Being smart about head protection

Across the country, contractors paid more than $1.3 million in fines during 2016 for not complying with OSHA Section 1926.100 head protection guidelines. Section 1926.100 requires contractors to provide protective helmets for workers in areas of possible head injury from impact, falling and flying objects or electrical shock and burns.
 
But there’s no clearly-stated OSHA mandate to wear hard hats at all times. The decision about potential danger is left up to site management. As a result, many contractors dictate hard hat use on all of their projects all the time, to err on the side of caution.
 
Inspectors enforce this standard aggressively. OSHA issued 627 citations during 627 inspections in 2016 for failure to comply, and alleged violators paid more than $1.3 million in associated fines. A prime cause for OSHA’s zeal is revealed in a Bureau of Labor Statistics report – head injuries account for nearly 1 of every 10 ten worker injuries.
 
Selecting effective head protection starts with reviewing the existing standards. 29 C.F.R. 1926.100 requires employers to provide head protection equipment that meets or exceeds the industry consensus standard ANSI Z89.1 (issued in 2009), to withstand top impact from small falling objects. Protect your workers with hard hats that meet or exceed this standard and make sure it is worn correctly so the shell can interact with the inside suspension to absorb energy from a blow to the head.
 
Be sure your hard hat is fit for duty
 
Hard hat maintenance is important for an effective head protection program. Workers should visually inspect their hard hat before and after every use. But superintendents should be involved if a hard hat cap is struck by a forcible blow of any magnitude. The hard hat shell and suspension should be replaced immediately, even if no damage is visible.
 
Here are some simple considerations to determine hard hat readiness:
 
Replace the hard hat when its shiny surface appears dull or chalky, the shell becomes brittle or cracks appear in the shell.
 
  • Replace suspensions at least every 12 months. Replacement could be sooner if the suspension becomes brittle, the cradling straps break or become worn or one or more of the mounts break off.
  • Manufacturers suggest replacement of the hard hat after no more than five years. Where worksites include higher exposure to temperature extremes, sunlight or chemicals, hard hats should be replaced automatically after two years of use. The service life of a hard hat starts when it is placed in use, not when it’s manufactured. It’s also suggested to not remove the manufacturer’s tag that is inside the hard hat. Contractors often add the initial date of service to the tag.
  • Carefully inspect the areas on which stickers are attached to the shell. Stickers must not cover up any damage or cracks. Stickers should be placed at least a half an inch above the brim to avoid any possibility of creating an electrical arc due to the metal content in some stickers. And stickers should not be used for purely decorative purposes.
  • Store hard hats where they cannot be exposed to the sun’s rays (like through the back window of a truck). UV rays can cause significant damage to hard hats.
 
Not made for the shade
 
Hard hats provide excellent protection from impact hazards, but are only marginally helpful in protecting concrete workers from another inherent jobsite danger – sun exposure. Hard hats protect only the face and front of the neck but leave the ears and the rest of the neck exposed to the sun’s rays. In recent years, workers have been encouraged to add protective clothing to reduce exposure to sun rays.
 
Want to dig deeper?
 
Head Protection: OSHA maintains a web site that provides up-to-date information on the personal protective equipment (PPE) hazards addressed in specific standards for the construction industry. The site highlights OSHA standards, Federal Register notices, directives, and letters of interpretation.
 
Eye and Face Protection
 
A closer look at eye and face protection
 
Contractors paid more than $2.6 million in OSHA fines (third highest of all violation categories) for allegations associated with failing to protect their employees’ eyes and faces in 2016. But these fines are a fraction of the total costs associated with this failure. According to OSHA, eye injuries cost employers more than $300 million per year in lost production time, medical expenses and worker’s compensation claims. And unfortunately, OSHA statistics also indicate that construction workers have a much higher rate of eye injuries per employee than any other industry.
 
Concrete crews frequently share jobsites with other subcontractors whose hammering, grinding, welding and sawing causes abrasive particles to become airborne. Plus, common concrete operations like mixing mortars, sawing joints, drilling anchor holes, tearing out concrete and applying coatings can generate airborne face and eye hazards. And workers need to protect their eyes from UV rays too.
 
OSHA standards require contractors to give crews appropriate eye and face protection for each task. A wide range of protective equipment is needed for concrete work, so meeting this requirement is no simple task. So, when you begin reviewing your job safety analysis documents, contact your HD Supply White Cap Account Manager to help ensure your procedures comply with current best practices.   
 
The 2016 OSHA eye and face protection standards were designed to make sure workers receive up-to-date eye and face protective equipment. Prior to 2016, OSHA referenced the ANSI Z87.1-1968 standard for eye and face protective equipment. In 2016, this reference was deleted, and in 2016 was replaced by three consensus standards ANSI/ISEA Z87.1-2010, ANSI Z87.1-2003 and ANSI Z87.1-1989 (R-1998).
 
When the change occurred, OSHA confirmed that contractors wouldn’t have to replace older protective equipment. The rule just updates the OSHA standards with current national industry standards. It’s intended to give employers up-to-date guidelines for selecting and using eye and face protection. If you aren’t sure that your equipment complies with OSHA standards, your HD Supply White Cap Account Manager may be able to help.
 
Contractors can keep crews focused on eye and face protection by creating and using a written program featuring site-specific procedures. The eye or face protection requirements for a concrete placing crew are different than those for repair technicians chipping out distressed concrete. Supers must recognize the differences and help each worker select the right protection.
 
And every training experience should be documented. OSHA regulations require including documentation showing how selection, medical evaluation, fit testing, training and use and care of PPE were done. This includes safety glasses, goggles and face or welding shields. The program must be administered by a trained individual who is qualified and knowledgeable in eye and face protection.
 
Following a four-level approach to eye care helps keep workers safe.
 
Level 1
 
Nonprescription and prescription safety glasses might look like regular glasses, but the lenses and frames are much stronger. They provide protection in working conditions where dust, chips or flying particles are present. Only safety glasses with a Z87 mark on the lens or frame meet the required ANSI standards.
 
Safety glasses with polycarbonate lenses offer more protection, but it’s also important to buy safety glasses featuring high quality optics. Low quality lenses can cause eye fatigue. When protection in windy and dusty areas is needed, glasses equipped with additional side protection are best. But now workers are moving to a relatively new style of sealed eye protection. These sleek, low-profile safety spectacles fit like a goggle and keep airborne debris away from eyes.
 
When concrete crews work outdoors they’re frequently exposed to direct sunlight and glare. These common hazards are routinely overlooked in safety audits, but they can contribute to unsafe conditions and lower productivity. Overexposure to direct and reflected light leads to headaches, fatigue, redness, dryness and irritation of the eyes. Safety glasses equipped with standard gray, brown or mirrored lens can help.
 
Level 2
 
Safety goggles protect eyes and areas of the face surrounding eyes from impact, dust and chemical splash. They envelope the eye and mid-face area, shielding against hazards coming from any direction and can be worn over non-safety prescription glasses.
 
Level 3
 
Face shields protect a worker’s entire face. They can be worn over safety glasses or goggles to reduce exposure to flying debris, chipping slag and overlay materials.
 
Level 4
 
Special equipment like helmets or goggles with special filters to protect eyes from radiation exposure are used for tasks like welding. Consider full-face respirators for severe conditions like sandblasting or acid etching.
 
Identifying a new eye danger
 
Believe it or not, electronic devices pose a significant risk to worker eyesight. Laptop computers, tablets, smartphones, LEDs and CFLs emit blue light that can cause anything from eye discomfort to potential retinal damage. These short, high-energy light waves create a glaring effect on the eyes that can
lead to symptoms like dry eye, blurred vision, headaches, nearsightedness
and eye fatigue.
 
Computers and electronic devices are gradually becoming common jobsite tools. To avoid chronic digital eye strain, remind your employees of these precautions:
 
  1. Keep the computer roughly 30 inches away from their eyes.
  2. Rest eyes every 20 minutes using the 20-20-20 rule: Every 20 minutes, look at something at least 20 feet away for at least 20 seconds.
  3. Remember to blink frequently. This simple action reduces dry eye and maintains eye health.
 
Want to dig deeper?
 
Eye Protection: The Electronic Library of Construction Occupational Safety and Health (eLCOSH.org) has more than 50 training resources on eye protection developed by safety professionals. eLCOSH.org was developed to provide accurate, user-friendly information about safety and health for construction workers, employers, and safety professionals.