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OSHA will ask the question: “Does the wearing of the hard hat backwards meet the requirements of ANSI Z89.1, 1969—Safety Requirements for Industrial Head Protection?” In other words, is the hard hat an employee is wearing backwards tested with the headband backwards by the company that manufactured it? If not, then it is not being worn properly and OSHA could, if they chose to, write a citation.
This practice is so widespread, hard hat manufacturers are now making hard hats with reversible head bands that have been tested both ways. The 360 degree brimmed hard had is also gaining popularity.
The OSHA document addressing this issue is OSHA’s letter of interpretation: 7/22/1992 — The use of head protection at construction sites.