The Occupational Safety and Health Administration (OSHA) is an agency of the US department of labor established under the Occupational Safety and Health Act. The Act was signed into law on 29th December 1970 by President Richard M. Nixon. The administrative role of the agency is geared towards ensuring safe and healthy working conditions for all citizens. This role is realized by enforcing the set standards of health and safety, sensitizing employers and employees on safety through training, education, and outreach, as well as providing assistance where need be.
Where conditions predispose workers to head injuries, OSHA guidelines call both the employer and the employee to ensure that hard hats are used always. These hats may be made of different materials some of which may fail certain requirements, hence our query, are aluminum hard hats OSHA approved? The answer to this question is better understood in the background of the working contexts where hard hats are a compulsory requirement.
In which work contexts does OSHA require hard hats?
Hard hats are a safety requirement in all work contexts where workers are consistently exposed to dangers and accidents that may injure the head. In OSHA standard 29 CFR 1910.135 on head protection, the agency guides that hard hats be used for general industry workers. In application, OSHA standard 29 CFR 1926.100, refers to the head protection guideline and sets it as a requirement for workers in construction, renovation, and demolition. These work contexts predispose workers to head injuries for three reasons:
- They are characterized by the consistent falling of objects and debris which may land of the heads of workers, causing life-threatening or altogether fatal injuries.
- Workers at construction sites are consistently in movement and may accidentally knock their heads against hard surfaces like low walls, construction support metals, construction machinery and the like.
- The construction work context always makes use of electricity and workers may be exposed to electrical circuits on their heads and consequently electrical shocks.
Information on OSHA data and statistics indicates that in 2017, a total of 5,147 workers died on their job. 4,674 fatalities happened in the private sector and of these, 20% (971) involved workers in construction. In addition, the agency reports that the ‘Fatal Four’ are the leading causes of deaths in the private construction sector. In order of the cause accounting for most deaths in 2017, the Fatal Four are falls, being struck by the object, electrocution and being caught between. These four causes accounted for 59.9 percent of all the deaths among construction workers that year.
The foregoing is enough reason to endorse wearing a hard hat as an indispensable prerequisite for protecting the laborer from fatal head injuries. But is any hard hat permissible? And are aluminum hard hats OSHA approved?
The hard hats that meet OSHA standards
OSHA regulation for head protection incorporates standards provided by the American National Standards Institute (ANSI). As such, OSHA refers to the guidelines by ANSI when listing the criteria for endorsing hard hats.
Depending on the aspect of compliance, a hard hat must comply with 1997, 2003, or 2009 editions of ANSI Z89.1 to be OSHA compliant. This means that head protection is guaranteed according to the provisions in 29 CFR 1910.135(b)(1) and as referenced in 29 CFR 1926.100(b)(1). Specifically, the standards define:
- The ‘types’ as well as the ‘classes’ of hard hats to be used in specific work situations;
- the design and resistance level of protection from impact, penetration, and electrocution; and
- the testing requisites that manufacturers must meet to make the hats OSHA compliant.
Generally, all hard hats must demonstrate protection levels that correspond to these standards or provide better protection. They must do so in type and class. Type implies that the hat protects specific areas of the head. Type 1 hats protect the top of the worker’s head while type 2 hats protect both the top and the sides.
Regarding the class, hard hats are classified into 3 categories depending on the level of protection provided against electrical hazards.
- Class G hats are in the General category and will offer protection in electrical hazards in the range of 2,200 volts.
- Class E hard hats are recommended for situations with 20,000 volts and are categorized as Electrical.
- Class C hats do not provide any protection from electrical hazards and are rated Conducive.
Do aluminum hard hats meet the above criteria?
Aluminum hats may be made to meet prerequisites for type 1 and 2. This means that they may protect the worker from falling objects and debris as well as from knocks. From the ‘classes’ perspective, however, aluminum hard hats are rated Conducive and will not protect the worker from electrocution.
In exemplification, reference is here made to a letter written by the Director at the Directorate of Compliance Programs, Richard E. Fairfax, on June 25, 2002. The letter was a reply to a certain Mr. Harper who had written to OSHA’s Directorate on April 29 the same year. The writer was requesting guidelines on whether his aluminum hard hat was safe to use when delivering hardware parts to construction and industrial sites.
In his reply letter, the Director of OSHA delivers to Mr. Harper an OSHA’s interpretation of his situation and explains that his aluminum hard hat would be considered to be within requirement in his work context but no so in contexts where he may come into contact with electrical circuits.
Away from the example, hard hats must be labeled to offer information on details related to the manufacturer’s name, a declaration on the edition of ANSI Z89.1 that the hat conforms to, the type and class of the hat, the fitting range, and the manufacturing date.
Conclusively, therefore, we’ve found an answer to the question are aluminum hard hats OSHA approved. Aluminum hard hats that meet the above criteria may be considered OSHA approved when used in work situations where there are dangers of falling objects and workers are exposed to accidental blows on their heads. The same hats will, however, not be OSHA compliant where laborers are exposed to dangers of electrocution.