Head protection requirements

Employers must ensure employees wear protective helmets whenever they work where there is a potential for head injury from falling objects. The rule at 1910.135(a)(1) explicitly requires helmets in areas with that hazard.

• Examples include work under suspended loads, below overhead operations, and areas where tools or materials might fall.
• Employers should identify affected employees through a workplace hazard assessment and provide helmets when the hazard exists; see the related interpretation about crane operations that applies this requirement to lifting work and similar overhead hazards at Head protection for crane operators.

A helmet designed to reduce electrical shock hazards is required when employees are near exposed electrical conductors that could contact the head. Section 1910.135(a)(2) mandates helmets that reduce electrical shock hazard in those situations.

• Use helmets rated for electrical protection (dielectric/insulating properties) consistent with the applicable ANSI consensus standard cited in 1910.135(b)(1).
• When in doubt, select helmets specified by the manufacturer for electrical work and document the basis for your choice.

Head protection must comply with one of the ANSI Z89.1 consensus standards listed in the regulation. Specifically, 1910.135(b)(1) references American National Standards Institute (ANSI) Z89.1-2009, ANSI Z89.1-2003, or ANSI Z89.1-1997 as acceptable standards.

• Employers may choose helmets certified to any one of these ANSI versions; the standard is incorporated by reference in 1910.6.
• When selecting helmets for electrical work, choose the appropriate ANSI electrical class (e.g., Class E for electrical insulation) per the ANSI standard referenced in 1910.135(b)(1).

Yes — an employer can use non-ANSI head protection if they demonstrate it is at least as effective as protection constructed according to one of the listed ANSI standards. 1910.135(b)(2) says devices shown to be at least as effective will be deemed in compliance.

• To support equivalency, keep documentation such as test reports, manufacturer certification, or engineering analyses comparing impact and electrical performance to ANSI requirements.
• If challenged in enforcement, you should be able to produce the evidence that shows the alternative device provides equivalent protection.

If a crane operator is exposed to an overhead hazard that could strike the head, the employer must provide and require a protective helmet. OSHA's head protection standard 1910.135(a)(1) applies when there is potential for injury from falling objects, and the OSHA interpretation Head protection for crane operators specifically explains this requirement for crane operations.

• The employer must assess the work area and, if overhead hazards exist (for example, lifting loads), provide helmets that meet the consensus standards in 1910.135(b)(1).
• Employers should also follow crane operation rules that minimize carrying loads over people, as noted in the OSHA interpretation.

Bump caps are generally not acceptable as substitutes for protective helmets required for protection from falling objects because they normally do not meet the ANSI Z89.1 impact-protection requirements referenced in 1910.135(b)(1).

• If an employer wants to use a non-ANSI device, they must demonstrate it is at least as effective under 1910.135(b)(2).
• For typical falling-object hazards, select helmets that explicitly meet the ANSI listed in 1910.135(b)(1) rather than bump caps.

No. OSHA's head protection standard does not require specific helmet colors; it requires protective helmets when hazards exist but does not mandate color coding. The requirements are set out in 1910.135(a) and the criteria for head protection are in 1910.135(b).

• Employers may use color-coding as a safety practice or for identification, but color choices are a management decision unless a specific program or state rule requires otherwise.
• Regardless of color, helmets must meet the applicable ANSI requirements cited in 1910.135(b)(1).

Yes — a hard hat should be removed from service and replaced after a significant impact or when it shows damage that could reduce protection. While 1910.135(b)(1) references ANSI standards for head protection, ANSI guidance and manufacturers recommend replacing helmets after a substantial blow or when damaged.

• Keep and follow the helmet manufacturer's replacement guidance and the ANSI recommendations tied to the ANSI editions listed in 1910.135(b)(1).
• Document your inspection and replacement program to show compliance with the employer's duty to provide effective protection under 1910.135.

An "affected employee" is any employee exposed to head injury hazards such as falling objects or contact with exposed electrical conductors and must be provided head protection under 1910.135(a).

• This includes workers, and can include visitors or contractors performing tasks in areas with those hazards; employers must ensure anyone exposed is protected.
• The employer should document hazard assessments and the steps taken to provide helmets to affected employees, per the requirement to ensure protection under 1910.135(a)(1).

If the crane operator could be exposed to an overhead hazard that could strike the head, the employer must provide and require a helmet; being in a cab does not automatically remove the requirement. OSHA's head protection standard 1910.135(a)(1) and the interpretation Head protection for crane operators explain that operators who can be in the vicinity of falling hazards need head protection.

• The employer must assess whether the cab provides adequate protection; if not, require a helmet that meets the ANSI criteria in 1910.135(b)(1).
• Employers should also follow operating rules that minimize carrying loads over people, as noted in the OSHA interpretation.

The employer should keep clear, written evidence showing the alternative device provides protection at least equivalent to the ANSI standards listed in 1910.135(b)(1). 1910.135(b)(2) requires demonstration of equivalence.

• Useful documentation includes independent laboratory test reports, manufacturer certifications comparing performance to ANSI test criteria, engineering analyses, and any relevant certificates.
• Keep these records available for review during inspections or after incidents to support the equivalency claim.

Employers must ensure any person exposed to head injury hazards in the workplace — employees or visitors — is provided appropriate protective helmets. 1910.135(a)(1) requires protection for affected persons, not just employees.

• Practical steps include offering rental or site-issued helmets to visitors, contractors, and vendors before they enter hazardous areas.
• Document visitor protection procedures so you can show how the employer meets the duty to protect all people exposed to head hazards.

Yes — an employer may require helmets at all times on a jobsite as a safety policy, even when specific hazards are not present. 1910.135(a)(1) sets minimum requirements; employers may adopt stricter rules.

• Requiring helmets consistently can simplify compliance and help prevent accidental exposures when conditions change.
• If stricter internal rules are adopted, ensure helmets still meet the ANSI criteria in 1910.135(b)(1).

OSHA's head protection standard does not generally require chin straps, but an employer can require them when necessary to ensure the helmet provides protection. 1910.135 sets the protection requirement but does not prescribe chin straps.

• Use chin straps when the work (for example, working under suspended loads or in windy conditions) would otherwise allow a helmet to be dislodged, and document the decision in your hazard assessment.
• Any accessory used should not reduce the helmet's protective performance and should be compatible with the ANSI requirements referenced in 1910.135(b)(1).

While 1910.135 focuses on supplying compliant head protection, employers are responsible for ensuring protective equipment is used properly and effectively, which includes training on fit, care, and limitations. The head protection criteria are in 1910.135(b), and training aligns with the employer's overall duty to provide protection.

• Training topics should include when helmets are required, correct fit and adjustment, inspection and replacement criteria, and restrictions (e.g., do not paint or modify helmets unless permitted by the manufacturer).
• Keep training records to show your program ensures workers use head protection in compliance with 1910.135.

Yes — if there is a potential for head injury from bumping into fixed objects, employers must provide protective helmets to affected employees. 1910.135(a)(1) requires protection when there is potential for head injury; that potential includes striking fixed objects.

• Evaluate the workplace for low clearances, protruding equipment, or confined-space hazards and provide helmets where needed.
• Ensure the chosen helmets meet the ANSI criteria in 1910.135(b)(1).

No — administrative controls like signs alone are not an acceptable substitute when there is a real potential for head injury; employers must provide and require protective helmets where hazards exist. 1910.135(a)(1) requires helmets in areas with potential for head injury.

• Administrative controls can supplement protection but should not replace personal protective equipment when direct hazards exist.
• The employer should implement engineering, administrative, and PPE measures as needed and document the hazard assessment and controls used to protect workers.

Face shields alone are not an acceptable substitute for protective helmets required for falling-object hazards because they do not provide equivalent impact protection to ANSI Z89.1-compliant helmets referenced in 1910.135(b)(1).

• Face shields can be used along with helmets when additional face protection is needed, but do not replace the helmet itself.
• If claiming an alternative provides equivalent protection, the employer must demonstrate equivalency under 1910.135(b)(2).

Yes — employers must prevent or minimize carrying loads over people as part of controlling the hazard that triggers the helmet requirement. The OSHA interpretation Head protection for crane operators notes that in addition to providing helmets under 1910.135(a)(1), employers should follow crane operation practices that avoid carrying loads over people.

• Combining hazard controls (safe lifting practices, exclusion zones, and helmets) provides better protection than PPE alone.
• Document procedures and training that prevent carrying loads over people and show how you protect affected employees.

Yes — helmets marked as compliant with ANSI Z89.1-2009, ANSI Z89.1-2003, or ANSI Z89.1-1997 are accepted under 1910.135(b)(1) and do not require additional OSHA testing.

• Keep purchase records or manufacturer certification that the helmets meet the cited ANSI edition.
• If you select a helmet not marked to those standards, be prepared to demonstrate equivalency under 1910.135(b)(2).

No — the regulation allows helmets that comply with any of the listed ANSI editions (2009, 2003, or 1997) referenced in 1910.135(b)(1). Employers may adopt internal policies limiting acceptable editions, but OSHA accepts any of the three listed editions as compliant.

• If you choose to accept only a later edition for safety reasons, document the rationale in your safety program.
• Alternatives not meeting those editions must be demonstrated equivalent under 1910.135(b)(2).