OHS Code Explanation Guide

Published Date: July 01, 2009
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Part 18 Personal Protective Equipment

Section 234 Industrial headwear

Subsection 234(1)

The OHS Code does not require all workers under all circumstances to wear industrial protective headwear i.e. hard hats. Only if there is a foreseeable danger of injury to a worker’s head at a work site is industrial protective headwear required. The decision to require workers to use industrial protective headwear should be based on the results of the hazard assessment required by section 7 of the OHS Code.

For compliance purposes, industrial protective headwear intended for use where there is a significant possibility of lateral impact to the head must meet the requirements of CSA Standard CAN/CSA-Z94.1-05, Industrial Protective Headwear, or ANSI Standard Z89.1-2003, American National Standard for Industrial Head Protection, for Type II head protection. The headwear must be of  the appropriate Class for the type of work being performed.

Industrial safety headwear has traditionally been designed and tested to provide protection from an impact directed more or less downward onto the top of the head. The 1992 edition of CSA Standard Z94.1 introduced a new requirement for protection of the head from an impact landing on the side of the head. This was in response to injury studies that indicated a significant incidence of injury due to people being struck on the side of the head by objects, even when wearing safety headwear. According to the Standard, a lateral impact occurs when an object strikes the headwear from any direction other than directly above. All protective headwear that meets the requirements of this Standard provides lateral impact protection.

The 1997 edition of the referenced ANSI standard added requirements specific to lateral impact, creating a new Type II category for head protection.

CSA Standard

CSA Standard Z94.1-05, Industrial Protective Headwear, applies to headwear intended to protect the heads of industrial workers. The Standard defines the areas of the head that are to be protected and includes basic performance requirements for impact protection, object penetration, stability and dielectric properties (the ability of a material to resist the passage of electric current).

The Standard divides protective headwear into three Classes according to its intended use:

(a) Class G (General Use) – this Class is intended to provide workers with protection against impact and penetration. This headwear is non-conducting and must pass the 2200 V dielectric-strength test specified for Class G headwear. Although this class of protective headwear is manufactured from non-conducting materials, it must never be considered to be part of a protective system against electric shock. This protective headwear provides limited protection against electric shock following accidental contact between the headwear and exposed energized electrical sources.

(b) Class E (Electrical Trades) – this Class is intended to provide workers with protection against impact and penetration. This headwear is non-conducting and must pass the 20,000 V dielectric-strength test specified for Class E headwear. Although this class of protective headwear is manufactured from high grade non-conducting material, it must never be used as a primary barrier in a protective system designed to prevent contact with live electrical apparatus. This headwear provides improved protection against electric shock following accidental contact between the headwear and exposed energized electrical sources.

(c) Class C (Conducting Headwear) – this Class is intended to provide the user with protection against impact and penetration only.

Protective headwear meeting the CSA requirements may have a brim around the entire circumference of the shell or have a partial brim with a peak.

ANSI Standard Z89.1-2003

Type II helmets that meet the 1997 or 2003 editions of ANSI Standard Z89.1, American National Standard for Industrial Head Protection, may also be used at the workplace. The ANSI Standard applies to protective helmets intended to provide limited protection for the head against impact, flying particles, electric shock or any combination of these hazards.

The Standard divides protective helmets into two types and three classes according to their intended use. Type I helmets are intended to reduce the force of impact resulting from a blow only to the top of the head. Type II helmets are intended to reduce the force of impact resulting from a blow that may be received off-centre or to the top of the head. The three classes are as follows:

(a) Class G (General) – this Class is intended to reduce the danger of contact exposure to low voltage conductors and must pass the 2200 V dielectric-strength test specified for Class G helmets. These helmets are used in mining, construction, shipbuilding, tunnelling, lumbering and manufacturing. The previous 1986 edition of the standard classified such helmets as Class A.

(b) Class E (Electrical) – this Class is intended to reduce the danger of contact exposure to high voltage conductors and must pass the 20,000 V dielectric-strength test specified for Class E helmets. This Class of headwear is used extensively by electrical workers. The previous 1986 edition of the standard classified such helmets as Class B.

(c) Class C (Conductive – no electrical protection) – this Class is designed specifically for lightweight comfort and impact protection. This Class is usually manufactured from aluminum and offers no dielectric protection. Class C helmets are used in certain construction and manufacturing occupations, oil fields, refineries and chemical plants where there is no danger from electrical hazards or corrosion. They are also used on occasions where there is a possibility of bumping the head against a fixed object.

ANSI types and classes are combined to provide products classified as Type I, Class G or Type II, Class E, etc. Helmets meeting the ANSI requirements may have a brim around the entire circumference of the helmet shell or have a partial brim with a peak.

Class of headwear to be worn

An electrician working only on “residential type” circuits of 240 volts or less may wear headwear classified by CSA as Class G or E, or classified by ANSI as Class A or B. Headwear having one of these classifications has a dielectric-strength test rating of 2200 volts. While this upper voltage limit around residential type circuits may seem conservative, it takes into account the effects of accumulated dirt on the headwear and wear and tear of the headwear material.

Electrical utility workers, electricians and other workers who work on circuits having voltages exceeding 240 volts must use headwear classified by CSA and ANSI as Class E. Headwear having this classification has a dielectric test rating of 20,000 V.

Workers who are not exposed to energized electrical equipment in the normal course of their work may use headwear of any Class, including headwear classified by CSA and ANSI as Class C (Conductive). If workers receive special training and are given work assignments requiring work near exposed energized electrical sources, they must have and wear headwear with the appropriate dielectric rating. For example, workers assigned to clean and paint utility poles may be exposed to electrical hazards and should therefore wear electrically protective headwear.

Protective headwear use

Industrial headwear is designed to absorb some of the energy of a blow through partial destruction of its component parts. Headwear that has experienced a severe impact should be replaced even though it may not appear to be damaged. Unless permitted by the manufacturer, headwear must not be painted or cleaned with solvents, and the adhesive used on decals applied to the headwear must not interact with the headwear material to reduce its strength.

For maximum head protection, the headwear’s shell and suspension should be checked according to the manufacturer’s instructions before each use. If the shell or linings are found to have a crack, dent, or hole, or if the suspension is torn or broken, the headwear should either be discarded or the particular part replaced with an identical part from the original manufacturer.

Unless permitted by the manufacturer, headwear users should not carry or wear anything inside their protective headwear. A cap or object may contain metal parts that reduces the dielectric protection provided by the headwear. A clearance distance must be maintained between the wearer’s head and the headwear’s shell for the protection system to work properly. A cap or other object may limit this clearance. Products such as fabric winter liners or cotton sunshades are designed to work in conjunction with the headwear and their use is acceptable.

Unless permitted in the manufacturer’s written instructions for use, protective headwear must not be worn backwards. All headwear is tested while in its intended forward-facing direction. Very few models of headwear have undergone testing in both the forwards- and backwards-facing directions. Those products that have been tested and passed testing in both directions have usually required their suspension system to be reversed. In this case, only the shell of the headwear is backwards — the brow pad of the headband sits against the forehead and the extended nape strap is at the base of the skull.

Subsection 234(1.1)

A small utility vehicle is a small vehicle designated for off-road use, equipped with a bench-type seat and a steering wheel, and designed to transport more than one person. There are a variety of manufacturers and they are known by a variety of trade name including Polaris Ranger, Pug Back Forty, Bobcat Toolcat, John Deere Gator, Kawasaki Mule, Toro Twister and CubCadet Volunteer.

If a small utility vehicle is equipped with seat belts and rollover protection, riders are not required to wear a safety helmet. In such cases, the employer’s procedures must require that riders use the seat belts.

Employers need to make sure that what looks like rollover protection is not simply part of a roof canopy. Confirm with the product manufacturer that the structure provides true rollover protection to occupants of the machine. Rollover protection devices bear a tag or decal, permanently affixed to the device, usually located on the device where it attaches to the frame of the machine.

Subsection 234(2)

If the possibility of lateral impact to the head is unlikely, the headwear can meet the requirements of

(a) CSA Standard CAN/CSA-Z94.1-05, Industrial Protective Headwear, or
(b) ANSI Standard Z89.1-2003, American National Standard for Industrial Head Protection.

In assessing the “possibility of lateral impact to the head”, employers should consider the likelihood of a lateral impact occurring. Headwear providing lateral impact protection must be used if a lateral impact is foreseeable and likely based on the type of work normally performed. Examples of typical workplace situations requiring such protection include a workshop in which multiple overhead cranes are used to transport loads around the shop, workers involved in the felling of trees, workers involved in tree care operations (see Part 39) and workers involved in processes in which substantial flying objects or debris are generated.