OSHA Addresses Head Protection, Safety Practices for Electrical Work
Two new letters of interpretation from OSHA respond to questions about the agency’s head protection requirements as well as an inquiry about OSHA’s selection and use of work practices standard for electrical work. The agency’s responses are signed by Erin P. Gilmore, acting director of OSHA’s Directorate of Enforcement Programs. They are both dated Aug. 17 but were not available on the agency’s website until Oct. 10.
An individual from Lancaster, Pennsylvania, asked how OSHA’s head protection requirements under 29 CFR 1910.135 for general industry apply to the selection and use of Type II safety helmets that meet ANSI Z89.1 on industrial head protection. The individual also requested information about how OSHA applies its head protection requirements when employees may be exposed to lateral or off-center head impact hazards and whether a 2024 OSHA safety and health information bulletin on safety helmets (PDF) relates to enforcement.
OSHA’s reply explains that its head protection standard incorporates by reference ANSI Z89.1-2009, ANSI Z89.1-2003, and ANSI Z89.1-1997 but that the agency does not require employers to use a particular ANSI helmet type. OSHA’s personal protective equipment standard for general industry requires employers to assess workplaces for hazards that necessitate the use of PPE and then select and ensure that workers use the types of PPE that will protect them against hazards identified during the assessment.
“Accordingly, where a hazard assessment … identifies blow to the top or side of the head hazards, head protection that provides only top-impact protection may not be adequate to protect employees from those hazards,” OSHA’s letter states. “In such circumstances, OSHA will require employers to provide proper PPE (for example, Type II) that will protect the affected employee from the specific hazards identified in the hazard assessment.”
The letter of interpretation about head protection clarifies that the agency’s bulletin on safety helmets “is advisory in nature and does not create new legal requirements” and provides some additional insights in response to other questions about helmet type.
A separate letter of interpretation addresses a question from an individual from Utica, Ohio, who asked OSHA if “a lock bearing a permanently affixed label stating ‘unauthorized operation of the disconnecting means and unauthorized removal of the lock are prohibited’” would satisfy the requirements of the agency’s selection and use of work practices standard for electrical work. OSHA responded that a lock with a label as described would meet the standard’s requirements as long as the label is legible.
These and other letters of interpretation are available on OSHA’s website.