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1910 135 Head Protection

By Steve Stephenson

hard hat label example

OSHA 1910.135 establishes workplace risk assessments for head injury as the employer's responsibility to conduct. Based on the risk assessment the use of hard hats may be required.

In locations where there is no potential for head injuries, head protection is not required by OSHA 1910.135. Employers may still require that hard hats be worn in those locations; or when certain activities are taking place; or that they be worn by specific employees. Finding that an area does not have a potential for head injury hazards, does not prevent the employer from requiring that hard hats be worn.

In the workplace, avoidance of head injuries through risk assessment and implementation of appropriate controls is the most important preventive measure. The use of seat belts and safety helmets is important. Where there is a risk of falling objects, netting can be rigged below the work area, warnings given for those in the vicinity, and wearing of hard hats made compulsory. However, a safety helmet will not protect an individual from serious head if anything heavy is dropped from a height.

1910.135 Employer's Requirements

It is the employer's responsibility to ensure that appropriate head protection is used by employees who are in any area where there is a potential for an injury to the head from falling objects. A hard hat that will provide protection against electrical shock must be worn by employees, if there is potential for head contact with exposed electrical conductors. In that case, the hard hat must be designed to protect against electrical shock or burns. This means aluminum hard hats are only acceptable in areas where there is no possibility of an electrical hazard.

Hard Hat Design Requirements

Hard hats must meet certain design criteria. In general, OSHA 1910.135 requires that all types of protective helmets resist penetration by objects, absorb the shock of a blow, be water-resistant, and have slow-burning properties.

1910.135 also require that the manufacturers’ instructions for adjustment and the replacement of the suspension and headband be followed. If a hard hat suspension system shows any sign of damage or deterioration, it must be replaced. The suspension must also be replaced at the time intervals specified by the manufacturer, without regard to whether there is damage or not.

OSHA does not specify the specific design requirements for protective helmets. However 1910.135(b)(1) specifies that head protection must comply with the following consensus standards, or be constructed to be at least as effective as head protection that meets the following:

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

The above ANSI standards establish the criteria for two types and three classes of protective helmets.

Types of Helmets

  • Type I - Provides protection from blows to the top only.
  • Type II – Provides protection from blows to either the top or side.

ANSI Classes of Helmets

All classes of helmets are intended to provide protection from falling objects. In addition, Class A and Class B helmets provide protection from electrical hazards.  However, be aware that the voltages given below are the test voltages, they are not intended to be an indication of the voltage protection provided by the helmet.

  • Class A Helmets must reduce:
    • the impact force of a falling object.
    • the danger resulting from accidental contact with low-voltage conductors. Helmet shells are tested at 2,200 volts.
  • Class B Helmets must reduce:
    • the impact force of impact of a falling object
    • the danger resulting from accidental contact with low-voltage conductors. Helmet shells are tested at 20,00 volts.
  • Class C Helmets:
    • must reduce the impact force of a falling object.
    • are not to provide electrical protection.

Common Questions About Hard Hats

May Adhesive Stickers be Placed on Hard Hats?

Hard hat labels and stickers are commonly used to identify the employer, and may at times be used to identify the trade, union membership, or project, as well as to provide the name of the employee using the hard hat.

Stickers and labels are allowed, if applied in accordance with the manufacturer's instructions. Painting hard hats should be avoided, because it may cause deterioration of the hard hat material.  The concerns with painting and hard hat stickers include:

  • To ensure that a hard hat is undamaged, and does not have any dents, cracks, chips, or holes resulting from impact, rough treatment, or wear, it must be regularly inspected. An excessive number of adhesive stickers, or painting, may conceal damage that would otherwise be easy to see.
  • Hard hats also provide protection against electricity. Some types of paint and decals may reduce the electrical resistance provided by the hard hat.
  • The OSHA PPE standard (1910.132) requires that PPE be “maintained in a sanitary and reliable condition.”  The ability to comply with these requirements may be hindered by excessive painting or stickers on a hard hat.

The general rule of thumb is, don't use paint on hard hats. Use labels to mark hard hats, but use labels judiciously, and with a specific purpose. Do not cover the hard hat with a multitude of labels and stickers.

May Individuals Decline to Wear Hard Hats on Religious Grounds?

In 1990 the U.S. Supreme Court ruled that the “Free Exercise clause of the First Amendment does not relieve any individual of the obligation to comply with a neutral, generally applicable regulatory law, not-withstanding the dictates of the individual's religious practices.” This meant that everyone had to wear a hard hat, when it was required for safety.

In 1993 President Clinton signed the Religious Freedom Restoration Act that defined “neutral” laws, such as those requiring hard hats, as interfering with religious freedom. As a result OSHA does not issue citations to employers who have workers who refuse to wear a hard hat for religious reasons. However, employers are responsible for:

  • Instructing employees about overhead hazards, and using other methods to protect employers, such as nets to catch falling objects.
  • When an employee refuses to wear a hard hat or other PPE, based on religious objections, the employer must report this to the OSHA regional office for monitoring purposes.

OSHA makes it the employer's responsibility to identify hazards and ensure those hazards are either eliminated, guarded, or that employees are protected by PPE. In the case of head injury hazards this usually means wearing a hard hat. Erring on the safe side, by requiring hard hats be worn everywhere except in office areas, is often the best policy.