Head protection requirements

Under 1918.103(a) the employer must ensure employees wear a protective helmet when working in areas where there is a potential for head injury from falling objects.

• If workers perform tasks in areas where tools, cargo, or other objects could fall or be dislodged, the employer must provide and require head protection.
• This is a performance requirement: assess work areas for the potential for falling objects and make helmets mandatory where that hazard exists.

(See 1918.103(a).)

Under 1918.103(b)(1) head protection is acceptable if it complies with any of the listed ANSI standards: ANSI Z89.1-2009, ANSI Z89.1-2003, or ANSI Z89.1-1997.

• Employers may meet the requirement by supplying helmets manufactured to any one of those three ANSI versions referenced in 1918.103(b)(1)(i)-(iii).

(See 1918.103(b)(1)(i) and related subsections.)

Yes — under 1918.103(b)(2) an employer can use a head protection device that does not meet the listed ANSI standards if the employer can demonstrate it is at least as effective as one constructed to those consensus standards.

• The employer must be able to document or demonstrate equivalency in protective performance compared to an ANSI Z89.1 helmet.
• Keep the demonstration records or rationale available to support compliance when requested by OSHA.

Under 1918.103(c) the employer must clean and disinfect any previously worn protective hat before giving it to another employee.

• Cleaning and disinfection help prevent spread of skin conditions and maintain sanitary PPE.
• Employers should use cleaning methods recommended by the helmet manufacturer or follow established disinfecting procedures that do not damage the helmet's protective properties.

Under 1918.103(b)(1)(i) the ANSI Z89.1-2009 version is accepted, but the rule also explicitly lists earlier versions (1918.103(b)(1)(ii)-(iii)).

• Employers may use helmets that comply with ANSI Z89.1-2009, ANSI Z89.1-2003, or ANSI Z89.1-1997 as each is specifically incorporated by reference.
• You do not need the newest ANSI edition if your hard hats meet one of the listed versions or you can show equivalent protection per 1918.103(b)(2).

No, employers generally must provide required PPE, such as protective helmets, at no cost to the employee unless a specific exception applies; OSHA has explained the employer-pay requirement in its guidance on PPE payment methods.

• OSHA's interpretation on payment for PPE explains that employers must pay for PPE required by OSHA standards in Parts 1910, 1915, 1917, 1918, and 1926, with limited exceptions, and a deposit system cannot result in a net cost to the employee. See the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13.
• If the employer retains ownership, they may require return of the helmet upon termination and may recover the cost if the employee fails to return employer-owned PPE, but the employer cannot shift routine costs of required PPE onto the employee.

(See 1918.103 and the OSHA interpretation on employee PPE payment methods at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13.)

You should keep clear documentation showing how the non-ANSI head protection provides protection at least as effective as an ANSI-listed device, because 1918.103(b)(2) deems such devices compliant when equivalency is demonstrated.

• Documentation can include manufacturer test reports, third-party lab test results, engineering analyses, or other objective evidence comparing impact and penetration resistance to the ANSI performance levels.
• Retain those records with your safety program and make them available during inspections to substantiate the equivalency claim.

Yes — 1918.103(c) allows the employer to issue previously worn protective hats provided they are cleaned and disinfected before issuance to another employee.

• Ensure cleaning/disinfection methods do not damage suspension systems or shell integrity; follow manufacturer cleaning instructions where available.
• If a used helmet shows damage (cracks, deep dents, compromised suspension), it should be removed from service regardless of cleaning.

Under 1918.103(a) employers must ensure each affected employee wears a protective helmet when working in areas where there is a potential for head injury from falling objects; this typically means employees in those areas should wear helmets while exposed to the hazard.

• Employers can set clear, task- or area-specific policies based on hazard assessments (for example, require helmets during active cargo transfers or when beneath overhead loads).
• Document your hazard assessment and the rationale for when helmets are required to show you have met the performance requirement in 1918.103(a).

Although 1918.103 does not list post-impact replacement criteria, the employer must ensure protective helmets continue to protect employees; if a hard hat is struck or shows damage it should be removed from service and replaced.

• Follow manufacturer guidance and applicable ANSI criteria (see the ANSI standards listed in 1918.103(b)(1)).
• Keep damaged helmets out of circulation and replace them promptly to comply with the duty to provide effective head protection under 1918.103(a).

Yes, employers may rely on helmets labeled to ANSI Z89.1-1997 or ANSI Z89.1-2003 because 1918.103(b)(1)(ii)-(iii) explicitly incorporate those editions by reference.

• Ensure the helmet meets the version cited on its label and that the helmet remains serviceable.
• If you use a helmet listed to an older ANSI edition, document that it complies with one of the acceptable editions referenced in 1918.103(b)(1).

Yes — employers may rent or loan helmets for temporary use, but they must ensure the helmets meet the standard's requirements (an accepted ANSI version or proven equivalent) and that previously worn hats are cleaned and disinfected before issuing them to employees per 1918.103(b) and 1918.103(c).

• Verify the rented/loaned helmets comply with one of the ANSI versions in 1918.103(b)(1) or document equivalency under 1918.103(b)(2).
• Clean and disinfect previously worn hats before issuing them to another employee as required by 1918.103(c).

While 1918.103(c) requires cleaning and disinfecting previously worn hats, employers should follow manufacturer or ANSI guidance for cleaning and maintenance to avoid degrading protective performance.

• Use cleaning/disinfection methods recommended by the helmet manufacturer or consistent with the ANSI standards referenced in 1918.103(b)(1) to ensure the shell and suspension are not damaged.
• If manufacturer cleaning instructions are not available, document the cleaning method used and verify it does not impair the helmet's safety features, as required under 1918.103(c).

Yes, employers can use a deposit system for employer-owned PPE such as helmets as an incentive for return, but the system must not result in the employee bearing the cost of required PPE; OSHA's interpretation on PPE payment methods explains this.

• OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 permits deposit systems provided they do not circumvent the rule requiring employers to pay for PPE and do not result in a net cost to the employee.
• If the employer retains ownership, they may recover the cost of unreturned PPE but cannot charge employees for normal wear-and-tear resulting from workplace use.

(See 1918.103 and OSHA's PPE payment methods interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13.)

No — 1918.103(b) does not itself spell out helmet types or electrical classes; it requires that head protection comply with the ANSI standards listed in 1918.103(b)(1), and those ANSI standards provide the specific types and electrical classes.

• To determine whether a helmet protects against electrical hazards, refer to the applicable ANSI Z89.1 edition named in 1918.103(b)(1) and the helmet's labeling.
• If you need to use a non-ANSI helmet for electrical work, you must demonstrate equivalency under 1918.103(b)(2).

No — cloth or baseball caps do not meet the protective functions required by 1918.103(a) and 1918.103(b) because they are not constructed to the ANSI head-protection standards listed.

• Employers must provide helmets that meet one of the ANSI editions referenced in 1918.103(b)(1) or demonstrate an equivalent level of protection under 1918.103(b)(2).
• Soft hats do not provide impact or penetration protection required for areas with potential falling-object hazards.

While 1918.103 focuses on providing head protection, employers are responsible for ensuring employees use PPE properly, which includes training on when and how to wear protective helmets and how to inspect them for damage.

• Provide instruction on proper fit, adjustment of suspension systems, inspection for signs of damage, and care/cleaning per manufacturer recommendations or practices aligned with the ANSI standards referenced in 1918.103(b)(1).
• Training helps ensure compliance with 1918.103(a) by reducing misuse and extending effective protection.

Modifying helmets in a way that could affect their protective performance is not advisable unless the modification has been shown not to reduce protection; 1918.103(b)(2) allows equivalent protection only when demonstrated.

• Any modification that may alter impact resistance or structural integrity should be avoided unless validated by the manufacturer or a qualified testing authority and documented to show continued equivalency to the ANSI standards referenced in 1918.103(b)(1).
• Keep written approvals or test reports on file to justify modified helmets as compliant under 1918.103(b)(2).

Although 1918.103 requires helmets to comply with one of the ANSI editions listed, it does not itself mandate labeling practices; however, helmets meeting ANSI standards are typically labeled by the manufacturer to identify the standard edition.

• Using helmets labeled to an ANSI edition listed in 1918.103(b)(1) is good practice because the label documents compliance.
• If you claim equivalency under 1918.103(b)(2), maintain documentation showing why unlabeled or differently labeled helmets are at least as effective.