Guide to Hard Hat Requirements
Protective helmets should be worn in any work environment that presents a significant risk of head injury. There are various types of hard hats that may reduce the impact from falling objects or protect against electrical shock. Check out PE Facts to find out more about hard hat performance and safety!
The OSHA refers to the American National Standards Institute (ANSI) guidelines for their standard of performance criteria, referenced in the Code of Federal Regulations (CFR) Title 29 is OSHA's guidelines for Occupational Head Protection (1910.135). This document will discuss the ANSI guidelines along with the OSHA standard for occupational head protection.
Occupational Head Protection
The standard states in 29 CFR 1910.135(a)(1) that, "Each affected employee shall wear protective helmets when working in areas where there is a potential for injury to the head from falling objects." The standard also addresses situations in which electrical hazards are present. 1910.135(a)(2) states, "Protective helmets designed to reduce electrical shock hazard shall be worn by each such affected employee when near exposed electrical conductors which could contact the head."
The OSHA standard does not specify the occupations or applications where head protection is mandatory, but it does address this topic under a non-mandatory appendix (Appendix B to Subpart I—Non-Mandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection). Part (9) of the appendix states, "Some examples of occupations for which head protection should be routinely considered are: carpenters, electricians, lineman, mechanics and repairers, plumbers and pipe fitters, assemblers, packers, wrappers, sawyers, welders, laborers, freight handlers, timber cutting and logging, stock handlers, and warehouse laborers." The appendix also describes various applications where head protection should generally be worn.
1910.135 defines what constitutes a "protective helmet" by distinguishing between hard hats purchased before July 5, 1994, and hard hats purchased after this date. Protective helmets purchased before this date only had to meet the 1969 version of the ANSI standard (ANSI Z89.1-1969). Protective helmets purchased after this date now have to meet the performance criteria of the ANSI Z89.1-1986, American National Standard for Personal Protection—Protective Headwear for Industrial Workers Requirements.
Requirements of ANSI Z89.1-1986
Before we go any further, it is important to understand the difference between hard hats and bump caps. Bump caps do not abide by the ANSI guidelines and are not suitable for occupations or applications where an ANSI-compliant hard hat is required by the OSHA.
The ANSI standard differentiates protective headwear into specific types and classes. It groups helmets into two categories, Type 1 and Type 2. Type 1 helmets have a full brim around the entire hat while Type 2 helmets have a short brim only in the front. Type 2 hats are the dominant style in the field today. You will seldom find specific hard hat types in the compliance guidelines for these products. However, understand that there is a choice available and which type of helmet you select should depend on your specific application or work conditions.
ANSI recognizes three classes of electrical performance:
Class A Helmets are designed to decrease the impact of falling objects and to lessen the risk of being exposed to low-voltage electrical conductors. Helmets are tested at 2200 volts of electrical charge in order to be certified.
Class B Helmets are also intended to decrease the impact of falling objects, but these helmets reduce the risk of coming into contact with high-voltages electrical conductors. They are tested at 20,000 volts of electrical charge in order to receive certification.
Class C Helmets also reduce the force of impact of falling objects, but do not protect against electrical contact.
Note : The voltages stated in Classes A and B are not indications of the voltage at which the helmets protect the wearer.
Protective headwear is also tested for resistance to impact and penetration from hits on the top of the head, water absorption and flammability resistance. The standard describes the meticulous testing requirements in detail.
Any protective helmet that complies with the ANSI requirements must be marked with certification. The following information must be stated inside the hat:
- The manufacturer's name
- The legend, "ANSI Z89.1-1986"
- The class designation (A, B or C)
ANSI revised its Z89.1 protective head wear standard in 1997. Although the revision has not yet been incorporated into 29 CFR 1910.135, it contains some noteworthy changes. The revised standard removed the Type 1 and Type 2 brim design differentiation. Now Type I refers to hard hats that only provide protection from hits on top of the head and Type II describes hard hats that protect from blows to the top as well as the side of the head.
This revised standard also changed the classifications of electrical performance. Z89.1(1997) recognizes the following classes:
- Class G (General) Helmets --This is equivalent to the old Class A. Class G hard hats are tested at 2200 volts.
- Class E (Electrical) Helmets --This is equivalent to the old Class B. Class E protective helmets are tested at 20,000 volts.
- Class C (Conductive) Helmets -- Class C did not change from the old standard. This class provides no electrical insulation.
The 1997 standard also requires helmets to hold user information . Compliant hard hats must include the date of manufacture along with the manufacturer's name. The hard hat must also contain sizing instructions, guidelines for care and service, as well as the ANSI legend and class description.
Contrary to popular belief, hard hats do not have a pre-determined service life. In both the 1986 and 1997 versions of the ANSI standard, service life is discussed under the care and maintenance of the helmet. Those standards recommend checking protective helmets for dents, cracks, or any other damage daily. If a hard hat fails this simple visual inspection, it should be withdrawn from use until repaired.
In addition to damage from impact or rough treatment, ultraviolet (UV) radiation can be troublesome to plastic hard hats. The helmet looking chalky rather than having a nice glossy finish is an indication of UV damage. The flaking of the shell reveals even further damage. As soon as these signs of UV radiation degradation are seen, the hard hat should be replaced.
In 2003, ANSI once again revised the Z89.1-1997 standard. The changes were made according to national standards for head protection that test and evaluate the performance of such equipment. Many requirements were removed that involved hard hat components that did not increase user value, that limited design or limited performance.
Commonly Asked Questions
Q. Can decals be put on hard hats?
A. In most cases, yes. There is an extremely low risk for a chemical reaction between the hard hat shell and the pressure-sensitive sticker/decal adhesive. Under normal conditions, stickers and decals won’t negatively affect the performance of the hard hat.
Generally, these two rules of thumb should be followed:
- The decals should be placed at least three-fourths of an inch away from the edge of the hard hat. This eliminates the risk of the decal acting as a conductor between the inside and outside of the helmet.
- In order to easily inspect the hard hat for damages, the areas of the hard hat covered by stickers/decals should be kept to a minimum.
Q. Is it safe to paint a hard hat?
A. ANSI Z89.1-2003 Appendix A4 states, when painting hard hat shells, caution should be used because some paints and thinners may damage or degrade the shell decreasing the level of protection. Before painting, consult the hard hat manufacturer.
Q. Can hard hats be worn backward?
A. Generally, no. The Occupational Safety and Health Administration (OSHA) released a standard interpretation and compliance letter dated July 22, 1992 that states:
"Because ANSI only tests and certifies hard hats to be worn with the bill foreword, hard hats worn with the bill to the rear would not be considered reliable protection and would not meet the requirement of 29 CFR 1926.100 (a) and (b) unless the hard hat manufacturer certifies that this practice meets the ANSI requirements."
Before wearing your hard hat backward, you should obtain written verification and directions from the manufacturer on whether or not your hard hat model has been tested and found to be compliant with safety standards when worn backward.
Sources for More Information
OSHA 29 CFR 1910.135,
Occupational Head Protection Standard
Please Note: The information contained in this publication is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific questions should refer to the cited regulation or consult with an attorney.