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Reverse Signal Operations

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Reverse Signal Operations Program Summary

Information regarding vehicles, machinery, or equipment capable of operating in reverse and with an obstructed view to the rear. This program covers how requirements will be implemented at Virginia Tech.

Virginia Occupational Safety and Health (VOSH) adopted this unique standard to address accidents involving vehicles or equipment that were not previously covered by existing standards. The only enforcement tool to date has been the use of the "General Duty Clause". This clause was too general and did not establish the hazard as "recognized," nor did it lend itself to the consistent application of safety rules.

Construction work zone accidents involving fatalities from vehicles/equipment backing over people included dumpt trucks (majority of fatalities), cement trucks, fuel trucks, vacuum trucks, trackhoes, and similar equipment with an obstructed view by the operator to the rear.

General industry fatalities included vehichles such as tractor trailer trucks, logging vehicles, garbage trucks, and delivery trucks.

Some of the cases involved vehicles where reverse signal alarms were not operational, but other accidents occurred even with operational alarms. Employees apparently became de-sensitized to the sound of reverse signal alarms and other sounds in the work zone. Personnel behind the vehicle/equipment may not have been standing (ex. working on the ground or bending over) when they were struck. VOSH believes that employees will benefit from the increased safety requirements of this regulation.

Effective Date

The Reverse Signal Operation regulation became effective September 18, 2009. All sections of the regulation will be fully enforced starting October 19, 2009.

Regulatory Info

Review the standard: 16VAC 25-97

The program applies to any general or construction industry vehicle, machinery, or equipment capable of operating in reverse and which may have an obstructed view to the rear.  An "obstructed view to the rear" is anything that interferes with the driver's view to the rear of the vehicle at ground level. This includes structural members of the vehicle, its load, its height relative to ground level viewing, damage to windows or side mirrors, etc. used for rearview movements, restricted visibility due to weather conditions, or work being performed after dark without proper lighting.

Covered vehicles with an obstructed view to the rear shall not be operated in reverse unless:

  • The vehicle has a reverse signal alarm audible above the surrounding noise level;
  • Either the vehicle is backed up only when a designated observer or ground guide signals that it is safe to do so; and
  • Before operating the covered vehicle in reverse, the driver visually determined that no employee is in the path of the covered vehicle.

 

Reverse Signal Operations Online Program

Each department that owns or uses covered vehicles must ensure that all operators are trained in accordance with VOSH requirements for this program. This program applies to both general industry and construction vehicles, machinery, and equipment.

Scope

This program applies to all covered vehicles being operated by Virginia Tech personnel regardless of location, such as:

  • Pick up trucks and vans (depending on whether the rearview is likely to be obstructed or not);
  • Construction equipment, such as bobcats, front-end loaders, dump trucks;
  • Boom trucks;
  • Garbage trucks;
  • Cube vans; and
  • Tractor trailers.

Responsibilities regarding this program are covered in this section.

Environmental, Health & Safety

Environmental Health & Safety is responsible for developing, implementing, and administering the Reverse Signal Operations Program. This involves:

  • Training all drivers and ground guides/designated observers in the associated hazards and general safe work practices.
  • Maintaining centralized records of training and certification records.
  • Providing technical assistance to university personnel.
  • Evaluating the overall effectiveness of the program on a periodic basis.

Departments

Departments are expected to maintain a safe and healthy living, learning, and working environment for faculty, staff, students, and visitors to our campus. Departments must ensure equipment provided is of a safe design and in good condition and should designate responsible persons to coordinate the requirements of this program with employees.

Designated Ground Guides

Ground guides SHALL:

  • Be trained in the requirements of the regulation.
  • Always stay in the line of sight of the vehicle driver while it is backing up. Maintain visual contact with the driver at all times while the vehicle is operating in reverse.
  • Maintain a safe working distance from the vehicle.
  • Be provided with and wear during daylight hours, a safety vest/jacket in orange, yellow, strong yellow-green, or fluorescent versions of these colors.
  • Be provided with and wear at nighttime, a safety vest/jacket with retroreflective material in orange, yellow, white, silver, strong yellow-green, or a fluorescent version of these colors (visible at a minimum distance of 1,000 feet).

Ground guides SHALL NOT:

  • Perform any activities other than those related to the vehicle being signaled.
  • Use personal cell phones/headphones, etc. that could cause a distraction.
  • Walk close behind a vehicle that is backing up or cross behind in close proximity to a covered vehicle while it is operating in reverse.

Drivers/Operators

Drivers/operators of covered vehicles SHALL:

  • Be trained in the safety rules of this regulation.
  • NOT back up a vehicle unless they keep a constant line of sight of the ground guide. If the driver loses sight of the ground guide, he/she shall immediately stop the vehicle until the sight of the ground guide is regained and a signal is received from the ground guide to restart backup operations.

Employees/Pedestrians

Whereas the requirements of this regulation apply directly to employees in the vicinity of covered vehicles operating in reverse, we have equal concern for pedestrians on campus. At Virginia Tech, pedestrians will be included with employees in the vicinity of covered vehicles operating in reverse.

Employees/pedestrians must NOT walk close behind a vehicle that is backing up. If a driver/operator notices this situation, he/she should stop the vehicle immediately until the path is clear.

Contractors

Contractors must comply with all local, state, and federal safety requirements, and assure that all of their employees performing work on Virginia Tech properties have been suitably trained. Contractors must also comply with the requirements outlined in Virginia Tech's Contractor Safety Program.

Reverse Signal Operations Training

Drivers and designated ground guides shall receive initial training on reverse signal operation requirements and duties. Training is valid for five years.

Refresher training is required for any driver or ground guide when:

  • They have violated the regulation;
  • Been involved in a reverse operation accident or near miss; or 
  • Received an evaluation indicating they have not been operating under this regulation in a safe manner.

The Virginia Reverse Signal Operations Guide provides information regarding requirements (and exemptions) for personnel who operate vehicles in Virginia covered by the standard. 

Information on Preventing Backovers is also available on OSHA's website.

See the Responsibilities section of this program for information on duties.

General information and guidelines for reverse signal operations are provided below.

Backing Up

No employer shall operate any covered vehicle in reverse unless:

  • The covered vehicle has a reverse signal (i.e. back up) alarm that is audible above the surrounding noise level; and
  • The covered vehicle is operated in reverse only when a designated observer or ground guide signals that it is safe to do so; or
  • Before operating the covered vehicle in reverse, the driver visually determines that no employee/pedestrian is in the path of the covered vehicle.

Note: If the back up alarm stops working properly and an immediate fix is not possible that day, the vehicle shall be backed up using ground guide signals or the vehicle be taken out of service until the alarm is repaired.

Exemptions

The requirements of this regulation do NOT apply to the following:

  • Covered vehicles with operable video equipment, or similar technological capability providing the driver with a full view behind the vehicle, are exempt from the requirement to use a ground guide.
  • To the extent that any federal Department of Transportation (DOT) regulation applying to covered vehicles conflicts with this chapter, the DOT regulation shall take precedence.
  • Covered vehicles that did not have a back up alarm when manufactured, or were not later retrofitted with an alarm, are exempt from the requirement to have a back up alarm. 
    • Note: If the manufacturer offered the employer a back up alarm retrofit package at a reasonable and economically feasible cost and the employer did not have the retrofit package installed, this exemption does not apply.

 

Terms and definitions used in reverse signal operations.

Covered vehicles: Any general or construction industry vehicle, machinery, or equipment capable of operating in reverse and with an obstructed view to the rear.

General Duty Clause: "It shall be the duty of every employer to furnish to each of his employee's safe employment and a place of employment which is free from recognized hazards that are causing, or are likely to cause, death or serious physical harm to his employees..."

Ground guide: The person designated to observe and guide the covered vehicle during reverse signaling activities.

Obstructed view to the rear: Anything that interferes with the driver's view to the rear of the vehicle at ground level. This includes structural members of the vehicle, its load (e.g. gravel, dirt, machinery parts), its height relative to ground level viewing, damage to windows or side mirrors etc. used for rearview movements, restricted visibility due to weather conditions (e.g. heavy fog, heavy snow), or work being done after dark without proper lighting.

Reverse signaling activities: Includes, but is not limited to, collecting tickets from drivers, giving verbal instructions to drivers, and signaling to drivers once reverse operation of the covered vehicle has begun.

Reverse signal alarm: Adevice such as a horn (i.e. back up alarm) that is audible above, and distinguishable from, surrounding noise.


Frequently Asked Questions 

VOSH has the authority to monitor and inspect working conditions of covered employees engaged in rescue operations to make certain that all necessary procedures are being taken to protect the lives of rescuers. Where this rescue work is performed by the employer, VOSH standards apply.

Not necessarily. If the driver can see directly behind the vehicle at ground level by looking through a rearview mirror, or by turning around and looking out the rear window, then the view is not considered obstructed and the requirements would not apply.

However, if the pickup truck has a load that would obstruct the view when backing up, or if work is being done after dark without proper lighting, or if windows/mirrors are damaged, or if severe weather affects the view, then the requirements would apply. If the pickup truck has a camper shell, it must have a front and rear window so that the driver can see when backing up.

Yes. Covered vehicles with operable video or similar technological capability providing the driver with a full view behind the vehicle are exempt from the requirement to use a ground guide.

To the extent that any federal Department of Transportation (DOT) regulation applying to covered vehicles conflicts with this regulation, the DOT regulations shall take precedence.

Covered vehicles that did not have a backup alarm when manufactured, or were not later retrofitted with an alarm, are exempt from the requirement to have a backup alarm. Note: if the manufacturer offered the employer a backup alarm retrofit package at a reasonable and economically feasible cost, and the employer did not have the retrofit package installed, this exemption does not apply.

The requirements for reverse signal operations are based on existing OSHA requirements, such as the Logging Standard, 1910.266. VOSH/OSHA is not aware of any liability issues that did not already exist in the statutory or common law.

If an accident occurs "off road,"the VOSH regulations will apply, as will existing Worker's Compensation laws and regulations.

If an accident occurs on the highway or a street, the same laws will apply, along with existing traffic regulations that are enforced by the police and sheriff's office.

No. Most forklifts travel with the load in front of the vehicle and the driver should have a clear view when traveling in reverse. Some larger forklifts may have the height or structural members which would obstruct the rearview.

No. The standard allows for a second person to serve as a ground guide, OR the driver verifies that no person is in the path of the vehicle before backing up by checking live video views of the rear, exiting the vehicle and looking, or by driving past the space to be backed into first.

Small companies (i.e. less than 10 employees, sole owners, not incorporated, not a partnership) are exempt from VOSH requirements.

Larger companies should train their personnel the same as everyone else. Ex. UPS, FedEx, Contractors.

Anything that interferes with the driver's view to the rear of the vehicle at ground level. It includes:

  • Structural members of the vehicle;
  • The load being handled;
  • Height (relative to ground level viewing);
  • Damage to windows or side mirrors used for rearview movement;
  • Restricted visibility due to weather conditions (e.g. heavy fog, heavy snow); and
  • Work being done after dark without proper lighting.

Mainly bobcats, track hoes, and front-end loaders where the rearview can be obstructed by a structural member or damaged windows/mirrors. One solution would be to barricade the area of operation so that personnel are not in the "danger zone" when the equipment is running.

Equipment that rotates (ex. mobile cranes) is generally not covered since the operator can rotate to see if anyone is in the path of travel before proceeding.

All general industry and construction vehicles, machinery, or equipment capable of operating in reverse and with an obstructed view to the rear.

Examples include:

  • Cube vans;
  • Tractor-trailer trucks;
  • Garbage trucks;
  • Boom trucks;
  • Dump trucks;
  • Bobcats;
  • Front end loaders;
  • Pickup trucks with camper shells (possibly);
  • Flatbed trucks with a load (possibly); and
  • Cargo vans (possibly).

Documents


Contact Information

Robin McCall-Miller, Occupational Safety Program Manager

Phone: 540-231-2341
Email: rmmiller@vt.edu