Washington employers with workers near moving vehicles have two overlapping compliance obligations: federal OSHA requirements enforced by Washington L&I, and Washington-specific rules under WAC 296-155-200. The good news is that both point to the same standard: ANSI/ISEA 107-2020. The question most Washington contractors get wrong is not whether hi-vis is required, it is which class is required for which job and which conditions.
This guide covers exactly that, using Washington state rules, the current ANSI standard, and the January 2025 OSHA PPE fit update.
How Washington State Enforces Hi-Vis Requirements
Washington operates under a state OSHA plan through the Department of Labor and Industries (L&I), administered by the Division of Occupational Safety and Health (DOSH). This means Washington employers are regulated by L&I/DOSH rather than federal OSHA directly, though the standards align.
The Washington administrative code that governs hi-vis PPE for construction workers is WAC 296-155-200. It states that during daylight hours, when employees’ duties are performed in close proximity to moving vehicles, employers must ensure workers wear a high-visibility safety vest, shirt, or jacket that is fluorescent yellow-green, fluorescent orange-red, or fluorescent red. The garment must always be worn as an outermost layer.
During hours of darkness — defined as one-half hour before sunset to one-half hour after sunrise, and during other low-visibility conditions such as fog, heavy rain, and snow — WAC 296-155-200 requires a garment meeting ANSI/ISEA 107 Class 2 or Class 3 with retroreflective properties.
For work on Washington state DOT projects, WSDOT contractor specifications may impose requirements beyond the WAC minimums. If your company holds WSDOT contracts, confirm the project-specific requirements before outfitting your crew, as failing to meet WSDOT specifications can affect future contract eligibility.
L&I citations for PPE violations are serious. As of 2026, a serious OSHA violation carries a fine of over $16,000 per instance, and willful or repeated violations reach over $160,000. Beyond fines, a failed inspection delays projects and affects your safety record with general contractors who vet subcontractors on compliance.
What Is ANSI/ISEA 107 and Why Does It Apply in Washington?
ANSI/ISEA 107-2020 is the national standard for high-visibility safety apparel. ANSI develops voluntary consensus standards, but OSHA, and by extension Washington L&I references ANSI/ISEA 107 as the compliance standard for hi-vis PPE. Meeting ANSI/ISEA 107-2020 is how you demonstrate compliance when L&I inspects your job site.
The standard classifies garments by how much fluorescent background material and retroreflective tape they contain, and whether they are designed for roadway or off-road use.
The current edition, ANSI/ISEA 107-2020, supersedes the 2015 version. Garments certified to the 2015 standard still provide acceptable protection, but new purchases should meet the 2020 edition.
Northwest Custom Apparel Compliance with Safety Laws
Safety apparel laws in Washington State are generally required and noted in all government contracts. Northwest Custom Apparel complies with associations that write the standards for safety gear.
Northwest Custom Apparel represents Port Authority safety apparel. Furthermore, Our partnership with Port Authority dates back to 1977 in Seattle. The original name for Northwest Custom Apparel was Northwest Embroidery. We wanted to accommodate Seattle’s construction companies’ interests in custom safety apparel. Equally important, Port Authority safety jackets, t-shirts, and vests meet standards set by accrediting organizations.
ANSI (American National Standard) classification of ANSI/ISEA 107-2010 sets the flame-resistant (FR) apparel wear standard. Conversely, all safety wear isn’t flame-resistant. However, if the label (ANSI 107) is in the garment, it is flame resistant.
Why a specific label
Each piece of safety apparel must have a tag on the collar, which shows that the garment was manufactured according to National Standards.
Equally important, the label eliminates confusion about whether a piece is flame-resistant. Conversely, safety apparel made with polyester is not flame-resistant. Furthermore, it will melt when coming into contact with an igniter. Above all, Seattle electricians working on high-voltage lines need safety. Equally important, safety gear can’t ignite when working close to a high-voltage line.
ANSI Class 1, Class 2, and Class 3: What the Numbers Mean
What is ANSI Class 1 hi-vis apparel?
Class 1 provides the minimum level of visibility material. It is designed for environments where traffic speeds do not exceed 25 mph and workers are clearly separated from vehicle traffic.
Class 1 is appropriate for parking lot attendants, warehouse workers on private property away from public roads, and similar low-traffic situations. Class 1 is not appropriate for any Washington construction crew working on or near public roads.
What is ANSI Class 2 hi-vis apparel?
Class 2 is the minimum required for most Washington road-adjacent construction work. It requires a minimum of 775 square inches of fluorescent background fabric and 201 square inches of retroreflective tape. The reflective tape runs horizontally around the torso and vertically over the shoulders.
Class 2 is appropriate for road construction crews on roads with traffic speeds between 25 and 50 mph, crossing guards, survey crews, and general construction workers where the site hazard assessment identifies moderate traffic exposure.
Most Washington general contractors require Class 2 as a blanket minimum across their entire site, regardless of whether every worker is directly in the roadway.
What is ANSI Class 3 hi-vis apparel?
Class 3 provides the highest level of visibility. It requires a minimum of 1,240 square inches of fluorescent background fabric and 310 square inches of retroreflective tape. Class 3 garments must include sleeves — a vest alone cannot achieve Class 3 rating because sleeves are required to meet the background area minimum.
Class 3 garments must make the wearer identifiable as a human from a minimum distance of 1,280 feet.
Class 3 is required for workers on roads with posted speeds above 50 mph, night shift workers and those working in low-visibility conditions (fog, heavy rain, snow), flaggers on high-speed roads, highway construction workers, utility workers maintaining infrastructure along Washington interstates and state routes, and emergency responders on active roadways.
The cost difference between a Class 2 and Class 3 garment is typically a few dollars. When in doubt, choose Class 3. There is no compliance penalty for exceeding the minimum requirement.
Type R, Type O, and Type P: Why Garment Type Matters
Beyond the class number, ANSI/ISEA 107 designates garments by type based on the work environment.
Type R (Roadway) is required for any worker exposed to traffic on public roads. This covers virtually every Washington construction, electrical, HVAC, and utility crew working near streets, highways, or state routes. Type R is the default for Washington construction.
Type O (Off-Road) is designed for workers not exposed to roadway traffic — warehouse employees, rail workers, and indoor facility staff. Type O garments are not compliant for roadway use.
Type P (Public Safety) applies to law enforcement and emergency responders.
The compliance label on any garment you purchase must show the ANSI/ISEA 107 edition year, the Type designation, and the Class. If any of those are missing, the garment is not certified compliant regardless of what the packaging says.
Which Class Does Each Washington Worker Need?
| Worker Role | Environment | Minimum Class Required |
|---|---|---|
| Flagger (daytime, road speed under 50 mph) | Public road | Class 2, Type R |
| Flagger (road speed above 50 mph or low-visibility) | Public road | Class 3, Type R |
| Road construction crew (daytime) | Highway work zone | Class 2, Type R |
| Road construction crew (night shift or fog/heavy rain) | Highway work zone | Class 3, Type R |
| Utility worker near traffic | Public right-of-way | Class 2, Type R minimum |
| Survey crew near traffic | Public road | Class 2, Type R |
| HVAC / electrical crew near traffic | Urban street | Class 2, Type R |
| Construction crew on WSDOT project | State highway | Confirm project specs — often Class 3 |
| Warehouse worker (forklift area) | Private property | Class 2, Type O (no public road exposure) |
| Parking lot attendant | Low-traffic private | Class 1 acceptable |
The Class E Combination: How to Achieve Class 3 Without a Full Class 3 Jacket
Class E is a special designation for hi-vis lower body garments such as pants, coveralls, or bibs with fluorescent and retroreflective material. When a worker wears a Class 2 vest or shirt combined with Class E pants, the ensemble meets the Class 3 material minimums.
This combination gives Washington crews flexibility in warmer months. A worker who needs Class 3 compliance on a summer highway job can achieve it with a Class 2 vest plus Class E pants rather than a full Class 3 insulated jacket. In cooler months or night shifts, a Class 3 insulated jacket or parka as the outermost layer is the more practical solution.
The Pacific Northwest Rain Problem: Compliance and Layering
This is the most common compliance error on Washington construction sites, and it does not come up in most hi-vis guides written for other regions.
Washington’s climate means workers frequently layer in cooler, wet months. The critical rule is this: whatever is on the outside is what counts. If a worker wears a compliant Class 2 hi-vis vest underneath a standard non-hi-vis rain jacket, they are not compliant. The hi-vis layer must be the outermost visible garment.
For Washington crews working in rain and cold, the solution is an ANSI-rated hi-vis rain jacket or insulated hi-vis parka worn as the outer layer, not a non-hi-vis shell over a hi-vis vest. ANSI-rated rain gear that meets Class 2 or Class 3 requirements is available from Carhartt, Portwest, Radians, and Helly Hansen Workwear.
The same rule applies to cold weather. A Class 2 hi-vis hoodie or insulated jacket worn as the outermost layer satisfies the requirement while keeping workers warm. A non-hi-vis jacket worn over a hi-vis vest does not.
The January 2025 OSHA PPE Fit Rule: What Changed for Washington Employers
Effective January 13, 2025, OSHA updated its PPE standard for the construction industry to require that all personal protective equipment, including high-visibility vests properly fits each individual worker.
This means Washington employers can no longer hand out one-size-fits-all vests from a communal bin and call it compliant. A vest that is so oversized it becomes a snag hazard, or so small it does not meet the minimum coverage area, no longer satisfies the standard.
Practical steps for Washington employers to comply with the 2025 fit rule:
- Document hi-vis garment sizing in your written PPE program for each worker.
- Conduct a written hazard assessment that identifies the class required for each work environment.
- Purchase correctly sized garments per worker, not shared bins.
- Establish a garment inspection and replacement schedule.
Washington L&I enforces this update as part of WAC 296-155-200 PPE requirements.
When Does a Hi-Vis Garment Stop Being Compliant?
A garment is compliant when manufactured and labeled to ANSI/ISEA 107-2020 standards. It becomes non-compliant when the fluorescent material fades or the retroreflective tape peels, tears, or loses reflectivity through washing and UV exposure.
Industry guidance on replacement timelines:
- Garments worn daily should be replaced every 6–12 months.
- Garments used occasionally can last up to 3 years if stored away from UV exposure.
- Garments exposed to chemical wash agents degrade faster than those hand-washed or machine-washed with standard detergent.
- Inspect retroreflective tape before each use. If it no longer reflects light clearly at night, replace the garment.
The compliance label on a garment tells you it was compliant when manufactured. It does not tell you whether it is still compliant after months of washing, outdoor UV exposure, and daily wear. Inspection is the employer’s responsibility.
Can You Add a Company Logo to a Compliant Hi-Vis Garment?
Yes, with placement restrictions. Washington construction companies, electrical contractors, and HVAC companies that want crew members to wear branded hi-vis apparel can add company logos through embroidery or screen printing, provided:
- The logo does not cover any retroreflective stripe or tape.
- The logo does not reduce the fluorescent background area below the class minimum (775 sq inches for Class 2, 1,240 sq inches for Class 3).
- The garment label still shows ANSI/ISEA 107-2020 compliance after decoration.
Learn how logo embroidery placement works on hi-vis garments
For Class 2 compliant shirts, the standard left-chest logo placement (3–4 inches wide) is safe if positioned between the reflective stripes, not across them. Full back logos require careful review against the background area minimum.
NW Custom Apparel reviews logo placement against ANSI compliance requirements before production on every hi-vis shirt order. We decorate compliant garments for Washington construction crews, general contractors, electrical companies, and HVAC teams from our Milton, WA facility. See custom hi-vis safety shirts with company logo embroidery for Washington crews for available styles and ordering details.
For garment types available for branding, the most common orders from Washington workwear programs are hi-vis polo shirts (Class 2 compliant with logo on left chest), hi-vis safety shirts, and hi-vis insulated jackets. See hi-vis polo shirts for Washington crews who need Class 2 compliance and custom embroidered work jackets for Washington construction crews for options.
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Discover Screen Printing SolutionsFrequently Asked Questions
WAC 296-155-200 requires workers near moving vehicles to wear hi-vis outer garments. For road-adjacent construction work, ANSI Class 2, Type R is the minimum. Class 3 is required for workers on roads with speeds above 50 mph, night shift workers, and workers in low-visibility conditions such as fog or heavy rain.
Washington operates under a state OSHA plan. L&I’s Division of Occupational Safety and Health (DOSH) enforces workplace safety rules in Washington. The applicable Washington regulation is WAC 296-155-200, which aligns with federal OSHA requirements but is enforced by L&I, not federal OSHA.
Class 2 requires 775 square inches of fluorescent background fabric and 201 square inches of retroreflective tape. Class 3 requires 1,240 square inches of background and 310 square inches of retroreflective tape. Class 3 must include sleeves and must make the wearer visible from at least 1,280 feet.
Flaggers on public roads must wear Class 2 hi-vis at a minimum. Class 3 is required when flagging on roads with speeds above 50 mph or in low-visibility conditions such as night, fog, or heavy rain. This is an FHWA/MUTCD requirement incorporated by OSHA and enforced by Washington L&I.
Yes. Combining a Class 2 vest or shirt with ANSI Class E hi-vis pants creates an ensemble that meets Class 3 material minimums. This is an accepted compliance method under ANSI/ISEA 107-2020.
Yes. Your outermost layer must be the compliant hi-vis garment. Wearing a non-hi-vis rain jacket over a hi-vis vest means the hi-vis is no longer your outer garment, and you are not compliant. Washington crews working in rain need ANSI-rated hi-vis rain jackets as the outer layer.
Yes, with placement restrictions. The logo must not cover retroreflective strips and must not reduce the fluorescent background area below the class minimum. NW Custom Apparel reviews placement compliance before decorating hi-vis garments for Washington crews.
Daily-use garments should be replaced every 6–12 months. Inspect retroreflective tape before each shift. If the tape no longer reflects light clearly or the fluorescent fabric has visibly faded, the garment is no longer compliant and must be replaced.
Order Custom Hi-Vis Workwear for Washington Crews
NW Custom Apparel decorates ANSI-compliant hi-vis shirts, polo shirts, and jackets for Washington construction companies, electrical contractors, HVAC teams, and road crews from our Milton, WA facility. Every order includes compliance review of logo placement against ANSI Class 2 and Class 3 material minimums before production.
Since 1977, Northwest Custom Apparel has been Seattle’s supplier of custom-printed safety gear. Safety vests with company logos are available to screen print or heat transfer. Safety green t-shirts are our best sellers and are available with a custom-printed company logo. Uniquely, big-sized safety green t-shirts come in sizes up to 5XL.
For custom corporate workwear and uniform programs for Washington businesses that include hi-vis garments, contact us at 1-800-851-3671 or sales@nwcustomapparel.com.
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