

                                       
                                  MEMORANDUM
                                       
Date:	August 17, 2020
From:	Carlie Knope, Taylor Carlough, and Chet Fenton, Eastern Research Group, Inc.
To:	Tom Ransdell (OSHA ORA)
--------------------------------------------------------------------------------
Subject:	ERG Cost Model for Safety Vests
To inform OSHA's sensitivity analysis of costs for items that are not of universal fit or reimbursed by employers, Eastern Research Group, Inc. (ERG) estimated the costs of requiring safety vests on construction sites for NAICS 236 (Construction of Buildings), 237 (Heavy and Civil Engineering Construction), and 238 (Specialty Trade Contractors). 
To estimate the number of workers that are required to wear safety vests, ERG used Bureau of Labor Statistics (BLS) Occupational Employment Statistics (OES) data for certain construction-specific occupations across the three NAICS codes in the construction sector in conjunction with ERG estimates of the percentage of those employees that are required to wear a safety vest. To estimate the cost, we paired the employment estimate with the unit costs of both ANSI Class 2 and Class 3 safety vests and an estimate of the average lifetime of such vests.
Table 1 summarizes the number of employees estimated to wear vests and the total annual costs of those vests.
Table 1. Summary of Affected Employees and Total Annual Costs
                                     NAICS
                                   Industry
                            Employees Wearing Vests
                              Total Annual Costs
236
Construction of Buildings
                                                                        134,911
                                                                     $1,258,396
237
Heavy and Civil Engineering Construction
                                                                        469,370
                                                                     $4,364,018
238
Specialty Trade Contractors
                                                                        223,897
                                                                     $2,076,529
Total
                                                                        828,178
                                                                     $7,698,943
Sources: BLS, 2020; Safety Gear Online, 2020b; Safety Gear Online, 2020c; ERG estimates.
Step 1: Develop List of Occupations that might Wear Vests
ERG identified which Standard Occupational Classification (SOC) codes represent employees in the construction sector that might need safety vests for improved visibility on construction sites. The list of SOCs that ERG generated is based largely on whether a given occupation would work on or near highways and roadways, but additionally includes workers operating or working near heavy equipment, who might also require vests for additional visibility.
The initial list of SOCs to consider follows. (Note that not all SOCs presented below are included for each of the three NAICS).
Surveyors (17-1022)
Health and Safety Engineers (17-2111)
Security Guards (33-9032)
Construction Laborers (47-2061)
Paving, Surfacing, and Temping Equipment Operators (47-2071)
Pile Driver Operators (47-2072)
Operating Engineers and Other Construction Equipment Operators (47-2073)
Helpers, Construction Trades (47-3019)
Construction and Building Inspectors (47-4011)
Highway Maintenance Workers (47-2051)
Radio, Cellular, and Tower Equipment Installers and Repairers (49-2021)
Electrical Power-Line Installers and Repairers (49-9051)
Telecommunications Line Installers and Repairers (49-9052)
Welders, Cutters, Solderers, and Brazers (51-4121)
Welding, Soldering, and Brazing Machine Setters, Operators, and Tenders (51-4122)
Table 3 presents the total employment across the three NAICS. 
Step 2: Estimate the Number of Employees Wearing Vests
ERG next estimated the percentage of employees that would wear a safety vest, based both on the industry in which these employees work and the type of work performed (see Table 2). We estimate that all of the SOCs identified above that are employed in NAICS 237 (Heavy and Civil Engineering Construction) and all flaggers wear vests, as this primarily includes work on or near highways and roadways of the sort identified in OSHA's (2004; 2009) Standard Interpretations regarding vests. Other occupations are estimated wo wear vests based on the amount of their work likely to be near roadways or heavy machinery (as opposed to, for instance, primarily performing work inside buildings).  
Table 2. Percentage of Workers Wearing Vests by Category
                                   Category
                                % Wearing Vests
NAICS 237 Heavy and Civil Engineering Construction
                                                                           100%
Flagger
                                                                           100%
Surveyor
                                                                            75%
Heavy Equipment
                                                                            25%
Other Construction Workers
                                                                            50%
Not Near Road
                                                                             5%
Source: ERG estimates.
ERG also estimated the percentage of vest-wearing employees that require an ANSI Class 2 safety vest versus those that require a Class 3 safety vest. Class 2 vests are "...intended for working environments that pose a greater risk. This can include workers who are on a roadway where traffic is moving under 50 mph." Class 3 vests "Class three vests are reserved for people working in the most dangerous environments where visibility is the highest priority. This includes roadways where traffic is traveling in excess of 50mph" (Safety Gear Online, 2020a). 
ERG estimated that all crossing guards and flaggers are required to wear Class 3 safety vests (OROSHA, Undated). For all other occupations, we estimate that 50 percent of employees would need to wear a vest wear a Class 2 vest and the other 50 percent a Class 3 safety vest. 
Table 3 summarizes the estimated number of employees needing to wear vests by NAICS.
Table 3. Employees Wearing Safety Vests
                                     NAICS
                                   Industry
                       Employees in Relevant Occupations
                            Employees Wearing Vests



                                    Class 2
                                    Class 3
                                     Total
236
Construction of Buildings
                                                                        295,450
                                                                         67,381
                                                                         67,531
                                                                        134,911
237
Heavy and Civil Engineering Construction
                                                                        469,370
                                                                        233,110
                                                                        236,260
                                                                        469,370
238
Specialty Trade Contractors
                                                                        581,740
                                                                        111,554
                                                                        112,344
                                                                        223,897
Total
                                                                      1,346,560
                                                                        412,044
                                                                        416,134
                                                                        828,178
% of Total
                                                                             -- 
                                                                          30.6%
                                                                          30.9%
                                                                          61.5%
Sources: BLS, 2020; ERG estimates.
Step 3: Estimate Unit Costs
Table 4 shows the unit costs of ANSI Class 2 and Class 3 vests (using the minimum price of the options listed). According to Safety Gear Online (2020b; 2020c), there is a different vest for surveyors, so ERG's findings include a slightly higher cost for these surveyor vests.
Table 4. Unit Costs
                                     Type
                                   Unit Cost
Class 2 Vest
                                                                         $4.80 
Class 2 Surveyor Vest
                                                                        $10.43 
Class 3 Vest
                                                                        $13.69 
Class 3 Surveyor Vest
                                                                        $18.49 
Sources: Safety Gear Online, 2020b; Safety Gear Online, 2020c.
Step 4: Calculate Total Costs
To estimate total costs, we multiply the number of employees needing vests (from Step 2) by the unit cost for each type of vest (from Step 3). We additionally account for the fact that the average life expectancy for safety vests is about 6 months (Work Zone Safety, 2012; Viewbrite Safety Products, 2011), so each affected employee would need two vests per year.
Table 5 shows the costs of vests by NAICS industry. ERG estimates that the total cost to provide 828,178 employees across the construction sector (NAICS 236, 237, and 238) two safety vests per year is about $7.7 million.

Table 5. Total Costs
                                     NAICS
                                   Industry
                            Employees Wearing Vests
                               Total Annual Cost
236
Construction of Buildings
                                                                        134,911
                                                                    $1,258,396 
237
Heavy and Civil Engineering Construction
                                                                        469,370
                                                                    $4,364,018 
238
Specialty Trade Contractors
                                                                        223,897
                                                                    $2,076,529 
Total
                                                                        828,178
                                                                    $7,698,943 
Sources: BLS, 2020; Safety Gear Online, 2020b; Safety Gear Online, 2020c; ERG estimates.


SOURCES
Bureau of Labor Statistics (BLS). (2020). Occupational Employment Statistics - May 2019 (Released March 31, 2020). Available at https://www.bls.gov/oes/tables.htm (Accessed April 3, 2020)
Eastern Research Group, Inc. (1998). Patterns of PPE Provision (Docket ID OSHA-S042-2006-0667-0002). Available at https://www.regulations.gov/document?D=OSHA-S042-2006-0667-0002 (Accessed August 10, 2020)
Employer Payment for Personal Protective Equipment. 72 FR 64342-64430
Gallagher Uniform. (2018). What Occupations Require High Visibility Uniforms? Available at https://www.gallagheruniform.com/news/occupations-require-high-visibility-uniforms/ (Accessed August 14, 2020)
Occupational Safety and Health Administration (OSHA). (2004). Standard Interpretations - Requirements for use of high-visibility warning garments by construction workers in highway work zones. May 11, 2004. Available at https://www.osha.gov/laws-regs/standardinterpretations/2004-05-11 (Accessed August 17, 2020)
Occupational Safety and Health Administration (OSHA). (2009). Standard Interpretations - Whether use of high-visibility warning garments by construction workers in highway work zones is required. August 5, 2009. Available at https://www.osha.gov/laws-regs/standardinterpretations/2009-08-05 (Accessed August 17, 2020)
Oregon OSHA (OROSHA). (Undated). High-visibility safety apparel - unraveled. Available at https://osha.oregon.gov/OSHAPubs/factsheets/fs42.pdf (Accessed August 14, 2020)
Safety Gear Online. (2020a). Explaining the Classes of an ANSI Safety Vest. Available at https://www.safetygearonline.com/explaining-ansi-safety-vest-classes (Accessed August 10, 2020)
Safety Gear Online. (2020b). Safety Vests: Class 3 Safety Vests. Available at https://www.safetygearonline.com/safety-vests/class-3-safety-vests (Accessed August 14, 2020)
Safety Gear Online. (2020c). Safety Vests: Class 2 Safety Vests. Available at https://www.safetygearonline.com/safety-vests/class-2-safety-vests (Accessed August 14, 2020)
Select Safety. (Undated). Jobs That Require a Safety Vest. Available at https://selectsafety.net/jobs-that-require-a-safety-vest/#:~:text=Heavy%20Equipment%20Handlers%20and%20Construction,or%20cluttered%20by%20heavy%20machines. (Accessed August 13, 2020)
Viewbrite Safety Products. (2011). How Long Does Safety Apparel Last? Available at http://blog.viewbritesafetyproducts.com/how-long-does-safety-apparel-last/ (Accessed August 14, 2020)
Work Zone Safety. (2012). High-Visibility Safety Apparel in Highway Work Zones. Available at https://www.workzonesafety.org/training-resources/fhwa_wz_grant/atssa_high_visibility/#:~:text=If%20you%20think%20your%20safety,of%20up%20to%203%20years. (Accessed August 14, 2020)

