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Hard Hat Requirements

Quick Tips #241

The Occupational Safety and Health Administration (OSHA) guidelines for head protection are referenced in 29 Code of Federal Regulations (CFR) 1910.135 and 1926.100.

Danger - Hard Hat Area

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Occupational Hard Hats

29 CFR 1910.135(a)(1) states, "Each affected employee shall wear protective helmets when working in areas where there is a potential for injury to the head from falling objects." The standard also covers conditions where electrical hazards are present. 1910.135(a)(2) states, "Protective helmets designed to reduce electrical shock hazard shall be worn by each such affected employee when near exposed electrical conductors which could contact the head." "Affected Employees" are defined by OSHA as "those employees who are exposed to the hazard(s) identified as violation(s) in a citation." This definition has been added to clarify that the term, as used in this regulation, applies specifically to those employees who are put at risk by the safety or health hazard cited by the OSHA Compliance Officer.

Although the OSHA standards themselves do not identify specific occupations or applications where a hard hat is required, appendix B to subpart I part 9 lists some examples. It states "Some examples of occupations for which head protection should be routinely considered are: carpenters, electricians, lineman, mechanics and repairers, plumbers and pipe fitters, assemblers, packers, wrappers, sawyers, welders, laborers, freight handlers, timber cutting and logging, stock handlers, and warehouse laborers." The appendix also provides examples of general applications where hard hats should be worn.

Performance Criteria

The performance criteria for head protection is provided in the American National Standards Institute (ANSI) Z89.1 American National Standard for Industrial Head Protection. This Standard is incorporated in 29CFR 1910.135 and by reference in 29CFR 1910.6.

Which Consensus Standards are applicable to Hard Hat Regulations?

On September 9, 2009, OSHA issued an update to its personal protective equipment (PPE) standards. The final rule went into effect in October that year and revised the PPE sections of OSHA's general industry, shipyard employment, longshoring, and marine terminals standards regarding requirements for eye- and face-protective devices, head protection and foot protection.

The revision updated the references in these regulations to recognize the more recent editions of the applicable national consensus standards (ANSI/ISEA 789.1). It allows employers to use PPE constructed in accordance with any of three national consensus standards, the two most recent and the incorporated reference in the current standards (OSHA 1910.135).

ANSI Z89.1-1997

ANSI Z89.1-1997 separates protective hard hats into different types and classes.

“Type” is used to designate whether a hard hat provides protection strictly from blows to the top of the head (Type I) or protection from blows to both the top and sides of the head (Type II).

Under Z89.1-1997, the following three classes are recognized:

According to the ANSI/ISEA standard, hard hats must also contain user information such as instructions pertaining to sizing, care and service life guidelines.

Every hard hat conforming to the requirements of ANSI Z89.1-1997 must be appropriately marked to verify its compliance. The following information must be marked inside the hard hat:

  • The manufacturer's name or identifying mark
  • Date of Manufacture
  • The legend, "ANSI Z89.1"
  • The Type and Class Designation
  • The approximate headsize range

ANSI Z89.1-2003

ANSI published a revision to the Z89.1-1997 standard in 2003. The most significant changes from the 1997 version were made to harmonize with other national standards that test and evaluate equipment performance. In addition, many physical hard hat requirements that do not provide added user value, or that limited design or performance, were removed.

ANSI Z89.1-2009

ANSI published a revision in January of 2009. The significant changes from the 2003 version include three non-mandatory tests.

The three optional hard hat test criteria are:
Reverse donning: Hard hats marked with a "reverse donning arrow" 2can be worn frontward or backward in accordance with the manufacturer's wearing instructions. They pass all hard hat testing requirements, whether worn frontward or backward.

Lower temperature: Hard hats marked with an "LT" indicate that the hard hat meets all testing requirements of the standard when preconditioned at a temperature of -30°C (-22°F).

High visibility: Hard hats marked with an "HV" indicate that the hard hat meets all testing requirements of the standard for high visibility colors. This includes tests for chromaticity and luminescence.

Service Life

One common misconception is that hard hats have a predetermined service life - that is not the case. Both the 1986 and 1997 ANSI standards address service life under maintenance and care of the hard hat. The standards state that all hard hat components should be inspected daily for signs of dents, cracks, penetration and any damage due to impact, rough treatment or wear. Although it is not considered a "shelf life", MSA brand hard hats do have "Useful Service Life Guidelines". These guidelines suggest replacing the suspension every 12 months and the hard hat after 5 years of use. Any hard hat that fails the visual inspection should be removed from service until the problem is corrected.

In addition to everyday wear and tear, ultraviolet (UV) radiation can pose a problem for hard hats constructed of plastic materials. Damage caused by UV radiation is easy to spot: the hat will lose its glossy finish and eventually take on a chalky appearance. Further degradation could cause the shell to actually start flaking away. Once the effects of UV radiation are detected, the hard hat shell should be immediately replaced.

Commonly Asked Questions

Can I paint or put decals on my hard hat?


OSHA would consider painting or placing adhesive stickers acceptable if the manufacturer authorizes the alteration or the employer can demonstrate the reliability of the helmet is not affected by the paint or the adhesive on the stickers, and if the paint or placement of stickers would not reduce the ability to identify defects (i.e., use of see-through stickers) or other conditions that would indicate a reduced reliability.


Can I wear my hard hat backward?


Most likely. Check the hard hat for the "reverse donning arrow" 2marking. The current 2009 edition addresses the issues of reverse wearing of hard hats. The standard now provides a non-mandatory test protocol that will allow manufacturers of hard hats to test the helmet and be marked with the "reverse donning arrow" 2. This means the hard hat can be worn frontward or backward in accordance with the manufacturer's wearing instructions.


Can a cap, scarf, liner or other items for purposes of cold weather protection be worn safely with a hard hat?


OSHA recommends that employers permit only liners that are specifically designed to be compatible with the protective properties of the hard hat. They also recommend that the employer contact the hard hat manufacturer to determine if any type of liner or garment is compatible with the use of the hard hat. Further information can be found in OSHA’s Standard Interpretations Letter dated April 17, 2006.


How can I tell what size hard hat to wear?


Here is a simple chart that converts the circumference of your head into hard hat sizing.


Sizing Chart

Centimeters Inches
6-1/2 52 20-1/2
6-5/8 53 20-7/8
6-3/4 54 21-1/4
6-7/8 55 21-5/8
7 56 22
7-1/8 57 22-3/8
7-1/4 58 22-3/4
7-3/8 59 23-1/8
7-1/2 60 23-1/2
7-5/8 61 23-7/8
7-3/4 62 24-1/4
7-7/8 63 24-5/8
8 64 25
8-1/2 68 26-1/2
Note: This table is intended for sizing guidance of round head bands only and should not be construed as prohibiting larger or smaller headbands.



Quick Tips #192: Hazard Assessment Form

OSHA 29 CFR 1910.135,
Occupational Head Protection Standard

1910 Subpart I App B,
Non-mandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection.

ANSI Z89.1-2009,
American National Standard for Personal Protection—Protective Headwear for Industrial Workers

ANSI Z89.1-2003,
American National Standard for Personal Protection—Protective Headwear for Industrial Workers

ANSI Z89.1-1997,
American National Standard for Personal Protection Protective Headwear for Industrial Workers

OSHA’s Standard Interpretations Letter dated April 17, 2006.

(Rev. 2/2014)


Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at

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Please Note:
The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.

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