Safety Sense: The new Manual on Uniform Traffic Control Devices.
The U.S. Department of Transportation Federal Highway Administration published a revised version of the Manual on Uniform Traffic Control Devices in the Federal Register on Dec. 16, 2009.
This move followed the administration’s official notice on Jan. 2, 2008, of a proposed revision to the manual, which generated more than 15,000 comments. The last major revision had been published in 2003.
Anyone who uses the Manual on Uniform Traffic Control Devices (MUTCD) will find significant changes to the formatting of the entire publication. All paragraphs are now numbered sequentially, and italicized printing is used to segregate types of information. A change that I personally like is that all metric values were eliminated in the text and graphics in favor of English units. (Anyone wishing to use metric units can use the conversion chart provided in the appendix.) Some changes have also been made in the definitions section in Part 1 of the MUTCD.
You and your designated traffic control plan employees need to become familiar with the 2009 MUTCD. Following is an overview of some of the specific changes that may affect your operations.
The question of where the new manual applies introduces a major change in the way we have to look at this issue. Quite simply, the MUTCD now applies to all public roads and private roads open to public travel. In the past, only public roads were included. The exact definitions of both are:
- Public Road − any road, street or similar facility under the jurisdiction of and maintained by a public agency and open to public travel.
- Private Road Open to Public Travel − private toll roads and roads (including any adjacent sidewalks that generally run parallel to the road) within shopping centers, airports, sports arenas, and other similar business and/or recreation facilities that are privately owned but where the public is allowed to travel without access restrictions. Roads within private gated properties (except for gated toll roads) where access is restricted at all times, parking areas, driving aisles within parking areas, and private grade crossings shall not be included in this definition.
The only problem with exempting parking lots from private roads open to public travel is that no real guidance is provided as to what needs to be done for both the aisles and the parking spaces. There certainly needs to be some consideration for safety, and the Revised American National Standard for High-Visibility Safety Apparel and Headwear, ANSI/ISEA 107-2004, requires at least a Class I vest for parking-lot activities. It would appear the idea in the MUTCD is to cover all of the high-volume private roads while leaving a lot of flexibility for the other areas.
Additionally, while the MUTCD appears to allow less protection in the exempt areas, OSHA could still potentially cite a company under the General Duty Clause if a worker is injured in an area where no signs, barricades or other protection devices are present.
The bottom line is that most fieldworkers will need more safety training. Each field-crew leader almost needs to become an expert in the MUTCD. Additionally, before crews hit the pavement, companies should conduct a daily safety briefing that addresses the work employees will be undertaking and what protective devices they may need. The most important part of any plan is to train, train and train again.
Temporary Traffic Control Zones
By now, everyone should realize that a couple of cones and a $3.95 vest from the local hardware store are woefully inadequate for roadway safety. Every company has to make an investment in apparel, barricades and other control devices along with the extensive training already mentioned.
Under 6D.03, Worker Safety Considerations, the new manual has made some changes and provided additional clarifications regarding temporary traffic control (TTC) zones. The guidance section has broken down the requirements into five separate topics that provide recommendations for all traffic safety concerns in TTC zones (see sidebar). The standard states:
All workers, including emergency responders, within the right-of-way who are exposed either to traffic (vehicles using the highway for purposes of travel) or to work vehicles and construction equipment within the TTC zone shall wear high-visibility safety apparel that meets the Performance Class 2 or 3 requirements of the ANSI/ISEA 107–2004 publication entitled “American National Standard for High-Visibility Safety Apparel and Headwear” (see Section 1A.11), or equivalent revisions, and labeled as meeting the ANSI 107-2004 standard performance for Class 2 or 3 risk exposure, except as provided in Paragraph 5. A person designated by the employer to be responsible for worker safety shall make the selection of the appropriate class of garment.
Keep in mind that if someone is hurt due to a traffic incident and OSHA gets involved, it’s easy to make the case that not enough was done to protect the workers--even if you feel you complied with the standards. Always thoroughly cover the guidance section of each MUTCD area to make certain that you understand what the Federal Highway Administration is trying to accomplish and to know how the administration believes it can be done. Also, make sure you have a person in charge of traffic safety within your company as noted in the guidance section of the manual. Someone needs to make certain that all crews have the necessary training, equipment and other resources that may be needed to set up temporary traffic control zones as outlined under the temporary traffic control plan.
The new manual also includes changes to some of the recommended drawings for setting up temporary traffic control plans as well as some wording changes in the flagging section.
Implementing the Changes
The entire 2009 manual took effect on Jan. 15, 2010. However, each state that has its own approved MUTCD has a maximum of two years to make changes equal to or better than those made in the 2009 MUTCD. The best advice is to use the version that provides the highest level of safety since all federal standards are written as the minimal acceptable standards.
Additional compliance dates are listed in the manual--in fact, the introduction contains three pages of starting dates for the 2009 MUTCD. One important date for surveyors is Dec. 31, 2011, which is the date by which fieldworkers will have to comply with the changes for the wearing of Class II or III work apparel. That date also brings changes to the visibility requirements of flaggers.
Where Can I Obtain the New Manual?
This is a tricky question. National organizations such as the American Traffic Safety Services Association (ATSSA), the Institute of Transportation Engineers (ITE), the American Association of State Highway and Transportation Officials (AASHTO) and the International Municipal Signal Association (IMSA) have partnered to sell printed hard copies of the new manual. However, the Federal Highway Administration has said that the official 2009 edition is the electronic version posted on the administration’s Web site. If you purchase a printed copy, you should always check the Web site before making major decisions. It’s also a good idea to check at least once per month for any errata or changes to the most recent version.
This column should by no means be considered a complete list of all the changes in the new manual. Spend some time looking over the new MUTCD, and consider providing some training classes for your field personnel. Anything that can be done to protect your workers is a sound investment in your company’s future.
Author’s Note: The official 2009 Edition of the MUTCD is available in both PDF and HTML format at mutcd.fhwa.dot.gov/kno_2009.htm. The final rule, as published in the Federal Register, is at edocket.access.gpo.gov/2009/pdf/E9-28322.pdf.
Sidebar: Worker Safety Guidance
The following are the key elements of worker safety and TTC management that should be considered to improve worker safety as listed in the 2009 MUTCD:
A. Training -- all workers should be trained on how to work next to motor vehicle traffic in a way that minimizes their vulnerability. Workers having specific TTC responsibilities should be trained in TTC techniques, device usage, and placement.
B. Temporary Traffic Barriers -- temporary traffic barriers should be placed along the work space depending on factors such as lateral clearance of workers from adjacent traffic, speed of traffic, duration and type of operations, time of day, and volume of traffic.
C. Speed Reduction -- reducing the speed of vehicular traffic, mainly through regulatory speed zoning, funneling, lane reduction, or the use of uniformed law enforcement officers or flaggers, should be considered.
D. Activity Area -- planning the internal work activity area to minimize backing-up maneuvers of construction vehicles should be considered to minimize the exposure to risk.
E. Worker Safety Planning -- a trained person designated by the employer should conduct a basic hazard assessment for the worksite and job classifications required in the activity area. This safety professional should determine whether engineering, administrative, or personal protection measures should be implemented. This plan should be in accordance with the Occupational Safety and Health Act of 1970, as amended, “General Duty Clause” Section 5(a)(1) - Public Law 91-596, 84 Stat. 1590, December 29, 1970, as amended, and with the requirement to assess worker risk exposures for each job site and job classification, as per 29 CFR 1926.20 (b)(2) of “Occupational Safety and Health Administration Regulations, General Safety and Health Provisions” (see Section 1A.11).
Source: 2009 MUTCD, 6D.03 Worker Safety Considerations.