How to allow your workers to face their hard hat bills backward
Did you know workers don’t always need to face their hard hat bills forward? OSHA even says it’s okay but guides employers in a Letter of Interpretation (LOI) dated May 9, 2011. Employers should read this article to learn how to comply with OSHA’s head protection requirements while allowing workers to face their bills to the rear.
While I was a field safety manager, there were two main reasons my workers asked me to wear hard hats backward. The first was because it looked better, and the other reason was that they couldn’t see suspended material loads picked from the main hook of a crane. As the load boomed over to them, the bill blocked their visibility of the load. This caused them to lean backward to see it properly. Leaning back while working at elevated heights increased their risk of having a fall event.
Guidance from OSHA
In the LOI above, OSHA states head protection must meet testing requirements in American National Standards Institute (ANSI) Z89.1-1969. But it only provides testing requirements for facing the bill forward.
The bill helps to deflect small falling objects from overhead. Without the bill, a worker’s face could get struck by a falling object. When I worked in the electrical transmission industry, small bolts, grit, and other things would fall from above during steel erection activities. In the LOI, OSHA states that employers can allow workers to face their bill to the rear if the manufacturer certifies that this practice meets ANSI Z89.1-1969 requirements.
In later versions, ANSI includes testing guidance to manufacturers for facing the bill to the rear. ANSI now provides manufacturers with a reverse-donning test to certify hard hats are safe for reverse wear. If the hard hat is safe to face backward, the manufacturer will place a symbol (two arrows curving to form a circle) on the hard hat.
Best practice tips
I’ve been a safety professional for almost two decades now. I’m telling you from experience that your workers will come up with unique reasons why they should face their bills to the rear. Some explanations will be completely legitimate. But OSHA’s personal protective equipment (PPE) standard requires employers to assess their workplace for hazards and determine when PPE is necessary to protect workers.
A competent person must decide when it’s safe to allow workers to face their bills backward. Manufacturers may certify their hard hat is safe to reverse wear, but employers must figure out if it’s safe to do in the workplace based on the hazards workers are exposed to.
Have a consistent policy in place for how you’ll handle requests. If you have many workers, it’ll be difficult managing individual approvals on a case-by-case basis. I recommend using work activities and work areas to determine whether workers can wear their bills to the rear. For instance, I’d allow workers to reverse-wear their hard hats if they were rigging and material handling loads from a crane’s hook or working in laydown yards without overhead falling object hazards.
In summary, you can allow your workers to turn their hard hats backward, but you’ll need to follow the guidance above to ensure it’s safe.
Key to remember
Workers can reverse-wear hard hats if the hard hat is certified by the manufacturer for reverse donning. The hard hat will have two arrows curving to form a circle if it is.
