OSHA Hard Hat Compliance: A Guide to the ANSI Z89.1 Standard

Simplifying construction industry regulations—and how to choose the right hard hat for your workplace

 

With construction workers facing the highest occupational risk of traumatic brain injuries (TBIs), hard hats are a critical piece of equipment on the job site. But what safety standards matter most—and how do you know that the construction helmet you choose offers appropriate protection?

Construction sites can be notoriously dangerous places, even when proper safety protocols are followed. From falls off a roof to collisions with exposed beams to getting struck by moving vehicles, the risk of head injury looms large.

During a seven-year study, the American Journal of Industrial Medicine found 2.6 fatal TBIs per 100,000 construction workers every year —more than triple the average rate across all other industries. That represents 1 in 4 construction-related deaths and nearly 1 in 4 of all occupational TBI fatalities.

Even mild TBIs can have life-long effects, impacting cognitive function, movement coordination, social behavior, and overall quality of life.

The right industrial helmets—commonly known as hard hats—can protect construction crews from falling debris, low-hanging objects, contact with electrical hazards, splashes, high heat, exposure to ultraviolet light, and more. A National Institutes of Health (NIH) report asserts that hard hats complying with American National Standards Institute (ANSI) guidance can reduce head acceleration by as much as 95% after impacts from large falling objects.

In this blog, we explain:

  • The American National Standards Institute’s (ANSI) American National Standard for Industrial Head Protection (ANSI/ISEA Z89.1-2014), which ensures the quality and safety of construction helmets.
  • When hard hats are required by the Occupational Safety and Health Administration (OSHA) and the role of the ANSI hard hat standard.
  • How to determine with a glance if a helmet is compliant.
  • We will also show the stiff penalties employers may face for non-compliance—including potential jail time.

Most important, we’ll help you determine the right level of hard hat protection for your needs.

ANSI and OSHA logos

OSHA codes and ANSI hard hat standards: What rules must the construction industry follow?

For a relatively small piece of personal protective equipment (PPE), construction hard hats have an immense responsibility for protecting workers:

  • Deflecting blows to the head
  • Resisting penetration
  • Absorbing the force of impacts via a suspension system
  • Preventing top-of-the-head impacts from traveling down the spine
  • Insulating against electric shocks, when needed
  • Providing water resistance
  • Being fire-resistant

Before OSHA was formed in 1970, construction companies maintained their own requirements for protective gear. Now, Title 29 of the Code of Federal Regulations (29 CFR aka CFR Title 29) mandates specific rules for head protection that aim to create a work environment safe from known dangers or hazards:

  • OSHA 29 CFR 1926.100 governs head protection requirements for construction, demolition, and renovation workers.

As with many of its standards, OSHA mandates that construction companies follow the guidelines set forth by the American National Standards Institute to achieve compliance with head protection regulations. In other words, OSHA establishes the rules construction companies must follow, and ANSI Z89.1 details specific steps needed to comply.

Colorful construction helmets

The 2014 version of the American National Standard for Industrial Head Protection (ANSI Z89.1-2014) details the most updated performance and testing requirements for construction helmets, considering improvements in technology, testing methods, materials, worker needs, and the use and application of products. The ANSI standard also establishes types and classifications for protective classes based on potential hazards, helping employers and users select hard hats that meet specific workplace needs.

The latest ANSI edition revised 2009 regulations. It was prepared by members of the Industrial Safety Equipment Association’s (ISEA's) Head Protection Group and approved by a consensus review panel of users, government agencies, and safety experts.

Key updates to the latest edition include:

  • Requiring manufacturers to provide proof that accessories and replacement components won’t cause helmets to fail
  • Clarification that useful service life doesn’t need to be explained by a set number of years
  • Additional protections for users who work in hotter environments.

OSHA regulations also permit workers to use hard hats that adhere to 2009, 2003, or 1997 ANSI editions, however. They even allow construction helmets that don’t follow ANSI requirements as long as employers can demonstrate equal or better protection.

But keep this in mind: if a job exposes workers to hazards only addressed by the 2014 edition, older products may not comply. For instance, there are new, optional rules for preconditioning hard hats for testing at higher temperatures. These additions make sure the equipment performs in more extreme environments.

It’s also important to note that neither OSHA nor ANSI approves bump caps, which are designed to help wearers avoid bruises, scrapes, and abrasions caused by minor impacts with stationary objects. Bump caps are unsuitable for protection against falling or moving items. They are never intended for use when job site hazards demand ANSI Z89.1 hard hats.

Bump cap and other PPE

When are OSHA hard hats required on construction sites?

OSHA regulations require construction workers to wear hard hats when they are exposed to the following potential hazards:

  • Objects may fall from overhead
  • Potential head contact with electrical hazards
  • Stationary objects like exposed beams and pipes risk head collisions

OSHA places responsibility squarely on employers’ shoulders for not only providing ANSI-compliant head protection but for ensuring employees wear it. Penalties for non-compliance can be severe: fines of up to $13,653 per violation for “serious” infractions, meaning employers knew about an existing risk that could impact health or safety but did little to correct it.

Failing to remedy the situation after receiving a citation can trigger daily fines. And “willful” violations—issued for intentionally ignoring OSHA standards—can lead to criminal penalties that include possible jail time if an employee is killed.

Even so, data from the U.S. Bureau of Labor Statistics found that only 16% of construction workers who suffered a head injury wore hard hats—despite regulations requiring protection for more than twice that number.

Other countries follow their own hard hat standards, like Canada’s CSA Z94.1-15 and Europe’s EN 397:2012 + A1:2012 and EN 50365:2002. The various challenges standards committees face in each geographic region make it unlikely that a global standard will be created any time soon.

For instance, the Canadian standard is similar to ANSI Z89.1, with the most apparent differences stemming from testing requirements. But approval from one organization doesn’t guarantee compliance with the other.

Always make sure your hard hat is labeled and certified for the right location!

Construction workers on a roof

Falls from a significant height represent a leading cause of traumatic brain injuries in construction workers.

How do I choose the right hard hat for my workplace?

As of 2023, if a hard hat meets ANSI Z89.1 for the specific hazardous conditions on the jobsite, it is OSHA-compliant. But what exactly does this mean? You will hear of many new jobsites in the USA requiring climbing or European style hard hats.

What this really means is that many job sites are starting to require a type II hard hat that may include a chin-strap. This doesn't mean though you have to wear that style of hard hat. There are plenty of Type II hardhats on the market, including our soon to launch Kevy hard hat that meets these requirements and doesn't look like a climbing helmet. 

Hard hat types

ANSI Z89.1-2014 (Chapter 4: Types and Classes) establishes two types of protective safety helmets. In this case, “type” doesn’t mean “style,” such as cap or full-brim models. It is a very specific designation that refers to impact and penetration protection.

  • A Type I hard hat cushions blows to the crown or top of the head. While no headgear can fully protect wearers from severe impacts or penetrations, ANSI Z89.1 hard hats deliver assurance that you’re protected from tools, small parts, or similar items falling from a reasonable height—or if you stand up under an obstruction and whack your head.
  • A Type II hard hat reduces the impact from top-of-the-head blows and protects wearers from front, back, and side impacts. This is necessary when working around moving equipment or materials that create a persistent threat of horizontal blows.

Hard hat classes

To further improve safety, ANSI also classifies hard hats by their ability to withstand electrical shock. In the past, ANSI’s electrical class designations were A, B, and C, with B offering the greatest protection.

The current labeling system is more intuitive for choosing the right model:

  • Class G (General) includes all-purpose, general construction helmets providing good impact and penetration protection and limited voltage protection. These hard hats are tested up to 2,200 volts and can be appropriate for general construction work.
  • Class E (Electrical) hard hats are tested up to 20,000 volts, protecting from high-voltage shock. They are well-suited for electrical work where users are regularly exposed to high-voltage environments. They also provide good impact and penetration protection.
  • Class C (Conductive) hard hats are not intended to protect wearers from contact with electrical conductors. While they provide good impact and penetration protection, they should only be used by construction workers with no risk of encountering electrical hazards. Conductive materials can also offer more breathability.

Electrical workers

ANSI-approved Class E hard hats can protect wearers from high-voltage shocks.

ANSI further sets requirements that must be met to achieve compliance with optional hard hat features, including:

  • Low-temperature applications
  • High-temperature applications
  • High visibility
  • Reverse donning (wearing the helmet backward or forward)

Does my construction helmet comply with OSHA and ANSI hard hat standards?

Determining if a construction helmet is ANSI-approved is easy—just sneak a peek inside the shell. In Chapter 6: Instructions and Marking, ANSI requires permanent labels or markings inside certified models. This information must include the following safety facts in 0.06” (1.5 mm) letters:

  • Manufacturer’s name or identification mark
  • Date of manufacture
  • Applicable ANSI standard (for instance, Z89.1-2014)
  • ANSI type (I or II)
  • ANSI class designation (G, E, or C)
  • Approximate head size range for fitting
  • Markings to indicate compliance with ANSI requirements for any optional hard hat features: "LT" for low-temperature rating, "HT" for high-temperature rating, "HV" for high visibility, and two arrows curving to form a circle for reverse wear.

If the certification markings are missing or no longer legible, replacing the hard hat as soon as possible is recommended.

ANSI also requires every hard hat to come with manufacturer’s instructions that explain proper use, the appropriate method of size adjustment and fitting, and guidelines for care and useful life. The 2014 edition clarifies that ANSI does not require manufacturers to define useful life in years; instead, it wants users to understand that conditions like extended sunlight exposure or chemicals could impact protection over time.

Hard hat reverse wear symbol

When this mark appears on the inside of your hard hat, it meets ANSI requirements for safe backward or forward wear.

ANSI testing requirements ensure hard hats provide robust head protection to construction workers

Before ANSI certifies that any type or class of hard hat offers adequate head protection, it must pass these rigorous performance tests detailed in Chapter 10: Test Methods:

  • Flammability — hard hats must be able to resist fire damage.
  • Force transmission — construction helmets must be able to reduce the force of an impact from a falling object to the top of a wearer’s head, even at high and low temperatures.
  • Apex penetration — headgear must resist penetration, even at high and low temperatures.
  • Electrical insulation, when applicable — helmets must withstand exposure to specific amounts of electricity without catching fire while allowing only a marginal amount of electricity to seep through.

Additional tests are required for Type II hard hats. ANSI also details tests for optional features like high-visibility and reverse-wear models that manufacturers can choose to perform.

Construction helmet manufacturers are responsible for ensuring their products are tested to ANSI standards. They typically send samples to independent laboratories that use specialized machines to evaluate performance according to ANSI specifications.

ANSI requires a minimum of 30 samples for the following schedule of performance tests, with anywhere from one to 24 hard hats utilized per test. If optional reverse-donning tests are also performed, a minimum of 36 samples must be used.

ANSI schedule of tests table

ANSI provides this rigorous testing schedule for certifying hard hats as Type I or Type II. It also includes testing for optional features. Table source: ANSI Z89.1-2014

Here’s an overview of what hard hat testing entails—be sure to refer to ANSI Z89.1-2014 for complete details:

ANSI testing requirements for Type I and II construction helmets

1. Flammability

Essentially, this test is performed by applying a Bunsen burner flame to a chosen test point on a hard hat for about five seconds. Five seconds after the flame is removed, testers inspect the sample.

The hard hat fails the flammability test if it shows any sign of visible flame five seconds after the Bunsen burner is removed.

2. Force transmission

Testing is conducted on hard hats preconditioned to the following environments:

  • Hot temperatures: At least 12 test samples are placed in a forced air circulating oven maintained at about 49°C (120°F) for at least two hours. Optional higher temperature testing can also be performed on test samples conditioned to approximately 60°C (140°F) for at least four hours.
  • Cold temperatures: At least 12 test samples are placed in a freezer maintained at about 18°C (0°F) for at least two hours. Optional lower temperature testing can also be performed on test samples conditioned to about –30°C (-22°F) for at least four hours.

Test samples are removed from the conditioning environment one at a time and placed on a headform (a specialized dummy head). An impactor (such as an anvil or steel ball) with a mass of about 8 lbs. (3.6 kg) and a spherical striking face with a radius of about 1.9” (48 mm) is dropped from a height that yields an impact velocity of about 18 ft/s (5.50 m/s).

Individual maximum force readings and impact velocities for all test samples are recorded. The average for each group of preconditioned hard hats is also calculated and recorded.

Construction helmets must not transmit a force to the headform that exceeds 4,450 N (1,000 lbf). The average maximum transmitted force for each preconditioning group must not exceed 3,780 N (850 lbf).

This video from Cadex—a company specializing in helmet-testing technology—demonstrates impact and penetration tests:

 

3. Apex penetration

Testing is conducted on headgear preconditioned to the following environments:

  • Hot temperatures: At least three test samples are placed in a forced air circulating oven maintained at about 49°C (120°F) for at least two hours. Optional higher temperature testing can also be performed on test samples conditioned to approximately 60°C (140°F) for at least four hours.
  • Cold temperatures: At least three test samples are placed in a freezer maintained at about 18°C (0°F) for at least two hours. Optional lower temperature testing can also be performed on test samples conditioned to about –30°C (-22°F) for at least four hours.

Test samples are removed from the conditioning environment one at a time and placed on the test headform. The test is conducted by dropping a pointed steel penetrator onto a hard hat from a height that yields an impact velocity of about 23 ft/s (7 m/s).

The penetrator should have a mass of about 2.32 lbs. (1 kg) and a spherical tip radius of 0.010” (0.25 mm).

Hard hats fail the test if the penetrator touches the top of the test headform.

4. Electrical insulation

Class C hard hats are not tested for electrical insulation. During testing of Class G and E hard hats, permanently attached helmet accessories like lamp brackets and chin straps remain on the sample.

This test is conducted by applying voltage to two test samples partially submerged in water for each helmet type and class.

For Class G hard hats, voltage is increased to 2,200 volts and held for one minute. Electrical current leakage is recorded.

For Class E hard hats, voltage is increased to 20,000 volts and held for not less than three minutes. Current leakage is also recorded. The test sample is then tested for burn-through by increasing the voltage to 30,000 at the rate of 1,000 volts per second — followed by immediately reducing the voltage to zero. Any evidence of burn-through is recorded.

Class G hard hats must be able to withstand 2,200 volts for one minute, with leakage not exceeding 3 milliamperes.

Class E hard hats must be able to withstand 20,000 volts for three minutes, with leakage not exceeding 9 milliamperes. At 30,000 volts, there should be no evidence of burn-through.

This Cadex video demonstrates an electrical insulation test on a construction helmet:

Additional ANSI Z89.1 testing requirements for Type 2 hard hats

1. Impact energy attenuation

This test measures a hard hat’s ability to absorb energy from a lateral impact. Testing is conducted on helmets preconditioned to the following environments:

  • Hot temperatures: At least four test samples are placed in a forced air circulating oven maintained at about 49°C (120°F) for at least two hours. Optional higher temperature testing can also be performed on test samples conditioned to approximately 60°C (140°F) for at least four hours.
  • Cold temperatures: At least four test samples are placed in a freezer maintained at about 18°C (0°F) for at least two hours. Optional lower-temperature testing can also be performed on test samples conditioned to about –30°C (-22°F) for at least four hours.
  • Wet conditions: At least four test samples are submerged in fresh tap water maintained at about 23°C (73.4°F) for at least two hours.

Test samples are removed from the conditioning environment one at a time and placed onto the test headform. The helmeted headform is dropped onto an anvil from a height that yields an impact velocity of about 11.5 f/s (3.5 m/s). The maximum g value (a coefficient of the acceleration of gravity) for each test and the associated impact velocity are recorded.

Maximum acceleration for Type 2 hard hats must not exceed 150g.

2. Off-center penetration

This test measures a hard hat’s ability to resist penetration at the front, side, and rear, as well as above a dynamic test line. Testing is conducted on hard hats preconditioned to the following environments:

  • Hot temperatures: At least two test samples are placed in a forced air circulating oven maintained at about 49°C (120°F) for at least two hours. Optional higher temperature testing can also be performed on test samples conditioned to approximately 60°C (140°F) for at least four hours.
  • Cold temperatures: At least two test samples are placed in a freezer maintained at about 18°C (0°F) for at least two hours. Optional lower temperature testing can also be performed on test samples conditioned to about –30°C (-22°F) for at least four hours.
  • Wet conditions: At least two test samples are submerged in fresh tap water maintained at about 23°C (73.4°F) for at least two hours.

Test samples are removed from the conditioning environment one at a time and placed onto the test headform. The same pointed steel penetrator from the apex penetration test is dropped from a height that yields an impact velocity of about 16.4 f/s (5 m/s).

For each construction helmet, the impactor is dropped at two different sites, reconditioning each sample for at least 15 minutes between impacts.

If the penetrator touches the headform, the helmet fails the test. 

3. Chin strap retention

This test measures a chin strap's ability to keep a hard hat on a wearer’s head. Chin straps must be made of a material at least 0.5” (12.7 mm) in width.

Testing is conducted on hard hats preconditioned to the following environments:

  • Hot temperatures: At least one test sample is placed in a forced air circulating oven maintained at about 49°C (120°F) for at least two hours. Optional higher temperature testing can also be performed on test samples conditioned to about 60°C (140°F) for at least four hours.
  • Cold temperatures: At least one test sample is placed in a freezer maintained at about 18°C (0°F) for at least two hours. Optional lower temperature testing can also be performed on test samples conditioned to about –30°C (-22°F) for at least four hours. 
  • Wet conditions: At least one test sample is submerged in fresh tap water maintained at about 23°C (73.4°F) for at least two hours.

Essentially, the test is conducted by attaching a roughly 22.2 lb. (10 kg) object to a helmet’s chin strap and dropping it from a height of about 4” (10 cm). Residual elongation—a measure of how much a plastic stretches (ductility)—must be recorded between 15 and 30 seconds after impact.

Chin straps must remain attached to the helmet. Residual elongation should not exceed 1” (25mm).

ANSI Z89.1 hard hat testing requirements for optional features

1. Reverse wearing ANSI hard hat standards

There are many reasons construction workers wear their hard hats with the bill backward, from a preference for the look to a better fit with masks to better visibility.

But changing a construction helmet’s orientation can also change its impact area and fit, significantly decreasing its protection. The 2009 edition of ANSI Z89.1 addressed reverse donning for the first time, establishing optional tests that helmets must pass before they are deemed safe for reverse wear:

  • Type 1 hard hats must pass the force transmission test when mounted in the reverse position on the headform to earn the reverse-wearing mark.

  • Type 2 hard hats must pass the force transmission, impact attenuation, and off-center penetration tests when mounted in the reverse position to earn the reverse-wearing mark.

Backwards hard hat

Wearing a hard hat backward that is not ANSI-certified for reverse wear is not a safe practice. Image source: State of California

2. High visibility ANSI hard hat standards

Low visibility ranks as a serious risk on road construction projects, with workers standing mere feet away from high-speed traffic or colleagues operating heavy equipment. Nearly 850 work-zone fatalities were reported in the U.S. in 2019—up 85 from the previous year.

Even employers with the best intentions may not be doing enough to protect their crews; for instance, safety vests with reflectivity on the back and torso do little to draw attention to workers viewed from the side.

Following ANSI’s non-mandatory requirements for high-visibility hard hats can go a long way toward keeping workers safe in poor sight conditions. To earn the “HV” marking, construction helmets must demonstrate the appropriate levels of chromaticity and luminance factor in Table 1 below based on color:

ANSI high-visibility hard hat table

Table source: ANSI Z89.1-2014

3. Higher and lower temperatures

Hard hats are tested for impact, penetration, and chin strap retention under normal temperature conditions and, optionally, at higher and lower temperatures.

Headgear that earns higher temperature “HT” markings is preconditioned in a forced air circulating oven maintained at about 60°C (140°F) for at least four hours before each test. This equipment must also meet all other testing and marking requirements relevant to a hard hat’s class and type.

Helmets that earn lower temperature “LT” markings are preconditioned in a freezer maintained at about –30°C (-22°F) for at least four hours before testing. They must also meet all testing and marking requirements relevant to type and class.

Construction workers on a job site

ANSI hard hat standards and good safety practices reduce construction head injuries

Worker safety should be the highest priority on any job site. And ANSI Z89.1 hard hats deliver a sufficient level of head protection in most conditions.

Of course, other factors also play an essential role in safeguarding workers. As ANSI Z89.1-2014 cautions, “The use of protective helmets should never be viewed as a substitute for good safety practices and engineering controls.”

Construction helmets should fit securely on the head, with the suspension adjusted to a snug fit. Workers should inspect their hard hat shell and suspension frequently and replace it immediately if it sustains a significant impact—even if there are no signs of visible damage.

Proper care and storage are also critical to safety; for instance, painting or using chemical solvents on a hard hat or storing it in direct sunlight can eventually compromise the shell.

OSHA and ANSI standards are a backbone of safety in the construction industry. Using our guide will help you understand the regulations you need to follow—and choose the hard hat that helps prevent serious injuries.

Want to learn more about helmet safety? Check out more posts on the Hard Head Veterans blog, where we explore head injury survival stories, the future of smart helmets, and the evolving science of brain injury