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June 12, 2021 7 min read
Decorating hard hats is popular in the construction industry, enabling workers to let their personalities shine and easily locate gear in a sea of lookalike buckets. Construction supervisors also have practical uses for hard hat stickers, from maximizing worker visibility to identifying company affiliations on large job sites to indicating wearers’ skills and qualifications.
Hard hat markings can be used to identify workers with safety certifications like CPR training in emergencies, as well.
But while adding hard hat accessories like stickers or paint may seem harmless—and there’s a lot to be said for anything that inspires workers to wear protective headgear—safety concerns can arise if decorations are applied improperly.
The Occupational Safety and Health Administration (OSHA) generally frowns on hard hat modifications. But there’s no denying workers’ desire to personalize protective gear. And the lack of clear-cut guidance on this common activity can leave construction companies struggling to interpret what is safe and what might qualify as a fine-inducing violation.
In this blog, we clear up confusion about what the law requires for decorations like hard hat stickers and paint, explaining the reasons for caution.
And while best practice means using a hard hat as it was purchased or consulting the manufacturer before any modifications, we’ll also cover tips for safer customization.
Essentially, giving a hard hat some personality shouldn’t compromise the reason you wear it: to protect your noggin!
Customizing hard hats on construction sites is nothing new; different-colored helmets have long been used to distinguish jobs or ranks. For instance, white hard hats typically indicate engineers or supervisors, brown is reserved for welders, and orange can identify road crews, new employees, or visitors.
Initially, hard hat stickers mainly advertised unions. Since then, an entire industry of construction helmet decorations has exploded on the internet. And one of the most common questions hard hat manufacturers field is whether it’s OK to apply stuff to protective headgear.
While personalized hard hats can provide value, there are several issues to consider before slapping stickers or painting designs onto head protection:
Guidelines established in the national standard for hard hats and construction helmets, American National Standards Institute (ANSI) Z89.1, require workers to inspect every helmet component and accessory before every use for signs of wear or damage. Some manufacturers even recommend multiple inspections throughout the day to maximize safety since damage can occur at any time.
Applying too much paint or too many stickers risks masking damage to the shell that would otherwise fail inspection andrequire the helmet to be removed from service.
While best practice remains using PPE as purchased, personalized hard hats have become commonplace. Image source: eBay
It’s hard to avoid many things that weaken hard hat shells, such as ultraviolet light or exposure to chemicals or extreme temperatures on some job sites. But applying substances known to degrade a hard hat’s protection—like metallic stickers, many paints, and paint thinners—is an avoidable risk.
Construction workers often rely on brightly colored hard hats to maximize visibility to motorists or colleagues operating equipment or transporting heavy loads. Too many hard hat stickers can create an obstacle to viewers—limiting the attention-grabbing ability of a helmet’s solid, bright color.
Before you transform your hard hat into a tribute to your favorite NFL team or the American flag, be sure to check whether the company allows it. For reasons that run the gamut, from safety precautions to projecting a certain image, some construction companies have banned hard hats adorned with stickers or paint from the workplace.
OSHA regulations for personal protective equipment (PPE) are established in Title 29 of the Code of Federal Regulations (29 CFR aka CFR Title 29), which attempts to create a work environment safe from known dangers.
Using OSHA-compliant head protection is critical on construction job sites, where workers face the highest occupational risk of traumatic brain injuries (TBIs). To achieve compliance, OSHA mandates that the construction industry meet specific standards set forth by ANSI Z89.1.
To learn more about head protection rules the construction industry must follow, read our blog, “The ANSI Z89.1 Standard for Hard Hats & Construction Helmets: A Guide.”
The 2014 edition of ANSI Z89.1 (A7) instructs users to “never alter or modify the helmet to accept accessories” without manufacturer instruction. But OSHA and ANSI rules do not explicitly prohibit painting or placing adhesive stickers on hard hat shells.
And that’s where the waters get muddy.
In Chapter 5, “Accessories and Replacement Components,” ANSI Z89.1-2014 mandates: “Accessories or replacement components, when installed, shall not cause the helmet to fail the requirements of this standard.”
In a letter response intended to shed light on decorated hard hat enforcement, OSHA Director of Enforcement Programs Richard E. Fairfax notes that OSHA Standard 29 CFR 1910.132(a) requires employers to ensure PPE is “maintained in a sanitary and reliable condition.”
Fairfax explains that paint and adhesive stickers applied too heavily or in the wrong places can adversely impact an employer’s ability to assure reliability—concealing dents, cracks, penetrations, and other signs of wear or damage that would otherwise be easy to spot during an inspection.
The quantity and location of adhesive stickers can compromise hard hat safety. Image source: eBay
Unseen damage jeopardizes a hard hat’s integrity, rendering it unsafe. But even so, OSHA and ANSI regulations stop short of banning decorations on protective headgear.
ANSI Z89.1 (A7) warns that “caution should be taken when marking or decorating Class G or E helmets” so electrical resistance isn’t impacted. It also states: “Helmet decorations should not be used to obscure dents, cracks, non-manufactured holes, other penetrations, burns or other damages.”
ANSI (A4) also emphasizes that “caution should be exercised if shells are to be painted,” noting that “some paints and thinners may attack and damage the shell and reduce protection.”
But ultimately, OSHA and ANSI punt responsibility back to hard hat manufacturers, instructing workers who want to decorate their headgear to seek guidance from their specific manufacturer about what’s safe.
“Painting or applying stickers must be performed in accordance with the manufacturer's instructions, unless the employer can demonstrate that the altered protective helmet is equally as effective and protective as those meeting the requirements of Z89.1,” OSHA’s Fairfax writes in his letter response.
“OSHA would consider painting or placing adhesive stickers acceptable if the manufacturer authorizes the alteration or the employer can demonstrate that the reliability of the helmet is not affected by the paint or the adhesive on the stickers; and the paint or placement of stickers would not reduce the ability to identify defects (i.e., use of see-through stickers) or other conditions that would indicate a reduced reliability.”
Company logos and motivational slogans represent just a few practical uses construction companies have found for hard hat stickers. Image source: Considerate Contractors
As a rule, hard hat manufacturers emphasize that helmets should not be altered or modified in any way. That said, most recognize that applying stickers is common. And most concede that a reasonable amount of pressure-sensitive, non-metallic stickers or tape with self-adhesive backing is generally OK—if they are placed at least 3/4” from the helmet’s edge.
In Safety & Health magazine, Bullard Head and Face Protection Product Manager Jeannette Gaunce states that the type of adhesive common in pressure-sensitive stickers risks "very little potential for chemical interaction" that negatively impacts a hard hat's safety performance under normal conditions.
However, she adds: “The helmet should be removed from service and replaced immediately if any surface cracks, however small, appear on the shell surface, whether or not they are in the vicinity of the stickers.”
Gaunce states stickers can become a safety concern if the location or quantity makes it challenging to inspect the hard hat shell. For this reason, hard hat manufacturers like North and Fibre-Metal recommend that wearers seek written permission from the company before applying stickers to their helmets.
It’s also good practice to pay extra attention to the corresponding area inside the hard hat shell during inspections to better catch damage that a sticker may hide.
Feeling inspired? Always consult the manufacturer before personalizing a hard hat with paint. Image source:NanXSeven on Imagr
Hard hat paint represents a stronger concern—and most manufacturers forbid users from applying paint without explicit permission. For instance, MSA recommends “paint never be used” on most of its hard hats because it “may attack and damage shells … thereby reducing the degree of protection originally provided.”
However, MSA qualifies that paint approved for such purposes can be used on three specific hard hats it manufactures out of materials with inert properties that won’t suffer degradation.
In contrast, Honeywell, which owns brands like North and Fibre-Metal, states hard hats should “never be painted or sprayed with any chemicals.”
As an alternative to applying hard hat accessories, Bullard’s Gaunce recommends options like pad printing by the manufacturer. This process prints logos or other designs directly and permanently on hard hat shells and doesn’t peel, crack, or fade like stickers and decals.
Gaunce also states that identification data can be engraved on the underside of a helmet’s brim without impacting safety performance—but nowhere else.
Hard hats stand out as the most recognizable piece of safety equipment in the construction industry, but customization enables them to play other important roles. Hard hat stickers and paint not only add style and personality but can be used to communicate information on job sites quickly.
But improper use of decorations—too many or types with the wrong chemicals—can jeopardize a hard hat’s safety performance, leaving construction workers vulnerable to traumatic brain injuries.
Consider this sobering fact: OSHA records more than50,000 “struck by falling object” injuries every year in the U.S. On construction sites, a hard hat can be all that stands between an unlucky worker underneath a dropped tool and serious injury or death.
OSHA and ANSI regulations offer murky guidance about hard hat decoration safety. But following simple best practices—and seeking manufacturer approval before applying hard hat stickers or paint—can help you adorn your PPE gear with confidence.
Want to learn more about construction helmet safety? Check out more resources from Hard Head Veterans, where we:
Top image source: MTA Capital Construction Mega Projects viaWikimedia (CC BY 2.0)