May 9, 2011
Mr. Raymond Horn
6996 Deerfield Road
Bartlett, Tennessee 38135
Dear Mr. Horn:
Thank you for your October 3, 2007, letter to the Occupational Safety and Health Administration (OSHA). Because it involves construction issues, it has been forwarded to the Directorate of Construction for response. We apologize for the delay in our reply. You have a specific question regarding OSHA hard hat requirements. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any question not delineated in your original correspondence.
Question: There is a brand of hard hat that comes packaged, and is issued to employees, with the bill facing to the rear. The hard hats are labeled as meeting ANSI Z89.1-2003 standards for Type 1, Class C helmets. Is it permissible to use such a hard hat with the bill facing to the rear?
Response: Yes. Hard hats are required where "there is a possible danger of head injury from impact, or from falling or flying objects, or from electrical shock and burns" under 29 CFR 1926.100(a). According to 29 CFR 1926.100(b), hard hats must meet the specifications outlined in American National Standards Institute (ANSI), Z89.1-1969, Safety Requirements for Industrial Head Protection.
Although the ANSI Z89.1-1969 standard gives specifications for testing the hard hats with the bill to the front but not the rear, OSHA issued a letter of interpretation1 in 1992 allowing the use of hard hats worn with the bill to the rear, so long as the manufacturer certifies that their tests meet ANSI Z89.1-1969 requirements. OSHA maintains this position. It is worth noting, however, that the 2009 version of the ANSI Z89.1 standard contains provisions for testing a hard hat with the bill to the rear.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.
James G. Maddux, Director
Directorate of Construction
1 In a July 22, 1992, letter to Mr. Artie Scruggs, OSHA stated, "ANSI only tests and certifies hard hats to be worn with the bill forward; hard hats worn with the bill to the rear would not be considered reliable protection and would not meet the requirements of 29 CFR 1926.100(a) and (b) unless the hard hat manufacturer certifies that this practice meets the ANSI Z89.1-1969 requirements." OSHA affirmed this decision in an April 17, 2002 letter to Ms. Linda Keene. [Return to Text]