Head protection requirements

Employees must wear protective helmets when working in areas where there is a potential for injury to the head from falling objects. This is the specific requirement in 1917.93(a); employers must identify such areas and ensure affected employees wear helmets.

• See the full head protection rule at 1917.93 for context.

Head protection must comply with any one of the ANSI standards listed in the rule: ANSI Z89.1-2009, ANSI Z89.1-2003, or ANSI Z89.1-1997. The regulation lists these options explicitly in 1917.93(b)(1)(i), 1917.93(b)(1)(ii), and 1917.93(b)(1)(iii).

• See 1917.93(b) for the list and placement in the standard.

Yes—an employer may use head protection not built to those ANSI versions if the employer can demonstrate the device is at least as effective as devices constructed to one of the listed consensus standards. That allowance is in 1917.93(b)(2).

• The standard places the burden on the employer to demonstrate equivalence; the rule itself does not prescribe the exact form of that demonstration, so employers should retain documentation (test data, manufacturer statements, or third-party certification) showing equal or better protection.

The employer must clean and disinfect any protective hat that was previously worn before issuing it to another employee. This requirement is stated directly in 1917.93(c).

• Employers should follow manufacturer cleaning instructions or established disinfecting procedures to ensure effective cleaning and to avoid damaging the helmet.

Yes—when the employer requires head protection under the standard, the employer generally must provide the protective helmets at no cost to employees. OSHA's final rule on employer payment for PPE applies to Part 1917 and requires employers to pay for PPE they require, with limited exceptions; see OSHA's interpretation on employee PPE payment methods at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 and the head protection rule at 1917.93.

• The 2014 interpretation explains that employers may retain ownership of PPE and may require return on termination, and may use deposit systems that do not result in an involuntary cost to the employee.
• Employers may not charge employees for wear and tear to PPE that is related to the work performed or workplace conditions.

Yes—an employer may require a deposit for PPE if the employer retains ownership of the equipment, but the deposit system must not result in the employee involuntarily paying for PPE required by the employer. OSHA's guidance on employer PPE payment methods explains this approach and cautions against systems that circumvent the payment rule; see https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 and 1917.93.

• A written agreement clarifying expectations is an effective method, and employers must not charge employees for work-related wear and tear.

Only head protection that meets one of the listed consensus standards or that the employer demonstrates is at least as effective will be deemed compliant. Therefore, a bump cap or soft head covering is compliant only if it meets the ANSI standards listed in 1917.93(b)(1) or the employer can demonstrate equivalent protection under 1917.93(b)(2).

• Many bump caps do not meet ANSI Z89.1 impact standards; check manufacturer certification or test data before relying on them for compliance.

Yes—an employer may reissue previously worn helmets to other employees provided they are cleaned and disinfected prior to reissuance as required by 1917.93(c).

• Employers should inspect reissued helmets for damage or degradation and follow manufacturer guidance to ensure the helmet still provides required protection.

The employer bears the burden of demonstrating that the alternative head protection device is at least as effective as devices constructed to one of the listed consensus standards. That employer responsibility is set out in 1917.93(b)(2).

• While the standard does not prescribe a specific method, reasonable documentation such as laboratory test reports, third-party certifications, or detailed manufacturer engineering data is appropriate to retain as proof of equivalence.

Employers may take reasonable steps to retrieve employer-owned PPE and may require payment for employer-owned PPE not returned at termination, but they may not charge employees for wear and tear related to work; see OSHA's PPE payment guidance at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 and the head protection rule 1917.93.

• If the PPE was employer-owned and lost, the employer's actions must comply with federal, state, and local pay-deduction laws and must not effectively force an employee to pay for required PPE.

Possibly not—Part 1917's specific requirements, including those in 1917.93, may not apply to a facility that meets the regulatory definition of a "designated waterfront facility." OSHA's interpretation about applicability to designated waterfront facilities explains that certain Part 1917 requirements do not apply in that situation; see https://www.osha.gov/laws-regs/standardinterpretations/2017-05-31.

• Employers operating at a designated waterfront facility should confirm which OSHA part governs their operations and which specific standards apply.

Modifying a helmet can affect its compliance because 1917.93(b) requires that head protection meet the listed standards or be demonstrated equivalent; any modification that alters protective performance may make the helmet noncompliant. Employers must ensure that any accessory or modification does not reduce protective capability and should document manufacturer approval or testing showing continued compliance.

• When in doubt, obtain written manufacturer approval or third-party testing to verify that the modified helmet remains at least as effective as an ANSI-certified device.

The standard requires cleaning and disinfecting previously worn protective hats before issuing them to another employee (1917.93(c)), but it does not specify recordkeeping for that cleaning; however, keeping simple documentation of cleaning and inspection is a prudent compliance and hygiene practice.

• Employers should follow manufacturer cleaning instructions and retain any records if internal policies or other standards require proof of PPE maintenance.