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OSHA 1926.201

Signaling requirements in construction

Subpart G

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.201(a), what rules apply to flaggers and the garments they wear on a construction site?

Under 1926.201(a), signaling by flaggers and the warning garments they wear must follow the Manual on Uniform Traffic Control Devices (MUTCD) Part 6 as incorporated by reference. Employers must ensure flaggers use methods, devices, and high-visibility garments that meet the requirements found in 1926.201(a) and the materials incorporated via 1926.6.

  • Train flaggers on the MUTCD Part 6 procedures for traffic control and hand-signaling or paddles.
  • Provide and require appropriate high-visibility warning garments per the MUTCD (e.g., reflective vests or apparel when required by Part 6).
  • Keep documentation of training and garment issuance as part of your site safety records.

(See the signaling requirement in 1926.201(a) and the incorporation authority in 1926.6.)

Who is responsible for making sure flaggers follow the MUTCD requirements on a construction project?

Under 1926.201(a), the employer is responsible for ensuring flaggers use signaling and warning garments that conform to the MUTCD Part 6 requirements. Employers must implement procedures, provide training, and issue required garments so flagging operations meet the expectations in 1926.201(a) and the materials incorporated by reference in 1926.6.

  • The employer should verify flagger qualifications and document training.
  • Supervisors must enforce correct use of signs, paddles, and warning garments on site.

(See 1926.201(a).)

Does 1926.201 require a specific national standard for crane and hoist hand signals?

Under 1926.201(b), OSHA directs users to follow applicable American National Standards Institute (ANSI) standards for crane and hoist signaling rather than prescribing a single set of hand signals in the construction regulation itself. The regulation states that "regulations for crane and hoist signaling will be found in applicable ANSI standards" as set out in 1926.201(b).

  • Employers should adopt a recognized ANSI signal standard and train signal persons and crane operators to that standard.
  • If your workplace uses a different agreed-upon signal system, make sure all involved employees (signal persons and operators) are trained and the system is unambiguous.

(See 1926.201(b).)

If mine contractor requires a flagger to wear a reflective vest at night, is that consistent with OSHA's signaling rule?

Yes. Under 1926.201(a), flaggers must conform to MUTCD Part 6, which includes high-visibility and retroreflective apparel guidance for night and low-light conditions. Employers must provide and require appropriate warning garments consistent with that incorporated guidance.

  • Provide the type of high-visibility garment (class/level) the MUTCD specifies for the conditions.
  • Train flaggers on visibility practices for night operations (placement, illumination, and spacing of signs, as directed by MUTCD Part 6).

(See 1926.201(a) and the incorporation authority in 1926.6.)

Under 1926.201, can a construction site use nonstandard hand signals between a crane operator and a signal person?

Under 1926.201(b), crane and hoist signaling should follow recognized ANSI standards; however, employers may use alternate signals only if they ensure the operator and signal person have a clear, unambiguous, and agreed-upon system and are properly trained.

  • If you choose a non-ANSI system, document the signals and ensure all affected workers are trained and understand them.
  • For safety and to minimize confusion, using an established ANSI signal code is strongly recommended.

(See 1926.201(b).)

What must an employer do when the MUTCD is updated—does 1926.201 automatically require following the new MUTCD?

Under 1926.201(a), flagging must conform to Part 6 of the MUTCD as incorporated by reference in the OSHA construction standards via 1926.6. When the MUTCD is updated, the incorporated version in 1926.6 controls until OSHA updates the incorporation by reference.

  • Employers should track MUTCD updates and confirm which edition is incorporated by reference in 1926.6.
  • Where an updated MUTCD offers clearer or stronger safety practices, employers should consider adopting them proactively even before OSHA formally incorporates the new edition.

(See 1926.201(a) and 1926.6.)

Are flaggers required on every construction job where vehicles are present under 1926.201?

No. 1926.201(a) requires that signaling by flaggers conform to MUTCD Part 6 when flaggers are used, but it does not mandate flaggers for every job. Employers must evaluate the worksite and follow MUTCD guidance to determine when flaggers are necessary for traffic control.

  • Conduct a hazard assessment to decide if flaggers or other traffic control measures (signs, barriers, detours) are required.
  • If flaggers are used, they must comply with MUTCD Part 6 as incorporated by 1926.201(a).

(See 1926.201(a).)

Under 1926.201, what documentation or training should employers keep for flaggers?

Under 1926.201(a), flagging must conform to MUTCD Part 6, and employers should document training and qualifications that demonstrate a flagger knows MUTCD Part 6 procedures. Keep records of training, the date, topics covered, and the trainer's name.

  • Maintain written evidence of flagger training and instruction in MUTCD-based signaling and safety practices.
  • Keep records of garment issuance (type and size) and any refresher training.

(See 1926.201(a).)

If a construction crew uses radios for crane signals instead of hand signals, is that acceptable under 1926.201(b)?

Yes, using radios can be acceptable so long as the signaling method is clear, reliable, and conforms to recognized signaling practices; 1926.201(b) points employers to applicable ANSI standards for crane and hoist signaling.

  • Ensure radio procedures are standardized, tested, and that both the signal person and operator are trained and understand radio phraseology.
  • Have backup methods (clear hand signals or stop procedures) in case radio communication fails.

(See 1926.201(b).)

Under 1926.201, does OSHA tell employers which ANSI standard to use for crane signals?

No. 1926.201(b) states that regulations for crane and hoist signaling will be found in applicable ANSI standards but does not name a specific ANSI document. Employers should adopt a current, applicable ANSI signal standard and train employees accordingly.

  • Common practice is to use widely recognized ANSI crane signal standards; confirm the edition and applicability for your equipment.
  • Document which ANSI standard you follow and show training records for signal persons and operators.

(See 1926.201(b).)

Can a worker who is not a trained flagger direct traffic if they are wearing a warning garment on site under 1926.201(a)?

No. Under 1926.201(a), simply wearing a warning garment does not authorize an untrained worker to perform flagging duties; flaggers must use signaling practices that conform to MUTCD Part 6, which requires appropriate training.

  • Assign only trained, competent flaggers to direct vehicular traffic.
  • Provide training in MUTCD Part 6 procedures and ensure flaggers wear appropriate warning garments.

(See 1926.201(a).)

How does 1926.201 interact with state or local DOT traffic-control rules for construction projects on public roads?

Under 1926.201(a), flagging must conform to MUTCD Part 6 as incorporated by reference; many state and local DOTs adopt versions of the MUTCD or add local supplements. Employers must comply with the MUTCD requirements in 1926.201(a) and any legally applicable state or local traffic-control regulations.

  • Where local DOT standards are more stringent, follow the stricter local requirement.
  • Coordinate with local authorities when planning traffic control on public roads and document which MUTCD or local supplement you are following.

(See 1926.201(a).)

Under 1926.201, are temporary traffic-control devices like stop/slow paddles required for flagging work?

1926.201(a) requires flaggers to conform to MUTCD Part 6 when flaggers are used; the MUTCD specifies the appropriate devices (like STOP/SLOW paddles) for many flagging situations. Employers must follow the MUTCD Part 6 device guidance when implementing flagging operations.

  • Refer to the MUTCD Part 6 device tables and diagrams for the correct paddle types and sizes for your situation.
  • Ensure devices are in good condition, used per MUTCD instruction, and flaggers are trained in their use.

(See 1926.201(a) and the incorporation in 1926.6.)

If a crane operator does not understand a signal given by a site signal person, what does 1926.201(b) imply the employer should do?

1926.201(b) points employers to applicable ANSI standards for crane signals; practically, that means employers must ensure signal persons and crane operators use a standardized, mutually understood set of signals and be trained. If the operator does not understand a signal, work must stop until clear, unambiguous signals are established and both parties are trained.

  • Stop operations immediately if a signal is unclear.
  • Re-establish and document the agreed signal protocol, train involved workers, and resume only when communication is reliable.

(See 1926.201(b).)

Are pedestrian control measures covered by 1926.201 signaling rules when construction work is next to sidewalks?

1926.201(a) requires flaggers to conform to MUTCD Part 6 when used; MUTCD Part 6 also provides guidance for pedestrian control in work zones. Employers must follow MUTCD Part 6 procedures and any local requirements to protect pedestrians where work affects sidewalks or crossings.

  • Use MUTCD-recommended pedestrian detours, barriers, signage, and trained flaggers where appropriate.
  • Coordinate with local authorities for safe pedestrian routing when public sidewalks are affected.

(See 1926.201(a)).

Under 1926.201, what should be included in training for crane signal persons?

Under 1926.201(b), signaling for cranes should follow applicable ANSI standards; training for signal persons should therefore cover the chosen ANSI signal code, site-specific procedures, communication methods (hand signals, radios), and how to stop operations when signals are unclear.

  • Train on the exact signal vocabulary you use (ANSI signals, radio phrases, or documented alternate signals).
  • Include practical exercises, recognition of obstructions/visibility issues, and emergency stop procedures.
  • Maintain training records and document which ANSI or alternate standard you follow.

(See 1926.201(b).)

Does 1926.201 require a certified signal person for crane operations?

1926.201(b) directs employers to applicable ANSI standards for crane and hoist signaling but does not itself prescribe certification requirements for signal persons; employers should consult the applicable ANSI standard and other OSHA crane-related regulations for certification expectations.

  • If an applicable ANSI or site-specific safety policy requires certification, ensure signal persons meet that requirement.
  • Regardless of certification, ensure signal persons have documented training and can provide clear signals to the operator.

(See 1926.201(b).)

If a site has both flaggers controlling public traffic and cranes lifting nearby loads, how should signaling be coordinated under 1926.201?

Under 1926.201(a) and 1926.201(b), flagging must conform to MUTCD Part 6 and crane signals should follow applicable ANSI standards; employers must coordinate these systems so signals to traffic and crane communications do not conflict and create hazards.

  • Separate responsibilities clearly (who controls vehicular traffic, who controls crane operations) and document communication protocols.
  • Use site briefings to inform all workers, flaggers, and crane crews of potential interactions and emergency stop signals.

(See 1926.201(a) and 1926.201(b).)

Can an employer create a written site-specific signaling plan to meet 1926.201 requirements?

Yes. While 1926.201(a) and 1926.201(b) require conformity with MUTCD Part 6 for flaggers and applicable ANSI standards for crane signals, a written site-specific signaling plan that references those standards and documents training, devices, and communication protocols is a practical way to demonstrate compliance.

  • Include which MUTCD edition or ANSI standard you follow, a diagram of flagging/crane zones, and training records.
  • Use the plan during pre-job briefings and keep it available for inspections.

(See 1926.201(a) and 1926.201(b).)

Under 1926.201, does OSHA provide the MUTCD text for flaggers or do employers have to obtain the MUTCD themselves?

1926.201(a) requires conformity to MUTCD Part 6 as incorporated by reference via 1926.6, but employers are responsible for obtaining and following the MUTCD text (or the edition incorporated by reference) to ensure compliance.

  • Obtain the applicable MUTCD Part 6 edition and train flaggers to its requirements.
  • Keep copies or clear references to the adopted edition accessible for supervisors and inspectors.

(See 1926.201(a) and 1926.6.)