Head protection requirements

Yes—under 1926.100(a) employers must provide protective helmets for employees who work in areas where there is a possible danger of head injury from impact, falling or flying objects, or from electrical shock and burns.

• The requirement is stated directly in 1926.100(a).
• If a work area has any of those hazards (for example, overhead material, tools that could fall, flying debris, or electrical exposure), the employer must ensure workers are protected by appropriate helmets.

Employers must provide helmets that meet one of the listed ANSI consensus standards: ANSI Z89.1-2009, ANSI Z89.1-2003, or ANSI Z89.1-1997.

• The acceptable standards are identified in 1926.100(b)(1) and the specific incorporated versions are listed at 1926.100(b)(1)(i) 1926.100(b)(1)(ii) and 1926.100(b)(1)(iii).
• Providing helmets that meet any one of those versions will satisfy the standard's specification requirement.

Head protection for employees exposed to high-voltage electrical shock and burns must also meet the electrical insulation specifications in Section 9.7 of one of the listed ANSI standards.

• This requirement is stated in 1926.100(b)(2).
• In practice that means you must select helmets classified and tested for electrical insulation per Section 9.7 of [ANSI Z89.1-2009/2003/1997] as incorporated by reference in the standard.

Yes—OSHA will accept a head protection device that the employer demonstrates is at least as effective as a device constructed to one of the listed ANSI consensus standards.

• This allowance is in 1926.100(b)(3).
• To rely on this provision, an employer must be able to demonstrate (and should document) that the alternative device provides protection equivalent to the relevant ANSI criteria for the hazard (impact, falling objects, electrical insulation, etc.).

Yes—employers must assess the workplace hazards to determine what head protection is needed before selecting PPE, including protective helmets.

• While 1926.100 identifies when helmets are required and what specifications they must meet (1926.100(a) and 1926.100(b)), OSHA's interpretation on PPE hazard assessments explains that employers must assess the workplace to determine hazards and the proper PPE and must prepare a written certification when PPE will be required. See the OSHA letter on PPE hazard assessment at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28.
• Conducting a hazard assessment helps you select the correct helmet type (impact class, electrical class, etc.) and document why that selection protects employees adequately.

Yes—a helmet that meets ANSI Z89.1-2009 satisfies the specification requirement in 1926.100(b)(1)(i) and therefore complies with the standard's equipment specification.

• The incorporation of ANSI Z89.1-2009 is explicit in 1926.100(b)(1)(i).
• Ensure the helmet is used for the hazards it was designed to protect against (for example, electrical-rated helmets for electrical hazards) and that it is maintained, adjusted, and replaced as needed.

An employer should document the demonstration showing the head protection device is at least as effective as an ANSI-compliant device, including the basis for equivalence and any testing, certifications, or engineering analysis relied upon.

• The authority for accepting such alternatives is in 1926.100(b)(3).
• Useful documentation elements include testing reports, manufacturer technical data comparing performance to ANSI criteria (impact, penetration, electrical insulation if relevant), and the employer's hazard assessment that explains why the alternative provides equal protection (see OSHA's PPE hazard assessment interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28).

Yes—head protection must be appropriate for the specific hazards present, and helmets intended for electrical protection must meet the electrical insulation specifications in Section 9.7 of the incorporated ANSI standards when high-voltage exposure exists.

• The general requirement to protect employees in hazard areas is in 1926.100(a), and the electrical-insulation requirement is in 1926.100(b)(2).
• Employers should conduct a hazard assessment to identify whether impact-only helmets are sufficient or whether electrical-class helmets (per Section 9.7 of the ANSI standards) are required; the PPE hazard assessment interpretation provides guidance on conducting and documenting those assessments (https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28).

Yes—many helmets are designed to provide both electrical insulation and impact protection, and if a helmet meets the appropriate ANSI requirements for both hazards it is acceptable.

• 1926.100 requires head protection where there is danger from impact or electrical hazards (1926.100(a)) and mandates electrical-insulation specifications for high-voltage exposure in 1926.100(b)(2).
• Verify the helmet’s ratings against the ANSI standard sections (impact and Section 9.7 for electrical insulation) or document equivalence per 1926.100(b)(3).

Only if the employer can demonstrate the bump cap provides protection at least as effective as an ANSI Z89.1-compliant industrial helmet for the specific hazard; otherwise bump caps generally do not meet the industrial helmet specifications.

• The standard accepts helmets that meet the named ANSI standards (1926.100(b)(1)) and allows alternatives only where the employer can demonstrate equivalent protection (1926.100(b)(3)).
• Because many bump caps are not tested to the ANSI impact and electrical criteria, employers should not rely on them unless they have documented evidence showing equivalent protection for the actual workplace hazards.

Only if the helmet either meets one of the listed ANSI versions or the employer can demonstrate it is at least as effective as an ANSI-compliant helmet; simply being older does not automatically make it acceptable.

• The standard lists specific acceptable ANSI versions in 1926.100(b)(1).
• Alternatively, 1926.100(b)(3) permits use of other devices when the employer demonstrates equivalence, so document any such demonstrations carefully.

Yes—OSHA guidance on PPE hazard assessments explains that when PPE is required the employer must assess the workplace hazards and prepare a written certification of that assessment.

• The head protection standard itself sets helmet requirements (1926.100(a) and (b)), and OSHA's interpretation on PPE hazard assessment clarifies the employer's duty to assess hazards and produce a written certification when PPE will be used; see the PPE hazard assessment letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28.
• The written certification should identify the workplace evaluated, the person conducting the assessment, the date, and that the assessment identified the hazards and the PPE selected to protect against them.

Yes—helmets used around high-voltage electrical hazards must meet the electrical insulation tests specified in Section 9.7 of the ANSI standards identified in 1926.100(b)(1).

• This specific electrical requirement is in 1926.100(b)(2).
• Verify the helmet's certification or testing shows compliance with Section 9.7 of one of the incorporated ANSI versions or document equivalent protection under 1926.100(b)(3).

Not unless the employer demonstrates the recreational or motorcycle helmet is at least as effective as an ANSI Z89.1 helmet for the workplace hazards; otherwise it will not meet the industrial standard.

• The standard requires helmets to meet one of the ANSI versions listed in 1926.100(b)(1) or to be shown equivalent under 1926.100(b)(3).
• Because motorcycle and recreational helmets are designed and tested to different standards, you should obtain testing/certification showing equivalence before accepting them for industrial head protection.

No—1926.100 sets requirements for when helmets are required and what specifications they must meet, but it does not specify inspection or replacement intervals; employers must establish maintenance and inspection practices to ensure helmets remain protective.

• The head protection standard itself is at 1926.100. It does not detail inspection schedules or discard intervals.
• Employers should follow manufacturer guidance, applicable ANSI recommendations, and their own hazard assessment to set inspection and replacement procedures and document them as part of their PPE program (see PPE hazard assessment guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28).