Protect Your Noggin! March is Brain Injury Awareness Month
According to the Bureau of Labor Statistics, in 2020, head injuries accounted for nearly 6% of non-fatal workplace injuries. The majority of these injuries occurred from contacting or bumping into objects or equipment, while about 20% were the result of slips, trips and falls.
What Are the Requirements?
The General Industry OSHA regulations regarding Personal Protective Equipment (29 CFR 1910.132) requires employers to conduct a hazard assessment to determine if hazards are present or are likely to be present that would require the use of PPE, including head protection. The types of PPE selected are required to be appropriate to the hazard and fit the employee appropriately. PPE is required to be provided by the employer, and the employer must train employees on the proper selection, use and care of PPE. Further, employers are expected to ensure that their employees wear provided PPE.
29 CFR 1910.135 provides additional requirements specific to Head Protection. This regulation specifically requires employers to “ensure that employees wear a protective helmet when working in areas where there is a potential for injury from falling objects”. When employees are exposed to electrical conductors that could contact the head, they must wear head protection at that time as well. Head protection must meet the requirements of ANSI Z89.1-2009, or ANSI Z89.1-2003, or ANSI Z89-1997 or be demonstrated by the employer are at least as effective as those manufactured and tested in accordance with the above ANSI standards.
For construction workplaces, 29 CFR 1926.95 specifically requires employers to pay for most PPE (including head protection) and generally requires that PPE “shall be provided, used and maintained in a sanitary and reliable condition wherever it is necessary by reasons of hazards of processes of environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any body part through absorption, inhalation or physical contact.” Specifically, in 29 CFR 1910.100, OSHA requires employees to be protected by protective helmets when working in areas where there is a possible danger of head injury from impact or from falling or flying objects or from electrical shock and burns. Further, the Scaffolding requirements in 29 CFR 1926.451(h)(1) states “In addition to wearing hardhats each employee on a scaffold shall be provided with additional protection from falling hand tools, debris, and other small objects…” Equipment used to provide head protection must meet the same requirements stated in 29 CFR 1910.135, summarized above.
Notice that it is not enough to simply provide the PPE, but the employer has a duty to ensure their employees wear and properly care for their PPE.
What’s New in Head Protection?
In November of 2023, OSHA published a Safety and Health Information Bulletin titled “Head Protection: Safety Helmets in the Workplace.” This bulletin recognizes the evolution of workplace safety equipment over the years that makes available to workers and employers improved PPE designs. Specifically, it outlines the differences between traditional Hard Hats and newer Safety Helmets. While traditional hard hats provide protection from bumping against objects and from some falling objects, they provide little in the way of side protection, can be heavy, and often do not provide good airflow. Newer safety helmets, on the other hand, are more similar in design to spelunking and other sports helmets. They are constructed of a variety of materials that reduces the overall weight of the helmet, fit more closely to prevent them from being easily knocked off, provide some side impact protection and are generally more comfortable. In a Trade Release in December 2023, OSHA announced that the department was switching from traditional hard hats to modern safety helmets for their employees to better protect them when they are on inspection sites.
How to Choose?
Should you switch from traditional Hard Hats to the more modern Safety Helmets? Perform a risk assessment of your workplace and consider the following:
Are employees wearing head protection all the time? A Safety Helmet may be more comfortable and less fatiguing to their necks. If PPE is comfortable and fits well, employees are more likely to wear it.
Are employees performing overhead work, and/or work that requires they maneuver their heads downwards? In these positions, traditional hard hats tend to fall off, consider Safety Helmets.
Are employees working in areas where they are likely to bump their head into and against objects such as pipes, a Safety Helmet may provide better protection and, again, is less likely to get knocked off.
Are employees subjected to potential strikes against the side of the head? Riggers, for example, could be struck more obliquely by hooks and other parts of lifting and hoisting equipment. A Safety Helmet will provide better protection from oblique impacts.