OSHA Hard Hat Compliance: A Guide to the ANSI Z89.1 ...

Simplifying construction industry regulations—and how to choose the right hard hat for your workplace

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With construction workers facing the highest occupational risk of traumatic brain injuries (TBIs), hard hats are a critical piece of equipment on the job site. But what safety standards matter most—and how do you know that the construction helmet you choose offers appropriate protection?

Construction sites can be notoriously dangerous places, even when proper safety protocols are followed. From falls off a roof to collisions with exposed beams to getting struck by moving vehicles, the risk of head injury looms large.

During a seven-year study, the American Journal of Industrial Medicine found 2.6 fatal TBIs per 100,000 construction workers every year—more than triple the average rate across all other industries. That represents 1 in 4 construction-related deaths and nearly 1 in 4 of all occupational TBI fatalities.

Even mild TBIs can have life-long effects, impacting cognitive function, movement coordination, social behavior, and overall quality of life.

The right industrial helmets—commonly known as hard hats—can protect construction crews from falling debris, low-hanging objects, contact with electrical hazards, splashes, high heat, exposure to ultraviolet light, and more. A National Institutes of Health (NIH) report asserts that hard hats complying with American National Standards Institute (ANSI) guidance can reduce head acceleration by as much as 95% after impacts from large falling objects.

In this blog, we explain:

• The American National Standards Institute’s (ANSI) American National Standard for Industrial Head Protection (ANSI/ISEA Z89.1-2014), which ensures the quality and safety of construction helmets.

• When hard hats are required by the Occupational Safety and Health Administration (OSHA) and the role of the ANSI hard hat standard.

• How to determine with a glance if a helmet is compliant.

• We will also show the stiff penalties employers may face for non-compliance—including potential jail time.

Most important, we’ll help you determine the right level of hard hat protection for your needs.

OSHA codes and ANSI hard hat standards: What rules must the construction industry follow?

For a relatively small piece of personal protective equipment (PPE), construction hard hats have an immense responsibility for protecting workers:

• Deflecting blows to the head
• Resisting penetration
• Absorbing the force of impacts via a suspension system
• Preventing top-of-the-head impacts from traveling down the spine
• Insulating against electric shocks, when needed
• Providing water resistance
• Being fire-resistant

Before OSHA was formed in 1970, construction companies maintained their own requirements for protective gear. Now, Title 29 of the Code of Federal Regulations (29 CFR aka CFR Title 29) mandates specific rules for head protection that aim to create a work environment safe from known dangers or hazards:

• OSHA 29 CFR 1910.135 governs safety helmet requirements for general industry workers.

• OSHA 29 CFR 1926.100 governs head protection requirements for construction, demolition, and renovation workers.

As with many of its standards, OSHA mandates that construction companies follow the guidelines set forth by the American National Standards Institute to achieve compliance with head protection regulations. In other words, OSHA establishes the rules construction companies must follow, and ANSI Z89.1 details specific steps needed to comply.

The 2014 version of the American National Standard for Industrial Head Protection (ANSI Z89.1-2014) details the most updated performance and testing requirements for construction helmets, considering improvements in technology, testing methods, materials, worker needs, and the use and application of products. The ANSI standard also establishes types and classifications for protective classes based on potential hazards, helping employers and users select hard hats that meet specific workplace needs.

The latest ANSI edition revised 2009 regulations. It was prepared by members of the Industrial Safety Equipment Association’s (ISEA's) Head Protection Group and approved by a consensus review panel of users, government agencies, and safety experts.

Key updates to the latest edition include:

• Requiring manufacturers to provide proof that accessories and replacement components won’t cause helmets to fail
• Clarification that useful service life doesn’t need to be explained by a set number of years
• Additional protections for users who work in hotter environments.

OSHA regulations also permit workers to use hard hats that adhere to 2009, 2003, or 1997 ANSI editions, however. They even allow construction helmets that don’t follow ANSI requirements as long as employers can demonstrate equal or better protection.

But keep this in mind: if a job exposes workers to hazards only addressed by the 2014 edition, older products may not comply. For instance, there are new, optional rules for preconditioning hard hats for testing at higher temperatures. These additions make sure the equipment performs in more extreme environments.

It’s also important to note that neither OSHA nor ANSI approves bump caps, which are designed to help wearers avoid bruises, scrapes, and abrasions caused by minor impacts with stationary objects. Bump caps are unsuitable for protection against falling or moving items. They are never intended for use when job site hazards demand ANSI Z89.1 hard hats.

When are OSHA hard hats required on construction sites?

OSHA regulations require construction workers to wear hard hats when they are exposed to the following potential hazards:

• Objects may fall from overhead
• Potential head contact with electrical hazards
• Stationary objects like exposed beams and pipes risk head collisions

OSHA places responsibility squarely on employers’ shoulders for not only providing ANSI-compliant head protection but for ensuring employees wear it. Penalties for non-compliance can be severe: fines of up to $13,653 per violation for “serious” infractions, meaning employers knew about an existing risk that could impact health or safety but did little to correct it.

Failing to remedy the situation after receiving a citation can trigger daily fines. And “willful” violations—issued for intentionally ignoring OSHA standards—can lead to criminal penalties that include possible jail time if an employee is killed.

Even so, data from the U.S. Bureau of Labor Statistics found that only 16% of construction workers who suffered a head injury wore hard hats—despite regulations requiring protection for more than twice that number.

Other countries follow their own hard hat standards, like Canada’s CSA Z94.1-15 and Europe’s EN 397:2012 + A1:2012 and EN 50365:2002. The various challenges standards committees face in each geographic region make it unlikely that a global standard will be created any time soon.

For instance, the Canadian standard is similar to ANSI Z89.1, with the most apparent differences stemming from testing requirements. But approval from one organization doesn’t guarantee compliance with the other.

Always make sure your hard hat is labeled and certified for the right location!

Falls from a significant height represent a leading cause of traumatic brain injuries in construction workers.

How do I choose the right hard hat for my workplace?

As of 2023, if a hard hat meets ANSI Z89.1 for the specific hazardous conditions on the jobsite, it is OSHA-compliant. But what exactly does this mean? You will hear of many new jobsites in the USA requiring climbing or European style hard hats.

What this really means is that many job sites are starting to require a type II hard hat that may include a chin-strap. This doesn't mean though you have to wear that style of hard hat. There are plenty of Type II hardhats on the market, including our soon to launch Kevy hard hat that meets these requirements and doesn't look like a climbing helmet.

Hard Hat Types: Understanding the Differences

ANSI Z89.1-2014 (Chapter 4: Types and Classes) establishes two types of protective safety helmets. In this case, “type” doesn’t mean “style,” such as cap or full-brim models. It is a very specific designation that refers to impact and penetration protection.

• A Type I hard hat cushions blows to the crown or top of the head. While no headgear can fully protect wearers from severe impacts or penetrations, ANSI Z89.1 hard hats deliver assurance that you’re protected from tools, small parts, or similar items falling from a reasonable height—or if you stand up under an obstruction and whack your head.

• A Type II hard hat reduces the impact from top-of-the-head blows and protects wearers from front, back, and side impacts. This is necessary when working around moving equipment or materials that create a persistent threat of horizontal blows.

Hard Hat Classes: Electrical Protection Explained

To further improve safety, ANSI also classifies hard hats by their ability to withstand electrical shock. In the past, ANSI’s electrical class designations were A, B, and C, with B offering the greatest protection.

The current labeling system is more intuitive for choosing the right model:

• Class G (General) includes all-purpose, general construction helmets providing good impact and penetration protection and limited voltage protection. These hard hats are tested up to 2,200 volts and can be appropriate for general construction work.

• Class E (Electrical) hard hats are tested up to 20,000 volts, protecting from high-voltage shock. They are well-suited for electrical work where users are regularly exposed to high-voltage environments. They also provide good impact and penetration protection.
• Class C (Conductive) hard hats are not intended to protect wearers from contact with electrical conductors. While they provide good impact and penetration protection, they should only be used by construction workers with no risk of encountering electrical hazards. Conductive materials can also offer more breathability.

ANSI-approved Class E hard hats can protect wearers from high-voltage shocks.

ANSI further sets requirements that must be met to achieve compliance with optional hard hat features, including:

• Low-temperature applications
• High-temperature applications
• High visibility
• Reverse donning (wearing the helmet backward or forward)

Is Your Hard Hat OSHA and ANSI Compliant?

Determining if a construction helmet is ANSI-approved is easy—just sneak a peek inside the shell. In Chapter 6: Instructions and Marking, ANSI requires permanent labels or markings inside certified models. This information must include the following safety facts in 0.06” (1.5 mm) letters:

• Manufacturer’s name or identification mark
• Date of manufacture
• Applicable ANSI standard (for instance, Z89.1-2014)
• ANSI type (I or II)
• ANSI class designation (G, E, or C)
• Approximate head size range for fitting
• Markings to indicate compliance with ANSI requirements for any optional hard hat features: "LT" for low-temperature rating, "HT" for high-temperature rating, "HV" for high visibility, and two arrows curving to form a circle for reverse wear.

If the certification markings are missing or no longer legible, replacing the hard hat as soon as possible is recommended.

ANSI also requires every hard hat to come with manufacturer’s instructions that explain proper use, the appropriate method of size adjustment and fitting, and guidelines for care and useful life. The 2014 edition clarifies that ANSI does not require manufacturers to define useful life in years; instead, it wants users to understand that conditions like extended sunlight exposure or chemicals could impact protection over time.

When this mark appears on the inside of your hard hat, it meets ANSI requirements for safe backward or forward wear.

ANSI testing requirements ensure hard hats provide robust head protection to construction workers

Before ANSI certifies that any type or class of hard hat offers adequate head protection, it must pass these rigorous performance tests detailed in Chapter 10: Test Methods:

• Flammability — hard hats must be able to resist fire damage.
• Force transmission — construction helmets must be able to reduce the force of an impact from a falling object to the top of a wearer’s head, even at high and low temperatures.
• Apex penetration — headgear must resist penetration, even at high and low temperatures.
• Electrical insulation, when applicable — helmets must withstand exposure to specific amounts of electricity without catching fire while allowing only a marginal amount of electricity to seep through.

Additional tests are required for Type II hard hats. ANSI also details tests for optional features like high-visibility and reverse-wear models that manufacturers can choose to perform.

Construction helmet manufacturers are responsible for ensuring their products are tested to ANSI standards. They typically send samples to independent laboratories that use specialized machines to evaluate performance according to ANSI specifications.

ANSI requires a minimum of 30 samples for the following schedule of performance tests, with anywhere from one to 24 hard hats utilized per test. If optional reverse-donning tests are also performed, a minimum of 36 samples must be used.

ANSI provides this rigorous testing schedule for certifying hard hats as Type I or Type II. It also includes testing for optional features. Table source: ANSI Z89.1-2014

Here’s an overview of what hard hat testing entails—be sure to refer to ANSI Z89.1-2014 for complete details:

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ANSI Testing Requirements for Type I and II Construction Helmets

1. Flammability: Ensuring Fire Resistance

Essentially, this test is performed by applying a Bunsen burner flame to a chosen test point on a hard hat for about five seconds. Five seconds after the flame is removed, testers inspect the sample.

The hard hat fails the flammability test if it shows any sign of visible flame five seconds after the Bunsen burner is removed.

2. Force Transmission: Impact Force Absorption

Testing is conducted on hard hats preconditioned to the following environments:

• Hot temperatures: At least 12 test samples are placed in a forced air circulating oven maintained at about 49°C (120°F) for at least two hours. Optional higher temperature testing can also be performed on test samples conditioned to approximately 60°C (140°F) for at least four hours.

• Cold temperatures: At least 12 test samples are placed in a freezer maintained at about 18°C (0°F) for at least two hours. Optional lower temperature testing can also be performed on test samples conditioned to about –30°C (-22°F) for at least four hours.

Test samples are removed from the conditioning environment one at a time and placed on a headform (a specialized dummy head). An impactor (such as an anvil or steel ball) with a mass of about 8 lbs. (3.6 kg) and a spherical striking face with a radius of about 1.9” (48 mm) is dropped from a height that yields an impact velocity of about 18 ft/s (5.50 m/s).

Individual maximum force readings and impact velocities for all test samples are recorded. The average for each group of preconditioned hard hats is also calculated and recorded.

Construction helmets must not transmit a force to