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High visibility clothing is required by law under the Personal Protective Equipment at Work Regulations Act 1992. But although the provision and wearing of high visibility clothing seems sensible, the law can often be misunderstood or misinterpreted. In this case, simply providing workers with high visibility coats may not be appropriate, and may in fact contravene the requirements of the PPE Act. In order to understand exactly what is meant by high visibility clothing, what the law requires employers and employees to do, and how this is to be interpreted, this article aims to set out a few of the requirements in plain English. The first requirement regarding any PPE clothing is that it is suitable for the risk. This means that by providing high visibility coats to all employees you may actually be providing equipment unsuitable for the risk. For example, if you have marshallers working in broad daylight you may only need to provide high visibility waistcoats. If they are working during the summer it may well be that thick coats would not only be uncomfortable, but could actually pose a health risk in themselves. The law requires that high visibility clothing should be suitable for the risk - and all that may be required in such a case is a simple high visibility waistcoat. However, should the marshallers be working in the winter, in fog or snow perhaps, then a high visibility coat may be more suitable, and more suited to the risk since visibility will be much poorer. To be visible to traffic employees will need to wear highly reflective and highly visible clothing. This may incorporate retroreflective strips - bands which reflect any direct or ambient light such as vehicle headlights. Whilst the fluorescent colour of the material contrasts well with the ambient background, retroreflective strips are still required in order to ensure that employees are visible from as far away as possible. The simple rule for high visibility clothing is that the darker the conditions, and the less visibility there is due to conditions such as fog or snow, the greater the level of clothing - both in terms of the amount of coverage, and the amount of reflective banding. Another issue regarding compliance with the law is ensuring that clothing is suited not just to the risk, but to the job as well. What's the difference between being suited to the risk, and suited to the job? A worker may be on a building site using machinery within an area where vehicles or traffic might be moving about. It is clearly important to make sure that high visibility clothing is provided to address the risk. However, since the job itself entails working with machinery, loose clothing such as a tabard may snag on machinery - thereby adding to the existing risk by creating a new one. It is important therefore to ensure that any PPE clothing addresses the existing risk without creating new risks. Comfort is an aspect of PPE clothing which should not be overlooked, and may actually relate to employee performance. PPE high visibility clothing which restricts the worker's own visibility, or restricts movement, or is loose and cumbersome, or too hot in summer or too cold in winter may all create issues which could have longer term consequences. When choosing high visibility clothing it will be important to consider the time of year and environmental conditions as well as the worker's size and physical requirements. It may well be prudent to provide a range of PPE clothing, some suited to winter and some for summer months, as well as a range of sizes. Perhaps one of the most critical aspects of PPE high visibility clothing is the standard. All HV clothing must comply with BS EN471, which is the European standard for PPE high visibility clothing. This is a very stringent set of requirements which requires demanding levels of visibility, manufacture and durability. However, it is not the case that all PPE HV clothing must meet the same standard, as EN471 details three classes. Class 3 offers the highest level of visibility, with Class 1 offering the lowest. Clearly a waistcoat cannot hope to provide the same level of visibility as a full coat, and so a lower class applies. When choosing high visibility clothing look for the 'CE' mark which demonstrates that the clothing meets with the European standards. However, it is important to remember that simply buying HV clothing that meets a certain standard does not imply that it will be suited to the job, or suited to the risk - these are aspects which will need to be decided within the company. Remember, all high visibility clothing must be provided to employees free of charge if they are to be exposed to any risk, and it must always be kept in good condition. Dirty or soiled HV clothing may well fail to meet the standard necessary. Storage facilities must be provided, as well as training where necessary. Employees must, for their part, wear the high visibility clothing provided as instructed, and comply with the employer's requirements for storage and use.
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