Training Spanish-Speaking Traffic Control Crews: What OSHA Expects and What Works in the Field

A flagger's job is communication. They read a situation, receive an instruction over a radio, and pass a message to a driver with a paddle and a hand. When the instruction arrives in a language the flagger only half follows, the paddle still turns, and nobody knows anything went wrong until something does.

That is why language belongs in a traffic control company's safety program, not in its HR folder. This guide covers who is on the crews, what OSHA has said about training in a language workers understand, where language gaps cause real failures in traffic control, and the practical steps that work: training, briefings, radio discipline, written material, and the records to keep.

It is written about Spanish because that is the second language on most crews in the United States. The same approach applies to any language your people speak. Nothing here is legal advice. State-plan OSHA programs, state DOT rules and contracts can add requirements, so confirm the rules for your jobs with your safety adviser and the agency.

Who is on the crew

The size of the question is not a guess. In the Bureau of Labor Statistics' annual household data for 2025, 35.4 percent of the 12.1 million people employed in construction were Hispanic or Latino, compared with 20.0 percent of all employed people. That figure is for construction as a whole, and it describes ethnicity, not language. Many Hispanic workers are native English speakers or fully bilingual. It still tells you that on a typical road job, a large share of the people on foot may be more comfortable in Spanish.

The fatality data is the reason to care. BLS's Census of Fatal Occupational Injuries recorded 1,229 fatal work injuries among Hispanic or Latino workers in 2024, a rate of 4.3 per 100,000 full-time equivalent workers, and 68.5 percent of those deaths, 842, were among foreign-born workers. The same release reports 5,070 fatal work injuries in total in 2024, with transportation incidents the most frequent type of fatal event at 38.2 percent.

Traffic control sits where those two facts meet. It is transportation-incident work, done on foot, by a workforce in which many people were born elsewhere. On road construction sites specifically, the National Work Zone Safety Information Clearinghouse reports that a worker on foot struck by a motor vehicle accounted for 52.7 percent of worker fatalities over 2022 to 2024.

None of those sources says language caused a particular death, and this article does not claim it. What they establish is who is exposed. If your training reaches only the English speakers, it is missing a large part of the people it was meant to protect.

What OSHA has said

OSHA's standards are full of requirements to "train" or "instruct" employees. For construction, the general one is 29 CFR 1926.21(b)(2), which requires the employer to instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to their work environment.

In 2010 the agency published a memorandum to its regional administrators explaining how it reads those requirements. "In practical terms, this means that an employer must instruct its employees using both a language and vocabulary that the employees can understand," wrote David Michaels, then Assistant Secretary of Labor for Occupational Safety and Health, in the OSHA Training Standards Policy Statement dated April 28, 2010.

The memorandum goes on to give examples. If an employee does not speak or comprehend English, instruction must be provided in a language the employee can understand. If the employee's vocabulary is limited, the training must account for that. If employees are not literate, telling them to read training materials will not satisfy the employer's obligation.

Three practical points follow from that, and they apply whatever language is involved:

1. Delivery is not the test. Understanding is. A session that was held, signed for and not understood has not done its job.
2. Translation alone may not be enough. A translated handout does not help someone who reads little in any language, or who knows a regional word for a device that the handout does not use.
3. Vocabulary matters as much as language. A fluent English speaker who has never worked on a road does not know what a "taper" or a "buffer" is either.

How an inspector would apply the policy to your company is not something an article can tell you. If you are unsure, ask your state consultation program or OSHA area office. OSHA's highway work zones page collects the standards that apply to road work.

What the traffic control standards add

The MUTCD does not set a language requirement, but it describes the abilities the job needs. Section 6D.01 of Part 6 of the 11th Edition lists the abilities a flagger should be able to demonstrate. Among them are receiving and communicating specific instructions clearly, firmly and courteously, and understanding and applying safe traffic control practices. Section 6C.04 says all workers should be trained on how to work next to motor vehicle traffic in ways that minimize their vulnerability, and that workers with specific traffic control responsibilities should be trained in techniques, device usage and placement.

OSHA ties flagging to the manual. 29 CFR 1926.201 requires signaling by flaggers to conform to Part 6. So the standard a Spanish-speaking flagger has to meet is the same standard as everyone else. The employer's task is to make sure the training that gets them there is understood.

NIOSH, in its bulletin on preventing injuries from backing construction vehicles at roadway worksites, recommends that employers develop, implement and enforce a comprehensive safety and training program in the workers' primary language and at the appropriate literacy level. That is a recommendation from fatality investigations, not a regulation, and it is the clearest one-line statement of good practice available.

States and agencies can add more. Some specify which flagger credentials they accept and how the course must be delivered. Ask before you assume a Spanish-language course or card will be accepted on a given agency's work. See flagger certification requirements explained.

Where language gaps actually cause failures

General statements about "communication" do not help a crew lead. These are the specific points in a traffic control day where a language gap does damage.

The radio call. One-lane, two-way flagging depends on two people agreeing who has traffic. "Last car is the white pickup" has to mean the same thing at both ends. A flagger who is translating in their head answers a beat late, or answers "okay" to something they did not catch. Our guide to how a flagger tells traffic to proceed covers the signals themselves; the radio procedure around them is where language bites.

The plan change. At 10 a.m. the paving foreman moves the work 300 feet and wants the taper shifted. The instruction passes through three people. Each handoff across a language boundary loses detail. The crew moves the cones. Nobody moves the advance warning signs.

The driver at the window. A stopped driver asks how long the wait is or how to reach a driveway. The manual expects flaggers to deal with the public courteously. A flagger who cannot answer may wave the driver through to end the conversation.

The emergency. An ambulance needs through, or a truck has entered the closure. The words used in the next ten seconds need to have been agreed in advance.

The other contractor's equipment. A flagger with their back to the work is warned by an operator, in English, over engine noise. See preventing backover incidents in work zones for the case NIOSH documented.

The paperwork. A crew lead signs a daily ticket or an inspection checklist they could not fully read. The record now says something the crew lead did not mean to say.

Each of these has a practical fix, and none of the fixes is "hire only English speakers," which would shrink your labor pool and, depending on how it was done, could raise legal questions of its own. Talk to an employment attorney before writing any language requirement into a job description.

What works: training

Deliver certification training in the language the worker learns best in. Ask your training provider whether the flagger course, the materials and the exam are available in Spanish, and ask the agencies you work for whether they accept that version. Do not assume either answer.

Teach the vocabulary in both languages, on purpose. The terms on the plan, the radio and the sign faces are English. A Spanish-speaking flagger needs to recognize "taper," "buffer," "shoulder," "lane closed," "flagger ahead" and "one lane road" by sight and by ear, even if the explanation of each was given in Spanish. A short two-column glossary of your own job terms, built with your bilingual crew leads, is worth more than a generic translated manual. Our traffic control glossary is a starting list of the English terms.

Train with the equipment, not with slides. Set a short taper in the yard. Have each trainee place the signs, hold the paddle, give the three signals, and call a release on the radio. Physical practice crosses language better than any document, and it works for people who do not read easily.

Check understanding by asking for a demonstration. "Do you understand?" gets a yes in any language. "Show me where you stand when the truck backs up" gets an answer you can evaluate. So does "tell me what you do if you lose the radio."

Use a qualified bilingual trainer, not a volunteer interpreter. Asking a bilingual laborer to translate a safety class on the fly puts an unfair burden on them and gives you no control over what was said. If you use an interpreter, give them the material in advance.

Repeat it. New-hire training is one day. The skills are used for years. Short refreshers at the start of the season and after any incident keep the vocabulary alive.

What works: the daily briefing

The pre-shift briefing is where most real instruction happens, and it is the easiest place to lose half the crew.

• Say each point in both languages before moving on. Do not give the whole briefing in English and then a summary in Spanish. The summary is always shorter than the original, and what gets dropped is usually the detail that mattered.
• Point at things. Walk the crew to the first sign location. Show the escape route. Use the plan sheet and a finger.
• Assign the bilingual role. Each crew should have a named person responsible for making sure instructions cross the language line during the shift. If that person is absent, dispatch needs to know before the crew leaves.
• Agree the radio words. Pick a small set of fixed phrases for release, stop, hold, and emergency, and use only those. Many bilingual crews settle on English phrases for the radio because the foreman and the other contractor use English, and practice them until they are automatic.
• Ask one person to repeat the plan back. Rotate who it is.

Our guide to tailgate safety meetings for traffic control crews has a format that fits in five minutes.

What works: written material

Decide which documents a worker must be able to read, and deal with each one.

Safety policies and the handbook. Provide them in Spanish, translated by someone who knows the trade's vocabulary. Machine translation of safety text produces errors that range from funny to dangerous. Have a bilingual crew lead read the result before it goes out.

Daily tickets and checklists. If a crew lead signs it, they need to understand what they are signing. Bilingual labels on the form cost almost nothing.

Sign faces and plan sheets. These stay in English because the road does. Train recognition instead.

Pay, schedule and dispatch messages. A dispatch text that says where to be, at what time, with what equipment, should be as unambiguous as you can make it. Short sentences, addresses that can be tapped, and no slang. Confusion about a start time is a language problem as often as it is a reliability problem.

Emergency information. Site address, nearest hospital, who to call. Both languages, on a card in every truck.

What works: structure

Promote bilingual crew leads, and pay for the skill. A crew lead who can brief in both languages, talk to the inspector and talk to the public is doing more work than one who cannot. Companies that recognize it in the pay rate keep those people. See training new traffic control crew leads and hiring and retaining flaggers.

Pair deliberately. A new hire with limited English paired with a patient bilingual partner for the first weeks learns the vocabulary faster than in any class.

Do not isolate. A crew made up entirely of Spanish speakers with no bilingual lead cannot take an instruction from an English-speaking foreman. A flagger alone at the far end of a closure with a radio and limited English is the same problem in a smaller package.

Offer language help in both directions. Some companies pay for English classes. Fewer think to teach their English-speaking supervisors fifty words of job-site Spanish. Both shorten the gap, and the second one costs an afternoon.

Make reporting easy in Spanish. A worker who cannot easily report a near miss or a hazard in their own language will not report it. That is a loss of information you need. See measuring safety performance in a traffic control company.

The cost of getting it wrong, and of getting it right

Contractors already live with frequent work zone crashes. In the 2026 AGC and HCSS highway work zone survey, 60 percent of contractors reported at least one crash involving a moving vehicle in their work zones in the past year, and among firms that had crashes, 27 percent reported crashes that injured construction workers. A traffic control company cannot control the drivers. It can control whether every person on its crew understood the plan that morning.

The costs of a bilingual program are modest: translation of a handful of documents, a Spanish-language course fee, some paid time for a glossary and a yard session, and a pay differential for bilingual leads. The costs it avoids are an injury, a claim, a higher experience modification rate, and the loss of a customer who watched your crew fail to follow an instruction. Our post on safety records and EMR in prequalification explains how a single claim follows a company for years.

There is also a plain business case. In a tight labor market, the company known for treating Spanish-speaking workers as full members of the crew, with real training and a path to crew lead, has a recruiting advantage that an extra dollar an hour does not buy.

The records to keep

Training you cannot show did not happen, as far as a customer's safety auditor or an investigator is concerned. For language, keep four things.

1. Language preference on the employee record. Ask at hire which language the person prefers for training and for written material. Do not guess from a name.
2. Training records with the language noted. Date, topic, trainer, language of delivery, attendees, and how understanding was checked.
3. Who the bilingual lead is on each crew, each day. This belongs on the dispatch record, because it is a staffing requirement like a certified flagger or a driver with the right license.
4. Briefing records. A daily note that the briefing was held, in which languages, and who attended.

The third one is where most companies fall down. A dispatcher building tomorrow's crews from memory will send three Spanish-speaking flaggers and an English-only lead to a job with an English-only foreman, because nobody recorded the constraint anywhere they could see it. Treat language the way you treat credentials: as something dispatch checks before the crew is assigned. Our post on tracking crew qualifications before dispatch describes the mechanics.

This is the kind of record a system should hold so people do not have to. In Traffic OS, crew assignment, daily tickets and the audit trail live together, so the question "who was the bilingual lead on that job on that day" has an answer. The features page lists what is included, and because each pricing tier includes a block of driver seats, flaggers can have their own logins for schedules and tickets.

A starting checklist

If you have done none of this, do these in order.

• Ask every current employee which language they prefer for training and written material, and record it.
• Identify your bilingual crew members and ask which of them are willing to take the lead role. Agree what it pays.
• Find out whether your flagger training provider offers Spanish delivery and whether your agencies accept it.
• Build a one-page, two-column glossary of your job terms with your bilingual leads.
• Translate the safety policy, the emergency card and the labels on your daily ticket.
• Change the briefing format so each point is given in both languages before the next.
• Agree and practice the fixed radio phrases.
• Add "bilingual lead" as a requirement dispatch checks for any crew that needs one.
• Record all of it.

The short version

More than a third of the construction workforce is Hispanic or Latino, and the fatality data shows foreign-born Hispanic workers carrying a heavy share of the deaths. OSHA's position since 2010 is that training has to be given in a language and vocabulary workers understand. For a traffic control company that means Spanish-language training where it is needed, bilingual briefings delivered point by point, fixed radio phrases, a named bilingual lead on each crew, and records that show it. It is not expensive. It does require deciding to do it.

If you want to see how crew requirements, assignments and signed daily records fit together, book a walkthrough.