Article Categories Archives: Safety

Scene Safety Procedures: Increasing Your Safety on the Job

By Simon Birch, Technical Product Support – AW Direct

Much has been written and discussed about the merits of hi-vis, ANSI approved clothing, and there is no doubt that it contributes to keeping you safe out on the roadside. Towers all have and use warning lights as well, but what else can you do to protect yourself on the job?

In my 30 years as a towing operator, I had several close calls, but thankfully, no serious incidents. I’m going to share some of the procedures and policies I learned and was taught along the way that kept myco-workers and me safe.

Roadside Service

One of the most dangerous jobs we perform is roadside service. Tire changes, gas calls, jump starts, etc., all require your focus to be diverted from the traffic around you. The correct placement of your truck is the single most important thing you can do to provide some protection for yourself and your customers.

Ideally, you should park behind your casualty at a reasonable distance. You should be close enough to make getting your equipment easy, but far enough that should a vehicle strike your truck, you have enough room to get out of the way if necessary. You should also turn your wheels towards the ditch line, that way, if the impact is hard enough to move your vehicle, it will roll away from the lanes of traffic.

Roadside Towing

By following a few simple procedures, you can remain as safe as possible when approaching a disabled vehicle that you are going to tow. As you approach your casualty, start to slow down in plenty of time. Make your moves steady and predictable to the other motorists around you.

If your state law allows, activate your emergency lighting to give your fellow drivers some warning of the upcoming hazard.

Once pulled over and in front of the casualty, check your mirrors and look over your shoulder before exiting the vehicle. Never turn your back on the traffic that is approaching, and proceed around the front of your wrecker. Walk down the passenger side to your casualty.

Do as much of your hooking up as you can from the passenger side and only work on the traffic side when you absolutely have to, always watching and listening to the traffic around you. One trick is to listen for the rumble strips. Most major highways now have rumble strips on the hard shoulder. If you hear them, you know that an approaching vehicle has strayed over the white line and could become an issue for you.

Once your hook up is complete and you are ready to re-join traffic, it is a good idea, if you can, to build up some speed before you merge into the traffic lane. Slowly accelerate down the shoulder until your speed is sufficient so as to not cause the flow of traffic to be disrupted by your movements.

Recovery Jobs

Due to their incredible diversity and randomness, recovery jobs can be very dangerous situations where you are exposed to many potential hazards.

Let’s look at some of the more common issues and how to avoid possible injuries.

On a recovery job, there are many factors to consider. Hidden damage, heavy loads, equipment failure, load shifting, etc. Because your focus will be spread across many concerns, the first thing to do is ascertain a safe zone. Once working in that safe zone, you can be less concerned with what is going on around you, and stay more focused on the job at hand.

During your walk around, note anything that can go wrong during the recovery. This is especially important for heavy recovery jobs, as you are dealing with much heavier loads. However, it is still vital for the light duty jobs as well. Don’t assume that when you roll a car over, or winch it out of a ditch, that something can’t go wrong. Because it can and does.

When installing your rigging, check and double check all straps, chains, snatch blocks and wire rope for any sign of wear. Ensure they are installed correctly, with wear pads, safety latches and pins in place to prevent failure during the job. We have all seen images of wreckers lying on their sides, or broken ropes and straps that have recoiled at horrific speeds due to equipment failure.

Once your rigging is done, take up all the slack in your winch ropes, and then inspect your rigging again. Make sure that nothing has moved during the tensioning process. Make sure that when the job is complete, the casualty is going to be in a safe location. Make sure it will be secure and far enough away from your wreckers and rigging that you can facilitate a tow on it if needed.

Probably the most critical part of a recovery job is the position of the operator or operators. You need to be in a place where you can see what is going on and where you can communicate with other team members. More importantly, you need to be in a place where if something goes wrong, you are out of the danger zone.

Never stand between your wire ropes or inside a triangle of wire ropes. If you are using a snatch block to change direction, stand on the back side of it, so if something breaks it will move away from you.

If possible, use a remote control. Most modern recovery vehicles have remotes, and aftermarket ones are available for winches of every size and make.

As winching or lifting commences, listen. Your ropes and snatch blocks will make a noise. Old school operators will tell you of days gone by when the big mechanical wreckers with no pressure limits would“talk to you”. Wire ropes “sing” under a load. Listen to the casualty and make sure there is no noise coming from it that would indicate an unforeseen failure, which could result in injury. Keep your hands and feet away from all pinch points. If something needs to be changed in the rigging, make sure all personnel are aware and that all levers and remotes are not being handled.

It may seem obvious, but never stand or lay under an unsupported load. Do not rely on hydraulic pressure or winch brakes to hold the load. Too many lives and limbs are lost each year by loads dropping on operators.

Obviously, accidents happen. If they didn’t we wouldn’t have an industry, but by being aware, focused and knowledgeable, you can do a great deal to limit those accidents that occur during your work day. We have a very dangerous industry; it’s up to us to make it a safe as humanly possible.

Stay safe out there, folks.

AW Direct
Helping You Help Them
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Latch on to HazCom

By Bob Ernst, J. J. Keller & Associates, Inc.

If you look around any workplace, you are likely to see lots of different chemicals being used. With almost every chemical, there are risks to you, your physical surrounding and the environment as a whole. The possibility of accidents and injuries is always present when you’re working with hazardous chemicals, no matter how harmless they may seem.

The Occupational Health and Safety Administration (OSHA) says that workers have both a right and a need to know information about the hazards of the chemicals they work with or are exposed to, especially so that they can take steps to protect themselves when necessary.

On March 26, 2012, OSHA published the revised Hazard Communication Standard (HCS) “harmonizing” it with portions of the Globally Harmonized System (GHS). The GHS is an international approach to hazard communication that provides universal criteria for identification and communication of chemical hazards.

The revised HCS changes the existing requirements for classifying chemical hazards, the format and content of Safety Data Sheets (SDSs), and the labeling of chemical containers.

OSHA has established “phase-in dates” for compliance with the revised standard, which will be fully implemented by June 1, 2016. During the phase-in period, OSHA says that employers can comply with the old standard, the revised standard, or both.

Written plan

The HazCom standard has always required that employers prepare and implement a written hazard communication program. The written program is intended to ensure that the employer is in compliance with the all of the required elements of the standard.

The written program must also include a chemical inventory, which is a list of the chemical hazards known to be present in the work environment.

Container labels

One of the most visible changes we will see is new container labels. The label is a snapshot of the hazards and protective information related to the chemical, and a summary of the more detailed information available on the SDS.

All hazardous chemicals shipped after June 1, 2015, must be labeled, tagged, or marked with six specified label elements, four of which have been “harmonized” within the GHS system, and are pre-determined based upon the chemical’s hazard class and category.
Those required label elements are:

  • Product identifier;
  • Signal word;
  • Hazard statement(s);
  • Pictogram(s);
  • Precautionary statement(s); and
  • The name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.


Although the GHS system uses nine pictograms, OSHA has designated eight pictograms under the HCS for application to a hazard category.

OSHA requires pictograms on shipped containers be in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame sufficiently wide enough to be clearly visible.

Workplace labels

Any container of hazardous chemicals in the workplace must at a minimum include the product identifier and general information concerning the hazards of the chemical. This would apply to any containers of hazardous chemicals drivers carry on their trucks.

For instance, if your tow trucks carry small amounts of gasoline, so-called “non-bulk packagings,” the container must be DOT approved and must be marked with the name of the contents and with an indication of the hazards of the material it contains.

For those containers that are received already labeled from the supplier, and are used in the workplace, simply maintaining the label that is on the container from the supplier is the best and easiest option.

Some employers use third-party workplace label systems, such as those that have numerical ratings to indicate the hazards (e.g., National Fire Protection Association (NFPA) or Hazardous Materials Identification System (HMIS)).

OSHA says that employers may continue to use third-party label systems, as long as workers have access to the complete hazard information found on the SDS.

Consumer products

You will not see a change to the labels on containers of “consumer products,” which are those chemicals that anyone can purchase over the counter.

Safety data sheets

The SDS is the source of detailed hazard information about the hazardous chemical being used. The revised HCS requires that the information on the SDS is presented using a consistent 16-section format in a specified sequence:
Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical properties
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information
Section 13. Disposal considerations
Section 14. Transport information
Section 15. Regulatory information
Section 16. Other information, including date of preparation or last revision

The SDS must contain Sections 12 through 15 to be consistent with the GHS, but OSHA will not enforce the content of these sections because OSHA has no authority over those areas.

Safety data sheets must be available for each hazardous chemical in the workplace, and must be readily accessible to employees when they are in their work areas. For drivers, the SDSs may be kept at the primary workplace.

Training requirements

Employees who may be exposed to hazardous chemicals must be provided with information and “effective” training at the beginning of each new assignment involving a hazardous chemical or whenever a new physical or health hazard is first introduced. Effective training means that the training be understood by the employee, so training may need to be provided in a language other than English.

Employers are required to inform employees of the basic requirements of the standard, such as specific chemical hazards in the employee’s work area, the location of the written HazCom program and SDSs, and how to read container labels and SDSs.

Hazardous chemical training must include:

  • How to detect the presence or release of hazardous chemicals;
  • The physical and health hazards of those chemicals; and
  • Precautions employees can take to protect themselves against hazards, such as safe work practices, personal protective equipment, and emergency procedures.

Your HazCom Program

OSHA says that employers can implement an effective hazard communication program
by following these six steps:
Step 1. Learn the standard/Identify responsible staff
Step 2. Prepare and implement a written Hazard Communication Program
Step 3. Ensure containers are labeled
Step 4. Maintain Safety Data Sheets (SDSs)
Step 5. Inform and train employees
Step 6. Evaluate and reassess your program

OSHA believes that the Hazard Communication Standard will ensuring that hazardous chemicals in the workplace are identified, and that proper measures are implemented for safe use and handling. By understanding the hazards of the chemicals, and using available information to pick the proper control measures to address these hazards, we can achieve safer workplaces.

Copyright 2014 J. J. Keller &
Associates, Inc.®
PO Box 368, 3003 Breezewood Lane
Neenah WI 54957-0368

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Electronic Communications to the Trucks – A Blessing and a Curse!

By Thomas Bray

In this day and age, there are many communications devices that allow you to instantly contact your drivers. However, some of these devices can lead to an unsafe situation if used improperly. In some cases, it can also lead to a ticket.

The issues with electronic communication systems in vehicles have been well studied and the dangers well documented. The problems are “glances” and “attention to task.” When the driver is interacting with the communications device, the driver is not “watching traffic” (called a visual distraction), is not listening to what is going on around him/her (called an auditory distraction), is attempting to manually manipulate the device (called a manual distraction) and is not thinking about driving (referred to as a cognitive distraction).

The more types of distraction a device causes, the greater the risk is when using it while driving. Texting, which involves all four types of distraction, has long been recognized as the most dangerous of the electronic distractions. In one study, texting was found to increase the odds of the driver being involved in a safety-related event or crash by 23 times. There are many activities that carry the same level of risk for the same reason — they involve multiple types of distraction at the same time — such as dialing a cell phone when driving or using a computer terminal while driving.

Due to the dangers involved in electronic distraction, the Federal Motor Carriers Safety Administration (FMCSA) and many states have placed rules on the books limiting the use of cell phones and prohibiting texting while driving. By the way, “while driving” includes while stopped at a stop light or stop sign, and being stuck in traffic. To be “not driving,” the driver needs to be stopped and safely parked in a legal parking place.

Cell phones
The FMCSA and state cell phone regulations are such that a driver can use a cell phone while driving provided certain conditions are met. First, the phone cannot be held in the driver’s hand. It must be “hands free.” The hands-free requirement applies to everything from dialing to hanging up. Dialing andhanging up must be able to be accomplished with “one touch.”

Second, the driver must be able to answer or initiate calls while seated normally in the driver’s seat. If the driver has to reach in such a way that he/she has to “leave the driving position” to initiate or answer a call, the driver is in violation of the regulations.

The driver does have the option to get off of the roadway (park somewhere where it is legal and safe to park) and use the cell phone, if hands-free is not an option.

The only exception to the rules is if the driver needs to contact emergency services to report an emergency.

Basically, what is prohibited by the FMCSA (and most states and municipalities that have cell phone rules) is the driver holding the phone, dialing the phone, or having to leave the driving position to initiate or answer a call. If the driver has a hands-free headset or a “smart” vehicle that can link to the phone, then the driver can make and answer cell phone calls.

As a company, if you want to have “instant access” to your drivers using cell phones, you will need tomake sure that the drivers understand the rules and are equipped with hands-free technology. Otherwise, the drivers need to be told to let the call go to voicemail, and stop as soon as safely possible to check the voicemail.

The FMCSA regulations (as well as most state and municipal rules that restrict texting) prohibit “manual entering of alpha-numeric characters into a communication device or reading of alpha-numeric information on a communication device” while driving. This is the technical definition of “texting.” Unlike the cell phone regulation, the regulations do not provide an alternate means of texting that would be legal. The only way texting when driving can be done legally is if it can be done hands-free (such as using a smart vehicle system that has “voice to text”).

If the driver receives a text when driving, the driver needs to know to find a safe place to park to read and reply to the text. As a company, if you use a text-based system to communicate with your drivers, you need to understand that there will be a delay in the driver’s reply. This is due to the driver needing to find a safe place to read and reply. Anytime a driver that is supposed to be driving replies immediately, you should be concerned that the driver is texting while driving. This suspicion should at least warrant a conversation with the driver to verify that he/she understands and is following the rules.

These regulations (like the cell phone regulations) include an exception for contacting emergency services to report an emergency.

Just because you can, doesn’t mean you should!
There are circumstances in which the driver really should not be using a cell phone, even if it is hands-free.The issue is that cell phones, even hands-free cell phones, create cognitive distraction. This cognitive distraction may lead to the driver seeing something in front of him/her, but not reacting to it.The driver will be especially prone to these phenomena when there are multiple driving activities thatwill require his/her attention.

An example would be a driver approaching an accident scene. Approaching an accident scene requires covering the brake, checking traffic in the area, checking mirrors to see what traffic coming to the sceneis doing, following the directions of emergency responders, being prepared to stop on a moment’s notice, and actively deciding when and where to stop. A driver that is on the phone may not realize what is going on around him/her, much less be mentally prepared and able to make sound decisions.

Other situations, such as heavy traffic, bad road conditions, and bad weather conditions, can lead to similar problems. If the driver is in a driving situation that involves taking in a lot of driving data and making sound decisions, the driver should not be using even a hands-free cell phone.

The bottom line is that when the driver is in a difficult driving situation, the distraction of talking on even a hands-free cell phone may be enough to get the driver in trouble. Therefore, work with your drivers on when they should and shouldn’t be using a hands-free cell phone. And remember that there are no circumstances where texting while driving is allowed.

Thomas Bray is Sr. Editor – Transportation Management for J.J. Keller & Associates, Inc. Contact him at Also be sure to check out J. J. Keller’s website at

Copyright 2014 J. J. Keller & Associates, Inc.®
PO Box 368, 3003 Breezewood Lane
Neenah, WI 54957-0368

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Protecting Employees from Winter’s Hazards

By Mark H. Stromme


As a tow professional, you and other owners, operators, and employees work year-round outside in the elements. Depending on your location, the outdoor work environment can be brutal, especially in the winter months.

Wearing jackets, coveralls, insulated work boots, gloves, hats and balaclavas are a common means of protection from the cold, wind, rain, and snow. Crawling around over and under vehicles and on the beds of trailers can put this cold weather gear to the test.

Personal protective equipment

The above items are considered personal protective equipment, commonly referred to as “PPE.” PPE is equipment worn to minimize exposure to serious workplace injuries and illnesses. These injuries and illnesses may result from contact with chemical, radiological, physical, electrical, mechanical, or other workplace hazards. Personal protective equipment may also include items such as gloves, safety glasses, protective footwear, earplugs, hard hats, respirators, coveralls, vests, and full body suits.

Ensure proper use of personal protective equipment


OSHA requires that all personal protective equipment be of safe design and construction, and be maintained in a clean and reliable fashion. It should fit well and be comfortable, which encourages workers to use it. If the PPE does not fit properly, it can make the difference between being safely covered or dangerously exposed.

When engineering, work practice, and administrative controls are not feasible or do not provide sufficient protection, employers must provide PPE to their workers and ensure its proper use.


Employers are also required to train each worker required to use PPE to know:

  • When it is necessary
  • What kind is needed
  • How to properly put it on, adjust, wear and take it off
  • The limitations of the equipment
  • Proper care, maintenance, useful life, and disposal of the equipment

Body protection

Employees who face possible bodily injury of any kind that cannot be eliminated through engineering, work practice or administrative controls must wear appropriate body protection while performing their jobs. Employees working in the towing profession are often exposed to these hazards:

  • Temperature extremes;
  • Splashes from hot liquids;
  • Potential impacts from tools, machinery and materials; and
  • Chemicals.

All employers are required to perform a hazard assessment according to OSHA’s 29 CFR 1910.132(d), “Hazard assessment and equipment selection.”


29 CFR  1910.132(d)

The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:

  • Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
  • Communicate selection decisions to each affected employee; and
  • Select PPE that properly fits each affected employee.

If a hazard assessment indicates a need for full body protection against toxic substances or harmful physical agents, the clothing must:

  • Be carefully inspected before each use,
  • Fit each worker properly, and
  • Function properly and for the purpose for which it is intended.

Protective clothing comes in a variety of materials, each effective against particular hazards, such as:
Hard Hat & Work Boots

  • Paper-like fiber used for disposable suits provides protection against dust and splashes.
  • Treated wool and cotton adapts well to changing temperatures, is comfortable and fire-resistant and protects against dust, abrasions, and rough and irritating surfaces.
  • Duck is a closely woven cotton fabric that protects against cuts and bruises when handling heavy, sharp, or rough materials.
  • Leather is often used to protect against dry heat and flames.
  • Rubber, rubberized fabrics, neoprene and plastics protect against certain chemicals and physical hazards. When chemical or physical hazards are present, check with the clothing manufacturer to ensure that the material selected will provide protection against the specific hazard.

High-visibility retroreflective clothing

Visibility hazards can also pose problems for tow operators. When you are exposed to traffic hazards, a best practice would be to follow the 2009 edition of the Manual of Uniform Traffic Control Devices (MUTCD), Chapter 6E, Flagger Control, which states:

For daytime and nighttime activity, flaggers 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 Apparel and Headwear and labeled as meeting the ANSI 107-2004 standard performance for Class 2 or 3 risk exposures.

The apparel background (outer) material color shall be fluorescent orange-red, fluorescent yellow-green, or a combination of the two as defined in the ANSI standard. The retroreflective material shall be orange, yellow, white, silver, yellow-green, or a fluorescent version of these colors, and shall be visible at a minimum distance of 1,000 feet. The retroreflective safety apparel shall be designed to clearly identify the wearer as a person.

Providing Class 2 or 3 safety vests to all employees required to work in or around a roadway is an important step in protecting them.

Payment for protective equipment

The employer is required to pay for certain types of personal protective equipment. However, the employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job.

When the employer provides metatarsal guards and allows the employee, at his or her request, to use shoes or boots with built-in metatarsal protection, the employer is not required to reimburse the employee for the shoes or boots.

The employer is not required to pay for:

  • Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots; or
  • Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen.

The above indicates that you do not have to pay for heavy outerwear such as cold-weather jackets. However, since your employees may be working on or near roadways, they may be exposed to struck-by accidents. If this is the case, your hazard assessment would have indicated that and you would have to provide some type of appropriate high-visibility safety apparel.

Personal protective equipment/clothing checklist

Use the following checklist to help determine if you are in compliance with OSHA’s requirements:

  • Have you determined whether hazards that require the use of PPE (e.g., head, eye, face, hand, or foot protection) are present or are likely to be present?
  • If hazards or the likelihood of hazards are found, have you selected appropriate and properly fitted PPE suitable for protection from these hazards and do you ensure that affected employees use it?
  • Have employees been trained on PPE procedures, i.e., what PPE is necessary for job tasks, when workers need it, and how to properly wear and adjust it?
  • Are protective goggles or face shields provided and worn where there is any danger of flying particles or corrosive materials?
  • Are approved safety glasses required to be worn at all times in areas where there is a risk of eye injuries such as punctures, abrasions, contusions, or burns?
  • Are employees who wear corrective lenses (glasses or contacts) in workplaces with harmful exposures required to wear only approved safety glasses, protective goggles, or use other medically approved precautionary procedures?
  • Are protective gloves, aprons, shields, or other means provided and required where employees could be cut or where there is reasonably anticipated exposure to blood or other potentially infectious materials? See the OSHA Bloodborne Pathogens standard, 29 CFR 1910.1030(b), for the definition of “other potentially infectious materials.”
  • Are hard hats required, provided, and worn where the danger of falling objects exists?
  • Are hard hats periodically inspected for damage to the shell and suspension system?
  • Is appropriate foot protection required where there is the risk of foot injuries from hot, corrosive, or poisonous substances, falling objects, crushing, or penetrating actions?
  • Are approved respirators provided when needed?
  • Is all PPE maintained in a sanitary condition and ready for use?
  • Are foods or beverages consumed only in areas where there is no exposure to toxic material, blood, or other potentially infectious materials?
  • Is protection against the effects of occupational noise provided when sound levels exceed those of the OSHA noise standard?
  • Are adequate work procedures, PPE, and other equipment provided and used when cleaning up spilled hazardous materials?
  • Are appropriate procedures in place to dispose of or decontaminate PPE contaminated with, or reasonably anticipated to be contaminated with, blood or other potentially infectious materials?


Final thought

Tow professionals are responsible for protecting their workers from hazards, and when necessary, provide the proper PPE that employees need to stay safe.

Mark H. Stromme
Workplace Safety Editor with J.J. Keller & Associates, Inc.
3003 Breezewood Ln,
Neenah, WI 54957
(920) 722-2848

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Know the Lighting Requirements for Your Tow Trucks

Safety Lighting Requirements

Safety Lighting Requirements

By Tom Bray

Before we get into the discussion of the lighting requirements that are specific to tow trucks, let’s look at the general lighting requirements in the federal regulations. These requirements are found in two places:

  1. The National Highway Traffic Safety Administration’s (NHTSA) Federal Motor Vehicle Safety Standard (FMVSS) 108,  also known as FMVSS 108 or Section 571.108 (since it is located in Part 571), and
  2. The Federal Motor Carrier Safety Administration (FMCSA) regulations at Section 393.11.

The NHTSA regulations apply to new vehicles and the FMCSA regulations apply to vehicles that are presently in service. The two are tied together more closely than one might think. The FMCSA regulations (and most states) require that the vehicle, for the entire time it is in service, continues to meet the FMVSS requirements that were in place when the vehicle was built.

The basic light package that is required includes:

  • Headlights
  • Taillights
  • Brake lights
  • Front and rear turn signals
  • Front and rear side markers (lights that are visible from the side to indicate the length of the vehicle)
  • Front and rear clearance lights (lights that indicate the overall width of the vehicle)
  • Backup lights (activated when the vehicle is in reverse)

Flat bed wrecker loading a van
The vehicle must also have reflectors at the “corners,” visible from the side and rear.

Lights are allowed to serve multiple purposes, such as the vehicle’s “front parking lights” serving as both the front side marker light and the front clearance light, and having a reflective lens cover so it can serve as the front side reflector as well.

Extra lights may be required

If the vehicle is over certain dimensions, then additional lights will be required. If the vehicle is over 30 feet long, it must have an intermediate side marker light (and reflector) mounted at roughly the middle of the vehicle’s length. If the vehicle is over 80 inches wide, it must have a set of “identification markers” on the front and rear. The “ID markers” are the set of three lights mounted on top of the vehicle. They are there to identify the vehicle to other traffic as a wider-than-normal vehicle.

Light color is closely regulated

The regulations specify what color and what candlepower all of these required lights must be. In general, headlights and backup lights need to be white, rear-facing lights and the side marker lights at the rear corner of the vehicle need to be red, and all other markers and clearance lights need to be yellow. The only required lights on the vehicle that can be either red or yellow are the rear turn signals, provided they are not combined with a brake light. If the rear signal is combined with a brake light, the light must be red and the signal light must be the one that is active if the brakes and signals are active at the same time.

Be careful when making modifications

Most vehicle and body manufacturers know these rules quite well and build their vehicles to comply. Doing aftermarket modifications to the vehicle or the body is what gets vehicle owners or operators in trouble when it comes to the required lights.

Tow truck specific requirements

At the federal level, mounting “lights other than those required” and/or “auxiliary lights” are allowed, as long as they do not reduce the effectiveness of the required lights or create confusion, and as long as the type or color of light is not prohibited. Additional lights must also comply with the state’s rules related to color and placement. For example, some states restrict the use of certain color auxiliary lights to specific vehicles — such as reserving blue for law enforcement or white strobes for school buses. Also, the driver must comply with any use restrictions the state may have in place on the use of additional or auxiliary lights.

States also place additional lighting requirements on certain vehicles, such as tow trucks. To operate as a tow truck in many states, the vehicle must be equipped with oscillating, rotating, or strobe lights of a specific color. Several states require two colors, one to be used when stopped on the side of the road (such as when hooking up at an accident scene) and another for use when actually towing another vehicle.

Most states also require that, if the lights on the rear of the tow truck are not readily visible to traffic following the tow truck, basic lights be placed at the rear of the vehicle being towed. There is a liability issue here as well. If the taillights, brake lights, and rear turn signals of the tow truck are not visible to traffic following the tow truck and it leads to an accident, the operator and company could both be held liable.

How do you find out about the tow-truck specific lighting rules? If you are on the city or county “rotation,” or have a “contract” with the city or county to do towing, the tow-truck lighting requirements may be included in the paperwork. If you cannot locate the information and you are not sure what the requirements are, you may contact your state or local towing association, or a local, county, or state police officer with thorough knowledge of the state vehicle regulations.

Thomas Bray is Sr. Editor – Transportation Management for J.J. Keller & Associates, Inc. Contact him at Also be sure to check out J. J. Keller’s website at

Copyright 2014 J. J. Keller & Associates, Inc.®
PO Box 368
3003 Breezewood LaneNeenah WI  54957-0368

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Keep Employees Safe During Vehicle Lockout/Tagout

By Mark Stromme

Tow professionals count on their vehicles and equipment to be in top-notch condition. After all, life is good at work when your machines are running smoothly. But, all good things come to an end, and you can count on your equipment needing service, maintenance, and repairs from time to time.

You want to keep downtime to a minimum, however, and workers can be tempted to make a quick fix without making absolutely sure the equipment won’t start up or release stored energy during the repair. If it does start up, there can easily be a serious injury or a death. That’s the reason for having lockout/tagout (LOTO) procedures.

OSHA’s Lockout/Tagout Standard

The Occupational Safety and Health Administration (OSHA) regulates lockout/tagout through the Control of Hazardous Energy standard, found at 29 CFR §1910.147. This standard mandates training, audits, and recordkeeping to ensure that workers will not be unintentionally injured by the unexpected energization, start-up, or release of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or any other type of energy.

Does It Apply to Vehicle Servicing and Maintenance?

Yes, it does. According to OSHA, accidents have occurred and continue to occur from inadequate hazardous energy control during vehicle servicing and maintenance activities.

In 1991, the U.S. Court of Appeals for the District of Columbia remanded the LOTO standard to OSHA for further consideration of the ways in which the final rule applies to all general industry workplaces. OSHA, in the March 30, 1993 Federal Register (Vol. 58, No. 59), reaffirmed and further explained the reasons for applying the standard to vehicle servicing and maintenance.

The scope and application sections of the preamble to the hazardous energy control standard provide that the LOTO standard applies to all “general industry workplaces.” The standard’s coverage includes vehicles, such as, but not limited to, automobiles, trucks, tractors, refrigeration transport vehicles, and material handling equipment.

What exactly is lockout/tagout and why is it so important?

The Basic Difference Is the Use of Locks

When you hear the term “lockout/tagout,” you might think lockout and tagout is the same thing or that you have to use both methods together. But, these are two different ways to isolate a machine from its energy supplies to keep it “off” during the repair job.

“Lockout” uses locks on the switches and valves that supply energy to a machine. The energy isolating devices can’t be moved from the “off” position because a padlock keeps them off.

“Tagout” uses warning tags on switches and valves. When you use tagout, there’s no lock to keep energy isolating devices in the off position. The tag has a clear warning on it to leave the equipment off, but tagout doesn’t provide the physical restraint that lockout provides.

You have to use tagout if the energy isolating device isn’t capable of being locked out. In this case, you really don’t have any choice — you can’t apply a lock, so you have to apply tagout. This may be the case with older equipment.

But, whenever you replace, or do a major repair, renovation, or modification of the machine, the energy isolating devices have to be upgraded to accept lockout. Also, whenever you install new machines or equipment, they must accept lockout. Basically, OSHA says that when the equipment can be locked out, you’re expected to use lockout procedures.

That being said, OSHA does allow you to still use tagout even if the equipment will accept lockout. To do this, your tagout system must provide “full employee protection,” and OSHA has additional requirements. You must use “additional safety measures such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle.” Taking these steps reduces the likelihood that the machine will start. Be sure to include these additional steps in your documented tagout procedure for the machine.

Whether you use lockout or tagout, both methods assure the mechanics that the machine won’t start up or release stored energy because someone operated a control to run the equipment or accidently hit a switch.

These are the LOTO basics. But what does OSHA say about the controlling of hazardous energy when working on your tow vehicles?

Controlling Hazardous Energy on Vehicles

The OSHA standard’s coverage includes vehicles, such as, but not limited to, automobiles, trucks, tractors, refrigeration transport vehicles, and material handling equipment.

For purposes of vehicle servicing and maintenance, hazardous energy refers to:

  • Mechanical motion;
  • Potential energy due to pressure, gravity, or springs;
  • Battery-generated electrical energy;
  • Thermal energy, including chemical energy; and
  • Other forms of energy, which can cause injury to employees working in, on, or around machines or equipment.

Any vehicle (e.g., internal combustion engines such as gasoline, natural gas and diesel powered vehicles; electric-powered vehicles; hybrid vehicles) may contain the following types of hazardous energy, such as, but not limited to:

  • Chemical energy due to contact with battery acid, coolant, lubricants;
  • Electric battery shock, arc, and burn hazards;
  • Explosion hazards associated with air bags;
  • Fire and explosion hazards associated with the fuel and fluid systems;
  • Gravitational energy (mechanical) hazards caused by elevated vehicles (e.g., unsafe use of automotive lift equipment) or vehicle components (e.g., unsupported elevated dump truck beds; unsupported elevated forklift carriage assembly);
  • Hot or cryogenic fluid, and surface (thermal) hazards;
  • Hydraulic hazards associated with fluid pressure and fluid loss (e.g., causing a carrier bed to drop);
  • Mechanical hazards associated with disc brake spring and tire components;
  • Mechanical motions due to moving power transmission components;
  • Premise wiring electric hazards associated with battery recharging (which are addressed by the Subpart S – Electrical standards); and
  • Mechanical hazards associated with unexpected start-up or unexpected energization of vehicles or vehicle components.

Energy Control Program

OSHA’s 29 CFR 1910.147 standard requires employers to develop an energy control program:

  • That is tailored to the workplace, and
  • Will protect employees performing servicing and maintenance tasks from the release of hazardous energy.


The performance-oriented language allows employers flexibility to design and implement the required energy control procedures, employee training requirements, and inspection requirements to fit the individual conditions present in their workplaces.

The selection of the specific method of control must reflect a thorough evaluation of the:

  • Extent of exposure to the hazard;
  • Risk of injury associated with the particular machine/equipment; and
  • Feasibility of applying a particular method of control.

Removing the Ignition Key

Due to the nature and unique aspects of vehicle maintenance and servicing activities, the control of hazardous energy final rule’s preamble recognizes feasible measures to prevent an engine from being started. OSHA references situations, involving vehicles, such as automobiles, buses, and over-the-road trucks, where the removal of the ignition key ensures that the engine cannot be started.

However, this simple control step of removing the ignition key may not, in all cases, adequately control other types of vehicle hazardous energy, such as is the case with the positioning of the vehicle or its components (e.g., buckets, blades, vehicle body parts). These and other hazards require careful evaluation and selection of additional hazard-specific control measures.


It should be noted that turning off the engine with and removing the car key is not, strictly speaking, the same as applying a lockout or tagout device to an energy isolating device (EID) because neither the ignition switch, nor the key, are EIDs. See §§ 1910.147(b) and (d)(3) for the energy isolating device definition and application of control provisions. Based upon the above standard’s preamble discussion, OSHA allows such alternative vehicle control measures in these limited circumstances only when the key removal fully ensures employee protection.

Turning off the engine and removing the ignition key may provide a significant degree of protection in many situations in which an employee is performing vehicle repair or maintenance. The authorized employee performing the repair or maintenance would need to retain sole control of the key (assuming the keyed switch is the only means of vehicle start-up). An additional precaution for the employee retaining the key would be to lock the doors.

Although this control practice reasonably protects employees from inadvertent startup of the vehicle’s engine, it may not adequately control other energy sources that are independent of the ignition key subsystem.

One Person Is Performing the Servicing

These exclusive control practices, if incorporated into the energy control program, are feasible measures that significantly reduce the risk of exposure to the hazardous energy associated with the start-up of an internal combustion vehicle engine in situations in which a single individual is performing the servicing and/or maintenance work.

However, although turning off the engine and retaining exclusive control of the ignition key may provide significant protection in some instances, there may be circumstances where there are other keys and/or other employees involved in the work activity. In situations such as these or when the work itself may activate the ignition circuit, additional measures are necessary to protect employees from hazardous energy exposures.

For example, employees have been struck by and even run over by vehicles when the technician “shorted out” the ignition circuit, causing the vehicle to unexpectedly move. In another example, potential unexpected start-up hazards exist with older diesel engines because they could be “jump-started” by putting the vehicle in gear (without setting the brakes) and then simply pushing/rocking (“budging”) the vehicle enough to start it (with or without the ignition on).

That is why it is very important that the selected control measure(s) effectively protect exposed workers from all types of hazardous energy.

Manufacturers’ Servicing and Maintenance Guidelines

It is essential for employers to consult with and incorporate specific vehicle manufacturer servicing and maintenance guidelines (e.g., operating manuals and bulletins) and other relevant materials to establish the hazardous energy control procedures. These manuals and materials often provide specific step-by-step instructions on how to safely perform servicing or maintenance tasks.

For example, the removal of an ignition key is not sufficient to protect employees from devices that may operate or activate independently of the ignition system. That is why it may be necessary to disconnect the battery cable for some repair tasks, such as working on some cooling fans, which automatically start up even after the key has been removed.

Likewise, air bags may inadvertently deploy and cause employee injury if the system is not properly controlled and residual energy dissipated before servicing or maintenance begins.

Employers, who meet manufacturers’ servicing and maintenance guidelines, may be cited for a §1910.147 violation if the manufacturer guidelines inadequately control the vehicle’s energy sources and employee exposure exists to hazardous energy.

Troubleshooting, Testing, and Component Positioning

There are circumstances when it is necessary to re-energize the vehicle or a component to accomplish a particular task (e.g., diagnostic testing; maintenance troubleshooting; vehicle or component positioning). OSHA does allow energization for testing or positioning purposes, as specified in §1910.147(f)(1), but only for the limited time during which it is necessary to test or reposition the vehicle or component.

During these transition periods, employee exposure to hazards is high and a procedure needs to be developed to define the sequence of actions to accomplish the task safely. Under no circumstances is any part of an employee’s body ever permitted to be exposed within a hazardous area, such as the point-of-operation or in-going nip point area, during servicing and/or maintenance activities while the machine is running or energized.

The use of supplemental safeguarding actions, such as personal protective equipment to protect against hot surfaces, use of a tarp to shield a hot surface or in-going nip point, safe work positioning, etc., must be used in conjunction with established procedures to protect your employees

Working Safely

OSHA requires employers to develop LOTO procedures and to have workers follow them. If you cut corners on these procedures, the result is likely to be equipment downtime, accidents, OSHA inspections and citations, and, possibly, employee fatalities.

Copyright 2013 J. J. Keller & Associates, Inc.®
PO Box 368, 3003 Breezewood Lane
Neenah WI  54957-0368

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The ERG: Know What You’re Dealing With

The Emergency Response Guidebook (ERG) is a resource that is published to assist emergency responders ― including tow operators ― when dealing with hazardous materials (hazmat). It is republished roughly every four years to provide users with the most current information.

Knowing about the ERG is key during the initial response phase. Along with knowing how to use it, equally important is knowing when to use it!

Anything that carries cargo.

Tow operators should always inquire, as early in the process as possible, about the cargo being carried in any cargo-carrying vehicle. This allows the driver, in the event of a cargo-related problem, to be aware of what materials could be involved at the beginning of the incident. An “incident” in this context does not mean the crash or breakdown that got the tow truck there initially, it means the operator or someone else at the scene noticing cargo spilling or dripping from the vehicle.

If the initial accident or breakdown involved the known release of hazmat, the authorities at the scene should be working with the tow operator as a fellow emergency response resource. The tow operator would also be operating under the incident command structure, so the orders to start moving the vehicle would be coordinated with the other emergency response resources working at the scene by the incident commander.

Isolate and identify

If material does start spilling or dripping from the unit being towed, the driver will need to take steps immediately. First, the driver should isolate the immediate area. It may be nothing, but the risk of exposing the driver or the public to toxic or dangerous chemicals is too great to not take immediate precautions.

Next steps for the driver are to identify the materials involved, determine the hazards associated with the materials, and take appropriate actions. This is where the ERG comes into play. The information in the ERG is intended to assist first responders by providing them an easy-to-use reference that will keep them and the public safe during the initial phase of an incident. Included in the ERG is information about:

  • Potential Hazards, including fire and explosion hazards, and health hazards.
  • Public Safety considerations, including immediate isolation instructions and distances (if applicable), necessary protective clothing, and immediate evacuation distances (if applicable).
  • Emergency Response information, including what to do if the material is burning, how to deal with a spill or leak, and first aid for anyone that has been exposed to the material.

Using the ERG

Because of its design, using the ERG is fairly easy ― provided the driver knows some basic information about the material involved. To use the ERG, it is best if the driver knows the name and/or four digit identification number for the material. If this is not available, the class of placard that is on the vehicle (or should have been on the vehicle) can be used. With any of the above information, the driver can locate the necessary information in the ERG.

When it comes to the name or identification number for the material, where would the tow operator get such information? It is available through the driver, on paperwork that is supposed to be in the cab of the vehicle. If the driver was driving, it should be visible and within the driver’s reach. If the driver was not with the vehicle, it should be on the driver’s seat or in a pouch on the driver’s door. Another potential contact is the carrier operating the vehicle (the name of the carrier should be on the door). The carrier and driver may not know what the specific material is, but they will know where they picked it up and the shipper will know what it is.

Placards are the diamond-shaped warning signs that are on the sides of a vehicle transporting either:

  • Certain hazardous materials (the really dangerous materials require placarding in any amount), or
  • A large quantity of other hazardous materials (the other hazardous materials must be placarded if the vehicle contains more than 1,000 pounds of hazardous materials).

There are several exceptions to the placarding regulations, so they cannot be relied on as a “foolproof” method of determining if a cargo-carrying vehicle contains a dangerous cargo. The shipping documentation and the driver are far more reliable. This goes back to the comment above about finding out about the cargo in the case of any cargo-carrying vehicle.

Once the tow operator has identified the material involved, the next step is using the ERG. Knowledge about the material will be used to locate the correct “guide.” The guides are the pages that provide the information discussed above.

If the placard is known, use the “Table of Placards and Initial Response,” which is on pages 16 and 17 in the white-bordered pages in the 2008 ERG, to locate the appropriate guide. If the four-digit identification number for the material is known, you would locate the guide using the yellow-bordered pages. If only the name of the material is known (make sure the spelling is right!), you would use the blue-bordered pages to locate the correct guide.

The ERG only provides “step one” in a chain of steps!

One key point about the ERG is that it is intended to only provide initial response information. The information necessary for the long-term handling of the incident is normally not found in the ERG. This includes information on how to safely contain and clean up the incident and how to dispose of contaminated materials. Other emergency responders, such as the “hazmat team,” are the ones that have access to that information.

Learn about the ERG before something goes wrong

While the ERG is fairly easy to use, ideally you do not want a tow operator you have just sent to a scene where something is dripping out of the back of the vehicle to be completely unfamiliar with the ERG. Knowing in advance what the cargo is, how to use the ERG, and what the tow operator can do are critical to effectively responding during an emergency incident.

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Road hazards—high visibility clothing and other PPE

Protecting employees working on or near a roadway should always be a number one safety concern. One way to do so is to provide your employees with the proper personal protective equipment (PPE). Selecting the proper PPE is more involved than employers may understand.

Hazard assessment

To determine the need for PPE, OSHA requires employers to conduct a hazard assessment per 29 CFR 1910.132(d). This hazard assessment must determine if hazards are present, or are likely to be present, that require the use of PPE. If such hazards are discovered, then you must select, and have each affected employee use, the types of PPE that will protect them.

When an employee is dispatched to assist/tow a vehicle there are several issues to consider:

  • What are the conditions? What is the visibility, weather, temperature, traffic?
  • What will the tow driver do at the scene? Work on the disabled vehicle onsite or tow it to a different location?
  • How close to the moving traffic will the employee be?

Answers to these questions will help you perform your hazard assessment.

Next, you have to communicate those PPE selection decisions to the workers and then find and fit the PPE for each affected employee.

Types of PPE

The hazard assessment should determine the need for the specific types of PPE. Some of those could include:

  • High-visibility apparel
  • Eye protection
  • Head protection
  • Foot protection
  • Hand protection
  • Cold-weather clothing
  • Hot-weather clothing
  • Other types of PPE

High visibility apparel—all workers (ANSI 107-2004)

When you dispatch a driver and tow vehicle to an accident scene make sure you provide the driver with the appropriate high-visibility safety clothing. This would include apparel that meets the Performance Class 2 or 3 requirements of the ANSI/ISEA 107–2004 publication.

The 2009 Edition of the Manual on Traffic Control Devices (MUTCD) states at Section 6D.03 Worker Safety Considerations, Standard 04:

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.

If you also dispatch a flagger to assist your driver, the MUTCD has specific requirements. Section 6E.02 High-Visibility Safety Apparel Standard 01 states:

For daytime and nighttime activity, flaggers 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 Apparel and Headwear” (see Section 1A.11) and labeled as meeting the ANSI 107-2004 standard performance for Class 2 or 3 risk exposure. The apparel background (outer) material color shall be fluorescent orange-red, fluorescent yellow-green, or a combination of the two as defined in the ANSI standard. The retroreflective material shall be orange, yellow, white, silver, yellow-green, or a fluorescent version of these colors, and shall be visible at a minimum distance of 1,000 feet. The retroreflective safety apparel shall be designed to clearly identify the wearer as a person.

Any employee that is dispatched to an accident or breakdown scene must wear high-visibility safety apparel that meets ANSI 107-2004 standard performance for Class 2 or 3 risk exposure.

High visibility apparel—emergency responders (ANSI 207-2004)

The 2009 MUTCD also has an option for emergency and incident responders and law enforcement personnel. Section 6D.03 Worker Safety Considerations, Option 05 says:

Emergency and incident responders and law enforcement personnel within the TTC zone may wear high visibility safety apparel that meets the performance requirements of the ANSI/ISEA 207-2006 publication entitled “American National Standard for High-Visibility Public Safety Vests” (see Section 1A.11), or equivalent revisions, and labeled as ANSI 207-2006, in lieu of ANSI/ISEA 107-2004 apparel.

There is also a newer version of ANSI/ISEA 207-2006. It is the 2011 edition (ANSI/ISEA 207-2011). In Appendix B there are three examples of what is called the “public safety sector” vest. Examples one and two have areas on the vest where the identification text (Fire Service, EMS, Police, etc.) can be placed. The third option does not show any identification text.

What types of personnel are considered to be “emergency and incident responders and law enforcement personnel?” ANSI/ISEA 207-2011 discusses “Identification of Personnel” at section 6.3, which says that, “Public safety industries may be identified with the specific names and colors: Red: Fire Service; Green: Emergency Medical Service (EMS); Blue: Law Enforcement.”

With this said, it appears that only public safety personnel can wear the ANSI 207 class vests. Other employees must wear the ANSI 107 class vests.

These types of high-visibility safety apparel will help protect your employees. When an employee is getting a vehicle ready to be towed, the drivers in oncoming vehicles must be able to see, and take measures to avoid, that employee.

Eye protection

OSHA requires that appropriate eye protection be provided when there is a hazard from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.

If you have employees that are working near moving traffic they could be exposed to road debris being picked up and thrown around. Also, crawling under and around vehicles can exposed them to dirt, road salt, and fumes that can fall into or enter the eyes.
Keeping the debris and related particles out of workers eyes is one of the main reasons to wear eye protection.

Safety glasses (either spectacles or goggles) are a common form of eye protection. If there is a severe hazard from flying objects then a face shield may also be necessary. At the least, safety glasses with side shields should be used.

OSHA requires that eye and face protection devices comply with the ANSI Z87.1-1989 or ANSI Z87.1-2003 consensus standards (American National Standard Practice for Occupational and Educational Eye and Face Protection).

Head protection

Hard hats must be worn when there is the potential for injury to the head from falling objects or bumping the head on an object. Crawling around and under vehicles can expose employees to these hazards. Every call may not require a hard hat to be worn; however, they should be available when needed.

OSHA requires that head protection comply with:

  • ANSI Z89.1–2003, American National Standard for Industrial Head Protection; or
  • ANSI Z89.1–1997, American National Standard for Industrial Head Protection; or
  • ANSI Z89.1–1986, American National Standard for Personnel Protection—Protective Headwear for Industrial Workers—Requirements.

Foot protection

Protective footwear must be worn by employees working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, and where employees’ feet are exposed to electrical hazards. Wrecked vehicles shed parts and pieces that could certainly fall into these categories.

Protective footwear must comply with any of the following consensus standards:

  • ASTM F–2412–2005, Standard Test Methods for Foot Protection and ASTM F–2413–2005, Standard Specification for Performance Requirements for Protective Footwear; or
  • ANSI Z41–1991 or ANSI Z41–1999, American National Standard for Personal Protection—Protective Footwear.

Slipping and falling is another hazard that could be encountered, especially when working in icy conditions. There are specific types of devices that attach to boots that provide added traction in these conditions.

Hand protection

Appropriate hand protection must be used when employees’ hands are exposed to hazards such as those from skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns, and harmful temperature extremes. Wrecked vehicles often have hazards like these. In addition, handling chains and wire rope used to upright and tow vehicles can be hazardous.

Cold-weather clothing

Depending on location of your operations, the winter season may bring cold temperatures, rain, wind (and accompanying low wind chills), and snow and sleet. These hazards can lead to frostbite; hypothermia; and slips, trips, and falls.

In the winter months provide employees working outdoors with the proper outerwear, boots, headwear, and hand protection. In addition, certain winter conditions can result in reduced visibility, so high-visibility safety apparel can be a necessity.

Hot-weather clothing

The summer season can start early for some parts of the country. Hot-weather clothing is a must for employees working outdoors. Avoid dark-colored clothing and clothing that doesn’t breathe. Hats are recommended to be worn when working in direct sunlight.

Other types of PPE

In addition to the types of PPE mentioned, there may be additional categories needed. Examples of these could include respiratory protection and clothing treated with insect repellant.

Wrap up

Employee well-being is always a concern, especially for those working on or near a roadway. Your hazard assessment will determine which hazards are present, or likely to be present, that require the use of PPE by employees. Properly sizing and providing that PPE can send those workers home safely each and every day.

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What Safety Regulations Apply to Me?

This is a common question asked by many types of motor carriers. Who is a motor carrier? Basically, it is anyone that uses a “commercial vehicle” to conduct business on the roadways. This, in most cases, includes tow operators.


For the purposes of the federal Department of Transportation and its agency that oversees interstate motor carrier safety (the Federal Motor Carrier Safety Administration, or FMCSA), a commercial vehicle is a vehicle used in interstate commerce that:

  • Has an actual or rated weight (single or combination) of 10,001
    pounds or more,
  • Is designed to seat either more than 8 or more than 15 people,
    depending on how compensation is handled, or
  • Is carrying a placardable amount of a hazardous material.

“Interstate commerce” is business that crosses state lines. In the case of carriers, it means either the vehicle or the cargo is destined to, or has, crossed a state line as part of the carrier’s movements. In the case of a tow operation, the “cargo” is the vehicle being towed. If the commercial vehicle is used in intrastate commerce, then the state’s definition of a commercial vehicle applies. Many states have adopted the FMCSA’s definition, but other states use their own definition.


If you operate vehicles that meet the FMCSA or state definition of a commercial vehicle, the FMCSA or state’s safety regulations will apply to your operation. If you are an intrastate carrier, you need to be aware that most states have adopted the majority of the FMCSA safety regulations for their intrastate carriers. Therefore, the FMCSA regulations or a slight variation of them may very likely apply to you. The key areas that these regulations cover are carrier credentialing, driver licensing and qualifications (and possibly drug testing), vehicle parts and accessories, hours of service, and vehicle inspection and maintenance. In this article we will discuss these requirements, and following each requirement will be the FMCSA regulation number involved if you want to look up the details.


Carriers that operate in interstate commerce must file an MCS-150 and be issued a USDOT number (see §390.19). If the carrier is charging the public for the service they provide (not just hauling cargo the company owns), the carrier must also have “for-hire authority.” Most states have a similar structure when it comes to their intrastate carriers. In addition, some states and municipalities have additional requirements on tow operators under their jurisdiction. In the case of a for-hire carrier, the company may also be subject to specific insurance minimums (see Part 387).

Once the company becomes a registered carrier, the vehicles must be marked in accordance with the regulations (see §390.21) and the company must maintain an “accident register” where all accidents the company is involved in are recorded. The FMCSA considers an accident to be an occurrence involving a company vehicle that resulted in a death, an injury requiring immediate treatment away from the scene, or a vehicle having to be towed away from the scene due to disabling damage (see §390.15).


Drivers must have the correct license for the vehicle being operated. If the vehicle qualifies as a CDL Class A vehicle (a vehicle weighing or rated at 26,001 pounds or more pulling a towed unit weighing or rated for 10,001 pounds or more) the driver must have a Class A CDL. If the unit being towed is a combination vehicle that has multiple units, the driver would also need to have the “double/triple” endorsement as well as a Class A CDL. If the towing unit weighs more than 26,001 pounds and the towed unit is under the 10,001 pound threshold, then a Class B CDL is required. If the combination is 26,000 pounds or less, and the towed unit is 10,000 pounds or less (and is carrying no placarded hazardous materials), a regular driver’s license is all that is required in most states (see §383.91).

If the vehicle being towed would require the driver of the vehicle to have a special endorsement to his/her CDL (hazardous materials, tanker, etc.) then the tow truck driver would need to have that endorsement as well (see §383.93).

The driver must also have passed a physical and have a valid medical card (see §391.43). The company must have a driver qualification file showing that the driver meets the driver qualification requirements. This file would need to include the driver’s application (§391.21), the background checks done when the driver was hired (§391.23), annual MVR checks (§391.25), annual reviews of driver’s performance (§391.27), road test certificate or equivalent (§391.31 and §391.33), and a copy of the driver’s medical card (§391.43).

Some jurisdictions have additional driver qualification requirements for drivers of tow truck drivers (such as a tow operator certification). If the driver operates a vehicle requiring a CDL to operate, the driver must have been provided a copy of the company’s drug and alcohol policy (see §382.601), and the company must have gotten a verified negative test result and have it on file before using the driver (see §382.301). The company must also have the driver on the random drug and alcohol testing selection list (see §382.305).

Last, the driver is covered by the hours-ofservice regulations. These regulations limit how many hours a driver can drive, how many hours the driver can be on duty, and how many hours of break time the driver must take. The basic rules include not driving after the driver has reached (see §395.3):

  • 11 hours of driving since the last break of 10 hours or more
  • 14 consecutive hours since the last break of 10 hours or more
  • 60 hours on duty in the last 7 days (70 hours in the last eight days if the company operates vehicle 7 days a week and the company chooses to use this option)

To record their hours-of-service compliance, drivers must maintain a “record of duty status,” better known as a “log” (see §395.8). There are exceptions for drivers that operate in “short haul” operations that can allow the company to use time records in place of the driver having to complete a log. The details of these exceptions are in the FMCSA regulations at §395.1(e). The key is that the driver cannot drive once one of these limits is reached, whether the driver is keeping a log or operating under one of the exceptions that allow time records to be kept in place of logs. The driver can still work, just not drive.


Just like the drivers, once a vehicle is a commercial vehicle, certain regulations apply. To begin with, the vehicle needs to be equipped in accordance with Part 393 of the regulations. These regulations mandate what parts and accessories are required and what condition they must be in. The vehicle then must be inspected and maintained by the company in accordance with Part 396, and maintenance records must be kept showing that the vehicle has been systematically inspected, maintained, lubricated, and repaired when necessary (see §396.3). The vehicle and cargo also must be inspected by the driver at the beginning of the workday and the driver must submit a report stating the condition of the vehicle at the end of the day (this is referred to as a driver vehicle inspection report or DVIR). These requirements are covered in the regulations at §392.7, §392.9, §396.11, and §396.13.

Finally, the vehicle must pass a very specific inspection called a “periodic inspection” (commonly called an “annual inspection”) as required by §396.17. If the state has an equivalent inspection that the commercial vehicle must undergo, this can take the place of this required inspection.


One point about these regulations: If the driver is operating in support of an emergency, then some or all of the regulations do not apply. An emergency in the case of towing includes:

  • A request from law enforcement to assist in clearing an accident or disabled vehicle from traffic.
  • Operating in support of a declared disaster.

When responding to a request from law enforcement or in the case of a declared disaster, the driver and vehicle are only exempted from the regulations when he/she is responding to, operating in direct support of, and returning from the event. In both cases, the regulations in Parts 390 to 399 are the regulations the driver and vehicle are exempted from, meaning that, if the vehicle requires a CDL driver to operate it, the drug and alcohol regulations in Part 382 and CDL regulations in Part 383 still apply. What it comes down to is, if the driver is doing “every day towing” (such as customer called- in tows, dealer tows, or auction tows) and not operating in one of the two emergency situations discussed above, all of the rules that normally apply to a commercial vehicle and its driver apply. The driver is only exempt from the rules in Parts 390 to 399 when the driver is involved in emergency or disaster relief operations.

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Lifting-Related Back Injuries: A Common, but Avoidable Occurrence

How to Avoid Back Pain while working a job.

How to Avoid Back Pain while working a job.

Using proper posture may be the last thing on an operator’s mind when out on a call. Instead, they may be focused on avoiding oncoming traffic, figuring out the best way to hook the vehicle, navigating slippery or uneven terrain, and braving the elements.  While these are all critical, so too is putting the body in the best position to avoid sprains, strains, and other musculoskeletal injuries.

According to the Bureau of Labor Statistics (BLS), strains and sprains are the most common type of injury/illness requiring days away from work for tow truck operators, with back injuries comprising the majority.

Why it’s a problem

Back injuries, though extremely common, are not always recognized until it’s too late. Often, the disorders develop gradually as a result of repeated small traumas to the back. Further, the conditions are often ignored until the symptoms become severe.

Tow operators may associate a back injury or sudden pain with a specific heavy lift, but often the real cause is the combined interaction of the heavy lift coupled with years of weakening musculoskeletal support due to repetitive small traumas. So, it’s critical that operators utilize proper technique at all times, even when the back is feeling good!

Even tougher problem for tow operators

For tow operators, the work environment is constantly changing and, often, the operators don’t find out what they’re dealing with until they arrive at the site. This makes it very challenging to plan ahead. Add to that the variation in temperature, site conditions and location, vehicle condition, and schedule, and it is easy to see why tow operators have a tough time combatting back injuries. That being said, there are measures operators can take to prevent these injuries.

How to identify back pain.

How to identify back pain.

Identify the problem areas

It is true that no two towing jobs are identical. But, there are similarities in many. And, there’s always one constant: the operator. If the operator can learn to identify the factors that can pose a risk for back injury, he/she can utilize effective safeguards and techniques no matter the specific environment.

Back disorders result from exceeding the capability of the muscles, tendons, discs, or the cumulative effect of several contributors. According to the OSHA Technical Manual, these contributors include:

  • Reaching while lifting
  • Poor posture—how one sits or stands
  • Stressful living and working activities—staying in one position for too long
  • Bad body mechanics—how one lifts, pushes, pulls, or carries objects
  • Poor physical condition—losing the strength and endurance to perform physical tasks without strain
  • Poor design of job or work station
  • Repetitive lifting of awkward items, equipment
  • Twisting while lifting
  • Bending while lifting
  • Maintaining bent postures
  • Heavy lifting
  • Fatigue
  • Poor footing such as slippery surfaces, or constrained posture
  • Lifting with forceful movement
  • Vibration, such as with driving a truck

Know how much is too much

No matter how great the lifting technique is, if the load is too much, then the body may break down. Operators have to recognize when a manual lift is beyond their physical limits and either use a mechanical aid, get help from another person, use two hands rather than one, move closer to the object being lifted, divide the load into multiple trips, or adjust body posture (in those limited cases where a posture shift will allow the load to be within acceptable limits of the body).

Determining an operator’s safe lifting limits is challenging because there is no across-the-board recommendation or standard; the weight a given worker can safely lift varies depending on several factors, including  condition of the worker, body posture, closeness to the load, height of the lift, twisting required, and frequency of the lift.

Operators cannot simply go by the weight of the object. The same worker who can lift a 50-pound box with ease under ideal conditions may not be able to safely lift the same box when crouched, or the same weight when it’s an oddly-shaped object rather than a box.  OSHA notes in an eTool that, generally, more weight can be safely lifted when the:

  • Load is close to the body and not too large or bulky,
  • Lift is at waist height,
  • Lift is performed in front of the body,
  • Lift is performed only occasionally,
  • Lift does not involve carrying, and
  • Load has handles.

In determining maximum safe lifts, operators may want to consider utilizing several tools. For example, OSHA often utilizes the National Institute for Occupational Safety and Health (NIOSH) Lifting Equation to evaluate manual two-handed lifts during a workplace inspection. The NIOSH equation sets a fixed weight of 51 pounds as the load constant (that is generally considered the maximum load nearly all healthy workers should be able to lift with two hands under optimal conditions.)

View the NIOSH Lifting Equation and Applications Manual

An alternative lifting guide that focuses on male/female population percentages capable of performing a two-handed lift with certain characteristics, rather than on maximum weight limits, are the Liberty Mutual Material Handling tables.

While it is not practical to utilize the NIOSH equation or similar types of guides while out on a towing call, operators can utilize these before going out to a site to get a general idea of a safe weight for various types of work.

Use proper technique

We’ve all heard the saying “lift with your knees, not your back.” While that statement is a good general rule-of-thumb, there is much more to safe lifting than that.

For typical lifts, it is recommended to:

  • Size up the load—Operators need to get a good estimate of the weight of the object, how the weight is distributed, condition of the object and handholds, and where the object will be taken. (Testing the load by lifting an edge/corner can give many clues as to the characteristics of the load.)
  • Place the body close to the load—Operators should place their feet close to the object and center themselves over the load, utilizing a wide stance.
  • Maintain neutral and straight spine alignment whenever possible—OSHA has noted that usually, bending at the knees, not the waist, helps maintain proper spine alignment.
  • Get a good grip, using two hands where possible.
  • Lift straight up in a smooth manner, using the legs to push up/ lift the load rather than the back or upper body.
  • Avoid twists and turns and jerking motions. If turns must be made, operators should step to one side.
  • Keep the load in the power zone (above the knees, below the shoulders, and close to the body) where possible.

But, what about non-typical lifts, like heavier, small-sized objects? In these cases, there may be a better way to lift. In a NIOSH publication, Ergonomic Guidelines for Manual Material Handling, it is recommended that for heavier small-sized objects (such as a sack) workers:

  • Kneel in front of the object;
  • Lean the object onto the kneeling leg;
  • Slide the object up onto kneeling leg;
  • Slide the object  onto the other leg while keeping the object close to the  body; and
  • While standing up, keep the object close to the body.

Beware of heavy tools

When we think of lifting injuries, we often think of a worker trying to pick up a box, container, or similar object to move it from one location to another. While those lifts certainly pose challenges, there are other lifting-related hazards that operators need to be aware of as well, for example, picking up a heavy tool and holding it. If a tow truck operator can remember to balance tools such as impact wrenches, rather than holding them, it can reduce the risk of sprain and strain. Additionally, just as it is proper technique to not twist or turn or make jerking motions while carrying an object on a two-handed lift, operators should avoid these actions when carrying heavy tools and equipment with one hand.

Avoid bending while lifting

Tow operators often find themselves having to work in many awkward positions. When combined with lifting, awkward postures pose a great risk for injury. In particular, bending while lifting forces the back to support the weight of the upper body in addition to the weight being lifted. OSHA notes that bending while lifting places strain on the back even when lifting something as light as a screwdriver.

Bending moves the load away from the body and allows leverage to significantly increase the effective load on the back. This increases the stress on the lower spine and fatigues the muscles.

Also, keep in mind that carrying loads on one shoulder, under an arm, or in one hand, creates uneven pressure on the spine.

Place heavy items mid-level

OSHA recommends that materials that must be manually lifted should be placed at “power zone” height, about mid-thigh to mid-chest.  Operators should evaluate their trucks for optimal placement of tools and equipment, so that the heaviest and most utilized equipment can be accessed easily and within the power zone, where possible. Further, operators should remove obstructions around tools and equipment so that the body doesn’t have to bend while lifting and the load doesn’t have to be farther away from the body than need be.

Maintain equipment

Tow operators have some built-in ergonomic equipment right on the truck. It is important to take advantage of this equipment; that means keeping it maintained. Obviously, poorly maintained vehicle lift/hoist equipment can pose serious hazards if the load falls. But, beyond that, if handles don’t turn smoothly or levers stick, it can require more force from the operator—posing risk of injury to the back and other body parts.

This should extend to the operator’s cab as well. If the driver’s seat isn’t adjusted properly or is worn down, operators may not be getting proper back support. As much time as operators spend in the cab, it’s important the seat provides proper support—over time, this can lead to increased risk for back injury.

Operators should make sure their regular vehicle service program includes those items that make the job easier and safer!

Utilize tools and resources

In addition to the NIOSH Lifting Equation and similar guides, there are many great tools and resources to help operators combat back injuries. For example, the Washington State Department of Labor and Industries maintains an Ergonomics Ideas Bank that may be helpful in finding ways to address various ergonomic issues.

In addition, operators may find it helpful to review catalogues from material handling suppliers, speak with others in the tow industry, and/or work with an ergonomics professional. (Often a workers’ compensation insurance carrier will have ergonomics professionals on staff or else can recommend assistance.)

Remember, there may be a better way

Lifting safely requires constant self-reminders. Out on a job site it can be easy to forget to do this. But, if operators can get in the habit, it can save a lifetime of back pain.

Bio: Travis Rhoden is an editor with J. J. Keller and Associates, Inc. Contact him at For more information on J. J. Keller & Associates, Inc. visit
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