Is OSHA changing the Personal Protection Equipment (PPE) regulation requiring chin straps on hard hats? This was asked by Carly from Don Brandel Plumbing and it’s probably a question that many contractors are concerned about.
According to California Code of Regulations Section 3381 Head Protection (Federal Regulations are similar), “Employees working in locations where there is a risk of receiving head injuries from flying or falling objects and/or electric shock and burns shall wear approved head protection in accordance with this section.”
In addition, it states:
When head protection is required, the employer shall provide each employee with head protection that meets the criteria in one of the following standards, which are hereby incorporated by reference:
(1) American National Standards Institute (ANSI)/International Safety Equipment Association (ISEA) Z89.1-2009, “American National Standard for Industrial Head Protection;”
(2) ANSI Z89.1-2003, “American National Standard for Industrial Head Protection;” or
(3) ANSI Z89.1-1997, “American National Standard for Industrial Head Protection.”
The employer shall ensure that the appropriate impact type helmet is selected and used.”
Head protection should not only absorb the impact of blows to the head, but also serve as insulators against electric shock, be water resistant, slow burning, and shield the scalp, face, neck, and shoulders. ANSI Z89.1 requires helmets to go through rigorous testing to ensure that they will withstand these hazards.
The short answer to your question is that there is no proposed change to the federal OSHA standard or to Cal-OSHA’S regulations requiring hard hats with chin straps.
The push for the change to safety helmets with a chin strap comes from the larger General Contractors. Clark Construction was one of the early pioneers of this movement, providing helmets with chin straps to their employees in 2017.
The main purpose of both types of helmets is to protect against traumatic brain injuries (TMI). Most TMIs occur due to employees not wearing their hard hats. Since the chin strap will make it more difficult to remove the hard hat, we may see a reduction in the number of TMIs, simply due to the fact that the helmet is being worn.
Hard hats are identified by Type and Class.
Impact protection is shown by Type. Type 1 provides protection from a blow to the top of the head. Type II provides protection not only from a blow from above but also from a side-impact.
The Class describes the electrical protection provided by the hard hat and there are three classes; E, G, and C.
-Class E (Electrical) Hard Hats provide electrical protection up to 20, 000 volts.
-Class G (General) Hard Hats provide electrical protection up to 2,200 volts.
Class C (Conductive) Hard Hats do not provide any electrical protection.
Currently, the most common types of Hard Hat worn in construction are Type 1, either “G” or “E”.
The biggest drawback to these new helmets is the cost.
The current hard hats that provide this level of protection can be purchased for about 10 bucks.
The least expensive helmets with chin straps are Type 1 Class C and they start around $30; while a Type 1 Class E Hard Hat runs upwards of $100.
By paying $30 you’ll get a chin strap with no electrical protection, or pay $10 for a hard hat with no electrical protection at all, but it has a chin strap.
Usually, hard hats/safety helmets with vents don’t provide electrical protection.
My opinion is that General Contractors set the tone for safety. We see GC’s implementing rules all the time that are more stringent than the underlying OSHA regulations and that’s what will probably happen here.
I wouldn’t be surprised to see helmets with chin straps required on jobs in the near future-even without an OSHA regulation.
PROPOSED CHANGE TO PPE.
Fed OSHA is updating the Construction PPE regulation, however. The current standard does not state clearly that PPE must fit each affected employee properly. The proposed change would clarify that PPE must fit each employee properly to protect them from occupational hazards.
The failure of standard-sized PPE to protect physically smaller construction workers properly, as well as problems with access to properly fitting PPE, have long been safety and health concerns in the construction industry, especially for some women. The proposed rule clarifies the existing requirement, and OSHA does not expect the change will increase employers’ costs or compliance burdens.
If you have a safety question, let me know at [email protected].
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