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# 

April 29, 2008

U.S. Department of Transportation

Dockets Management Facility

1200 New Jersey Avenue, SE.,

Washington, DC 20590,

> RE: FHWA Docket No. FHWA--2007--28977

National Standards for Traffic Control Devices

> The Manual on Uniform Traffic Control Devices
>
> for Streets and Highways; Revision

Gentlemen:

Thank you for the opportunity to provide comments on the proposed new
MUTCD. My comments are concerning Chapter 6E. [Flagger
Control]{.underline}.

I applaud FHWA's attempts to limit the exposure of flaggers to traffic
hazards by the inclusion of the Automatic Flagger Assistance Device
(AFAD) sections. It is evident, however, that even with increased use of
AFADs, there will still be flaggers with STOP/SLOW paddles or flags in
work zones.

I believe there is room for further improving the requirements for the
use of flaggers, their equipment, and how they operate to control
traffic.

The only specific requirement that addresses visibility of STOP/SLOW
paddles is a Standard statement in Section 6E.03, "...When used at
night, the STOP/SLOW paddles shall be retroreflectorized." Does the
Final Rule addressing minimum levels of retroreflectivity for signs also
apply to the STOP/SLOW faces? How can we improve the visibility of
STOP/SLOW paddles at night and in other low light conditions?

The new language regarding the use of a 7 foot staff is only suggested
when a staff is used. Flaggers have the option of using a paddle with
only a handle if they choose or if this is the only device provided to
them. Requiring the use of a 7 foot minimum length staff should be
considered by FHWA to ensure that the device is positioned to be visible
by more than just the first approaching vehicle.

Significant steps have been taken over the last few editions of the
MUTCD to improve the visibility and conspicuity of the flagger. We can
further improve their visibility by creating a Guidance statement (a
**should** condition) that STOP/SLOW paddles, when used at night, be
modified as provided in the current Option statement in lines 19 -- 35
on page 960 of the NPA Text Showing Revisions. [Section 6E.05 STOP/SLOW
Automated Flagger Assistance Devices]{.underline} contains a Standard
that requires minimum size STOP and SLOW signs and requires that these
signs "be supplemented with active conspicuity devices..." such as white
or red flashing lights. Shouldn't flaggers be protected by enhanced
devices also? A "should" condition will increase the likelihood that
improved and properly maintained devices are utilized. Unfortunately,
even in areas where worker safety is involved, decisions are made to use
only those devices that meet the minimum requirements. These devices are
also usually cheaper to purchase. The current Option statement regarding
STOP/SLOW paddles with flashing lights may inform users and specifiers
of their availability but it does not "guide" them to serious
consideration of their use. Yet, we require the use of flashing lights
with AFAD devices that allow the flaggers to be physically removed from
the roadway.

Thank you for the opportunity to comment on this rulemaking.

Sincerely,

Henry A. Ross

Director, Sales & Marketing