Protective helmet requirements

Under 1915.155(a)(1) employers must ensure affected employees wear protective helmets when there's a potential for head injury from falling objects. Employers must require helmets in any work area where tools, materials, or debris could strike an employee’s head from above or where objects may fall or be dropped onto workers.

• See the Use requirement in 1915.155(a)(1).
• Practical examples include work under scaffolds, while rigging, during overhead lifting, or during operations that may dislodge materials.

Under 1915.155(a)(2) employers must provide protective helmets specifically designed to reduce electrical shock hazards when employees could contact exposed electrical conductors that might contact the head. If the work involves a risk of electrical contact to the head (for example, working near energized bus bars or overhead live conductors), the helmet must be of a dielectric type intended to reduce that hazard.

• See the electrical-shock requirement in 1915.155(a)(2).
• Follow manufacturer guidance and applicable ANSI dielectric classifications incorporated by reference in 1915.5 when selecting helmets for electrical hazards.

Regarding 1915.155(b)(1), head protection must comply with one of the listed ANSI standards: ANSI Z89.1-2009, ANSI Z89.1-2003, or ANSI Z89.1–1997. Employers may choose helmets certified to any of those versions to meet the regulatory criteria.

• See the Criteria for protective helmets in 1915.155(b)(1) and the specific incorporated standards: ANSI Z89.1-2009, ANSI Z89.1-2003, and ANSI Z89.1-1997.
• The incorporation by reference of those standards is explained in 1915.5.

Under 1915.155(b)(2) an employer may use head protection devices that are not built exactly to the listed ANSI standards if the employer demonstrates they are at least as effective as devices constructed to one of those consensus standards. The employer must be able to document and justify why the alternative helmet provides equal or better protection.

• See the equivalence provision in 1915.155(b)(2).
• Practical steps: obtain test data or manufacturer certifications showing impact, penetration, and dielectric performance equal to the referenced ANSI standard; keep documentation available for inspection.

Under the employer-payment rule as applied to shipyard PPE, employers must provide required protective equipment like helmets at no cost to employees, except in limited situations allowed by the payment rule. Employers may use a deposit/return system only if it does not result in the employee effectively paying for PPE.

• See the protective helmet requirement in 1915.155(a) and OSHA's Employee PPE payment methods Letter of Interpretation explaining employer payment obligations for PPE in Part 1915.
• Employers may retain ownership and require return on termination, but they cannot charge employees for wear and tear caused by workplace conditions or administer deposits in a way that circumvents the requirement to provide PPE at no cost.

Under 1915.155(b)(1)(i) and 1915.5, the detailed performance and testing requirements are set by the incorporated ANSI standards (for example, ANSI Z89.1-2009). Employers must select helmets that meet the performance tests and classifications in those consensus standards.

• See the ANSI incorporation in 1915.155(b)(1)(i) and the incorporation clause in 1915.5.
• Follow the helmet manufacturer’s certification and ANSI testing (impact, penetration, electrical insulation where applicable) to confirm compliance.

Under 1915.155(a) the employer must ensure that each affected person working in areas with potential head‑injury hazards wears protective helmets; that responsibility extends to controlling safety for all people under the employer’s direction on the site, including contractors and visitors who are exposed to the same hazards.

• See the use requirement in 1915.155(a)(1).
• Employers should identify affected persons and make helmets available; when contractors bring their own employees, host employers should verify they are protected and, where necessary, provide helmets or require contractor-supplied compliant helmets.

Under 1915.155, bump caps are not acceptable in place of helmets that meet the listed consensus standards when there is a risk of injury from falling objects. Head protection must comply with the applicable ANSI standard or be shown to be at least as effective; most bump caps do not meet those impact and penetration tests.

• See the criteria in 1915.155(b)(1).
• Choose helmets certified to ANSI Z89.1 (or equivalent documentation per 1915.155(b)(2)) rather than bump caps when falling-object hazards exist.

Under 1915.155, employers should follow the requirements of the applicable ANSI standard and the helmet manufacturer's instructions for inspection and replacement; replace helmets that show cracks, dents, penetration, damaged suspension, or exposure-related degradation. Regular pre-use checks and documented periodic inspections are good practice.

• See the criteria reference in 1915.155(b)(1) (which incorporates ANSI performance and care guidance through 1915.5).
• Keep records of inspection findings and replacement actions; if in doubt about protective performance after a strike or chemical exposure, remove the helmet from service and replace it.

Under 1915.155(b)(1) employers may use helmets certified to any of the listed ANSI versions, including ANSI Z89.1–1997, ANSI Z89.1-2003, or ANSI Z89.1-2009, because those versions are specifically incorporated by reference in the rule.

• See the listed standards in 1915.155(b)(1)(i)–(iii).
• Ensure the helmet’s certification documentation or marking identifies the applicable ANSI standard/version.

Under 1915.155 an employer may allow employees to use personally owned helmets only if the helmets meet the required consensus standard or the employer can demonstrate equivalence; however, the employer remains responsible for ensuring the helmet provides the required protection. Additionally, under the employer‑payment rule, employers must provide required PPE at no cost, so relying solely on personal equipment can be problematic.

• See the use and criteria in 1915.155(a) and (b) and the PPE payment interpretation.
• If accepting personal helmets, verify compliance (ANSI marking or equivalent data) and document the employer’s acceptance decision.

Under 1915.155(b)(2) an employer should document equivalence by keeping technical test reports, manufacturer certification, or third‑party test data showing that the alternative helmet meets or exceeds ANSI performance criteria (impact, penetration, and, if applicable, dielectric tests). The documentation should be retained and available for inspection.

• See the equivalence clause in 1915.155(b)(2).
• Practical documentation: lab test reports, test protocols, comparison tables to the ANSI requirements, and a signed determination by a qualified person (e.g., competent person or safety manager).

Under 1915.155 the helmet requirement is focused on protection from head injury due to falling objects and electrical shock hazards; protection from intense radiant energy (such as welding arc radiation) typically requires eye/face protection and welding helmets specified in other standards (for example, 29 CFR 1915.153 for eye and face protection). For arc welding or cutting hazards, use equipment designed for those radiation risks.

• See the head-protection use in 1915.155(a) and the separate shipyard eye/face protection requirements in 29 CFR 1915.153 (see related guidance in OSHA's Letter on shipyard eye and face protection: https://www.osha.gov/laws-regs/standardinterpretations/2019-12-30).
• Use the appropriate protective device for the specific hazard (welding helmet for arc radiation; ANSI hard hat for impact).

Under 1915.155 and shipyard competent‑person guidance, the employer (through a competent person) is responsible for recognizing hazards and specifying the necessary head protection when the standard does not state the exact device. The competent person should evaluate the hazard and select helmets that meet 1915.155 criteria or demonstrate equivalent protection.

• See the use and criteria in 1915.155(a) and (b) and OSHA's competent person Letter of Interpretation describing that a competent person is capable of specifying necessary protection.
• Document the hazard assessment and the competent person's determination.

Under 1915.155 helmets may be painted or labeled only if such modifications do not compromise the helmet’s protective performance; covering or modifying the shell in ways that degrade impact or dielectric properties can void the helmet’s compliance. Employers should follow the helmet manufacturer's guidance and ANSI cautions about paints or adhesives.

• See the standards reference in 1915.155(b)(1) and the incorporation in 1915.5.
• When in doubt, consult the manufacturer or replace the helmet; document any manufacturer approval for permitted markings or coatings.

Under 1915.155 employers must select helmets that meet an applicable ANSI standard; ANSI Z89.1 uses classes and types (for example, electrical Class G or E and Type I or II) to indicate protection levels, so employers should choose the class/type appropriate to the hazards present (impact direction, electrical exposure).

• See the criteria referencing ANSI in 1915.155(b)(1).
• For example, choose a dielectric (Class G or E) helmet when electrical contact is a potential hazard per 1915.155(a)(2). Rely on ANSI markings and manufacturer data to confirm the helmet’s class and type.

Under 1915.155 employers should remove a helmet from service immediately if it has been struck by a heavy object, inspected for damage, and replaced if there is any sign of cracking, deformation, or compromised suspension; do not return a helmet to service without confirming it still meets the required protective performance.

• See the criteria in 1915.155(b)(1) and the incorporated ANSI guidance (via 1915.5) advising removal after a significant impact.
• Keep a replacement helmet available and document the incident and replacement decision.

Under 1915.155 employers must ensure helmets continue to provide required protection; if chemicals may degrade the helmet shell or suspension, the employer should remove affected helmets from service and replace them, and choose helmet materials or models resistant to those chemicals. Document the evaluation and replacement.

• See the head-protection criteria in 1915.155(b)(1) and rely on manufacturer/ANSI guidance for chemical compatibility (incorporated via 1915.5).
• A competent person should assess chemical exposure and specify helmets suitable for the environment (see OSHA competent‑person guidance at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

Under 1915.155 compliant helmets should display the manufacturer’s identification and the ANSI standard/version marking (for example, Z89.1-2009), and employers should retain any manufacturer certification or test data for alternative helmets shown to be equivalent. These markings and documents demonstrate the helmet meets the consensus standard or the employer’s equivalence determination.

• See the criteria in 1915.155(b)(1) and the incorporation reference in 1915.5.
• For non‑ANSI helmets used under 1915.155(b)(2), keep written test reports and the employer’s rationale available for inspection.