs change the garment that was reviewed. A new body color, fabric, tape layout, pocket or logo position means the finished configuration must be reviewed again before anyone relies on an earlier class. A digital color preview shows direction only. Production color and any classification are approved on a physical sample. At Safvero, customization covers fabric and color, reflective tape, pockets, closures and hardware, logo methods, labels and packing. Record each change in the written specification.