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.

April 17, 2002

Ms. Linda Keene
Safety Coordinator
Pipe Systems Inc.
P.O. Box 420
Carthage, MO 64836

Re: §1926.100(a) and (b); hard hat protection

Dear Ms. Keene:

This is in response to your letter of November 26, 2001, and a follow-up telephone conversation with Steve Stock of my staff, requesting guidance on OSHA hard hat requirements. Your letter was delayed in reaching this office because mail addressed to the government is first sent to a facility that sanitizes it. We apologize for the delay in addressing your concerns. We have paraphrased your question as follows:

Question: According to a letter issued by OSHA on July 22, 1992, under §1926.100(a) and (b), hard hats used by employees must be worn with the bill facing forward unless the hard hat manufacturer certifies that the bill facing back meets ANSI Z89.1-1969. Does OSHA still adhere to this interpretation?

Section 1926.100(a) provides:

Employees working in areas where there is a possible danger of head injury from impact, or from flying objects, or from electrical shock and [electrical] burns, shall be protected by protective helmets.

Section 1926.100(b) provides:

Helmets for the protection of employees against impact and penetration of falling and flying objects shall meet the specifications contained in American National Standards Institute, Z89.1-1969, Safety Requirements for Industrial Head Protection.1

In the 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.



This continues to be OSHA's interpretation of this standard. Additionally, note that a manufacturer may certify that it would be acceptable to wear the hard hat with the bill to the rear when the hard hat liner is turned/reversed.

If you need additional information, please do not hesitate to contact us by fax at: U.S. Department of Labor, OSHA, [Directorate of Construction, Office of Construction Standards and Guidance], fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.


Russell B. Swanson, Director
Directorate of Construction



1The impact testing requirements of ANSI Z89.1-1986 are even more specific than the 1969 version of the standard. Since the revised standard is, in effect, more rigorous, a hard hat that meets the criteria of the revised standard also meets the §1926.100 requirement for falling and flying object protection. [back to text]