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 https://www.osha.gov.

June 14, 1977

Mr. M. L. Stockwell
Sales Manager
American Allsafe Co., Inc.
1245 Niagara Street
Buffalo, New York 14213

Dear Mr. Stockwell:

This is to acknowledge the receipt of your letter dated April 22, 1977.

We feel the information contained therein is beneficial and express our appreciation for your effort in making the information available to us.

From earlier conversations you are aware that Dr. Donald L. Campbell, Safety Equipment Section, Testing and Certification Branch, NIOSH, Morgantown, West Virginia, planned to test the WindGard. His recent communication to us on the results of the tests stated that:


1. the liner, when wet and worn over the outside edge of the helmet totally negates the insulation properties of both Class A and Class B helmets, and these helmets must then be considered Class C helmets, and


2. the liner must be worn under the helmet, if dielectric protection is required.

It is also mentioned that the liner must not be worn or stored in such a way as to reduce the apex clearance between the shell and suspension since such a reduction will reduce the level of crown impact protection offered by the helmet. I hope this information will be helpful to you. A copy of your letter dated April 22, 1977, was sent to Dr. Campbell for his information.

Should you have any questions on, this matter, please feel free to contact us.


John K. Barto,
Division of Occupational Safety Programming