Head injuries are one of the most common types of injuries in construction and industrial workplaces. To protect workers from head injuries caused by falling objects, electrical hazards, and other dangers, the Occupational Safety and Health Administration (OSHA) has established requirements for wearing hard hats at job sites.
OSHA Standard for Head Protection
OSHA’s standard for head protection is outlined in 29 CFR 1926.100 and 29 CFR 1910.135. This standard establishes the requirements for wearing hard hats to reduce head injuries and fatalities in the workplace. The major requirements for head protection under the OSHA standard include:
- Employers must ensure that workers wear hard hats when working in areas where there is a potential for injury to the head from falling objects.
- Hard hats must comply with ANSI performance standards for industrial head protection.
- Hard hats must be worn with the bill facing forward, unless designed to be worn otherwise.
- Hard hats must be worn the proper way, not backwards or sideways.
- Hard hats should be inspected regularly for damage or wear that could reduce protection.
- Hard hats should be properly maintained and replaced as needed.
In general, OSHA requires employers to provide hard hats and ensure their use in construction, shipyards, factories, warehouses, and other workplaces with potential overhead or falling object hazards. Workers must wear the provided hard hats properly to receive protection.
Hard Hat Types
OSHA’s head protection standard references several standards from the American National Standards Institute (ANSI) that establish performance requirements for different types of hard hats:
- ANSI Type I – Provides impact and penetration resistance to top of head only.
- ANSI Type II – Provides impact and penetration resistance to top and sides of head.
- ANSI Class G (general) – General service; provides impact and penetration resistance.
- ANSI Class E (electrical) – Electrical; provides impact and penetration resistance plus added protection from electrical hazards up to 20,000 volts.
- ANSI Class C (conductive) – Conductive; provides lightweight comfort with limited voltage protection.
Common hard hat types used to meet OSHA requirements include:
- Full brim hard hats – Protect head, face, and neck.
- Hard hat with ratchet adjustment – Easily adjusts to fit head size.
- Bump caps – Lighter weight but provide less impact protection.
- High heat hard hats – Resist heat and sunlight during hot work.
- Cowboy hard hats – Provide high visibility and style.
- Vented hard hats – Cooler in high heat conditions.
To meet OSHA standards, hard hats should have ANSI labeling visible inside the shell to indicate their performance type and electrical protection class.
When Hard Hats Are Required
OSHA requires employers to conduct workplace hazard assessments to identify conditions or locations that necessitate PPE like hard hats. In general, hard hats must be worn in construction, demolition, and industrial work zones with these overhead hazards:
- Falling tools, materials, equipment or debris
- Beam or girder work
- Scaffolding
- Formwork and falsework erection/dismantling
- Working under catwalks or open stair wells
- Working around or under conveyor belts
- Demolition work
- Working around cranes or other lifting machinery
- Working around exposed energized electrical conductors
- Confined space work with limited standing room
- Working under machinery that presents hazards from falling objects
OSHA also requires hard hat use in locations where there are dangers from impact or penetration injuries, including:
- Low overhead clearances
- Protruding objects
- Exposed beams or framing
- Working inside trenches or excavations
- Work near exposed electrical wiring or components
Exceptions to Hard Hat Requirements
OSHA allows some exceptions to the requirement for hard hat use where an employer can demonstrate that wearing a hard hat is not feasible or presents a greater hazard. Examples include:
- Where hard hat suspension systems or the hat itself may get caught up in machinery or moving parts.
- In confined spaces with limited standing room where a hard hat could significantly restrict movement.
- Where there is minimal hazard from falling objects and use of hard hats could cause distraction or reduce visibility.
- Where workplace conditions like extreme heat could create additional hazards to workers wearing hard hats.
However, exceptions must be justified through hazard assessments and require detailed documentation by employers. OSHA compliance officers may request to review this documentation during inspections.
Hard Hat Requirements for Electrical Workers
Electrical workers are exposed to hazards from falling objects as well as burns and electric shock from contact with exposed energized conductors and circuit parts. OSHA requires electricians and electrical line workers to wear hard hats that meet ANSI Class E (electrical rating) and Class G (general ratings):
- Class E hard hats provide dielectric protection up to 20,000 volts phase-to-ground.
- Class G hard hats provide impact and penetration resistance.
- Electrical workers must not wear hard hats with metal components, which can conduct electricity.
- Work near high voltage lines or equipment may require additional head protection like arc-rated face shields.
Maintaining and Replacing Hard Hats
To maintain the full protective value of hard hats, OSHA requires regular inspection, maintenance, and replacement of hard hats according to these guidelines:
- Inspect hard hats at least daily for signs of dents, cracks, penetration or other damage that may reduce impact protection.
- Check suspension systems for fraying, damaged or missing straps and adjustments.
- Ensure hard hats are free from dirt, grease or chemicals that may weaken materials.
- Clean hard hats regularly with mild soap and water.
- Replace hard hats and suspension systems at least every 5 years from the date of manufacture.
- Replace hard hats immediately if damaged or subjected to heavy impact.
- Do not alter the hard hat shell or liner in any way.
- Do not decorate or paint over hard hats except for color coding.
- Do not store hard hats in direct sunlight, as UV exposure degrades materials.
Proper inspection and replacement of hard hats when recommended is essential to getting full and ongoing protection according to specifications. Workers should check for the manufacture date inside their hard hats and ask for replacements as needed.
Training on Hard Hat Use
To comply with OSHA standards, employers must train all workers on proper use, care and limitations of hard hats including:
- When head protection is required
- Selecting the right type of hard hat for hazards present
- Inspecting hard hats and identifying damage or defects
- Properly adjusting and wearing hard hats
- Cleaning and maintaining hard hats
- Recognizing the need to replace a hard hat
- Limitations of hard hats in protecting against electrical hazards
- Warnings and restrictions on applying paint or decals to hard hats
Training should be provided at hire, during orientation or when job tasks change. Regular refreshers should also be conducted such as during toolbox talks or safety meetings. Documentation of hard hat training should be kept on file.
OSHA Inspections and Penalties
Failure to comply with OSHA head protection standards can result in citations and penalties during agency inspections. Some common violations related to hard hats that OSHA compliance officers may look for include:
- Not providing or making available suitable hard hats for workers exposed to overhead or falling object hazards.
- Allowing workers to wear baseball caps or other caps not meeting ANSI standards in lieu of hard hats.
- Insufficient policies, procedures, or training programs for head protection.
- No established system for inspecting and maintaining head protection equipment.
- Permitting the use of damaged hard hats or suspension systems.
- Failing to replace hard hats according to manufacturer’s specifications.
- Not enforcing the use of hard hats in required areas.
Depending on the nature and severity of violations related to head protection, OSHA may issue citations with fines up to $13,653 per violation. Ensuring compliance with OSHA hard hat requirements is essential to avoid enforcement actions and prevent worker injuries.
Conclusion
OSHA head protection standards mandate wearing hard hats that meet ANSI standards in construction, industrial, and other occupational settings where hazards from falling objects, electrical shock or impact exist. Employers must provide suitable hard hats, train workers on proper use and care, and enforce hard hat policies. Regular inspection and timely replacement of hard hats is also critical. Following OSHA requirements prevents unnecessary head injuries and avoids regulatory fines and penalties for non-compliance.
