Head protection

A HARD-HEADED CHOICE

By Hayley Chandler

There is new and better head protection available, but Canadian regulations are all over the map on what’s required. How do you decide?

If you want the best head protection available, be glad that you’re Canadian. The Canadian Standards Association, or CSA, was the first group in North America to set standards for lateral impact of protective headwear. But if you’re not convinced that you need that type of protection, or you’re unhappy with the way manufacturers have chosen to provide it, you’re not alone. Canadian workers and employers have been slow to accept the latest advances in hard hat technology.

Shopping for hard hats just isn’t what it used to be. The traditional hard hat design did not change significantly for over 40 years. Then, just a few years ago, standards changed and new features were introduced. Much of the country’s occupational health and safety legislation has not changed to reflect this and many workplaces are finding it hard to decide what they should be providing for their workers.

The newest CSA standard, Z94.1-92 Industrial Protective Headwear, was published in 1992 and significantly improves the level of protection provided by hard hats. The old standard, or Z94.1 M1 1977 hats, "were designed primarily to protect against a top dead centre hit," says Doug McVittie, manager of program development for the Construction Safety Association of Ontario (CSAO). They provided little or no protection from blows to other parts of the head. The new standard addresses this, and CSA certified hard hats now provide protection against impact anywhere on the surface of the hat.

However, as McVittie acknowledges, "laterally flying missiles aren’t that common in construction. Things tend to fall straight down." For this reason, some people feel the new impact requirements are overkill. What they’re overlooking, McVittie says, is that impacts don’t just occur when objects hit workers. Fatalities and serious head injuries frequently occur when workers fall and strike their heads. "That’s the rationale largely behind the changes that were made to the CSA standard," he says. "A lot of people don’t understand that."

The second major difference in the new CSA standard was made following that same thinking. It was not uncommon for the old model of hard hat to come off when workers tripped or bent over, or if they were struck from the side. When they fell, the hats often flew off before their heads hit the ground. The CSA has addressed this by setting a standard for "passive retention", or the hard hat’s ability to stay on the wearer’s head. The rain gutter found on the old hats was one of the victims of the need to meet the new retention standard. The new hats generally don’t have one because a gutter that catches rain also tends to snag falling objects and could dislodge the hat.

No holes barred

When the most recent standard was introduced in 1992, the CSA also adopted a new method of testing for electrical protection. And that new testing method will likely have an impact on future design. The old dielectric test method used water inside and outside the hat as contacts for the electrodes. The electric current would pass through the water via even the smallest openings or holes and because of this, hard hats could not have ventilation openings. Now the test uses metal foil on either side of the hat. This probably means we’ll be seeing vented hats in the future. However, further research is necessary to determine how to introduce such openings without interfering with the shell’s protective capabilities.

There used to be four classes of CSA-certified protective headwear and two types: a hat and a cap. The classification system has been simplified and there are now only three classes:

* Class G (General Usage) headwear protects against impact and penetration. It is manufactured from nonconducting materials. However, it must never be considered to be part of a protective system against electric shock.

* Class E (Electrical Trades) meet the same impact and retention standard as Class G, but give a higher level of protection against electrical contact. Although they are made from a high-grade nonconducting material, these hats are not intended to be used as a primary barrier to prevent contact with live electrical apparatus.

* Class C (Conducting Headwear) only provides protection against impact and penetration. (Class C is also what a class G or E hat becomes if you add any metal part, such as a clip for holding a light.)

New features

So what does all this mean in terms of design? What are the new hard hats like? The answer depends on who makes the hat. The CSA sets a standard for performance. The association does not specify how to achieve those standards. Manufacturers develop their own designs, then submit samples of their hats to the CSA for testing. If they meet the testing requirements, the CSA will certify the hats. After publication of the new standard in 1992, manufacturers could either design a whole new hard hat or modify their existing designs. Approaches have varied, but most manufacturers have stuck with the traditional look.

Most have met the standard for side impact protection by using a liner inside the hat to absorb energy. Most of these are foam but one company has used a corrugated plastic liner to allow air to circulate between the head and the shell.

The most common approach to meeting the retention standard has been use of a ratchet to adjust the suspension (the harness-like part inside the hat that holds it on the head) to fit the worker. "All you do is grab a knob at the back of your helmet and turn it clockwise to tighten it," explains Larry Baker, senior loss management advisor for Syncrude Canada Ltd. in Fort McMurray, Alberta. "When you use a ratchet, you can get very precise sizing of the hat," says Ray Mullin, a regional sales manager for Arkon Safety Equipment and a member of the CSA technical committee on Industrial Protective Headwear. However, manufacturers also offer pin-lock suspensions that meet CSA’s retention requirements. With this type, the suspension size is adjusted by pushing a set of pins through corresponding holes in the head strap. There are also hard hats available with chin straps; they, or their equivalent, are actually required under some circumstances in some Canadian oh&s legislation. (See "Hard Hats and the Law, page xx.)

The most innovative hard hat currently available was developed the Construction Safety Association of Ontario. "It looks radically different from other hard hats," says McVittie. Instead of using a liner for impact protection, it has 56 fins positioned around the entire outside circumference of the hat. They’re very thin and about three-eighths of an inch deep. "If you fall and strike your head against an object or an object comes in and strikes you from the side, those fins will deform and consume energy," McVittie explains. "It’s kind of like the crushable parts of your car. The hood buckles, the fenders buckle, the bumper buckles and the amount of energy that comes to you in the passenger compartment is greatly reduced because energy has been consumed in deforming all these other structures."

Consumer response

Although they probably like the idea of improved protection, many Canadian workers have not liked the new hats. When they were first introduced, the negative comments most commonly heard about the new styles were that they were too heavy, too hot and too expensive.

Since then, most manufacturers have made some refinements to their designs. "They’ve made them lighter," says Mullin. Some manufacturers have put grooves in the foam liner to improve air circulation and make the hats cooler. "Since they were originally introduced, the cost of the hat has come down," he adds. The price range for the new models was about $35 to $60. They now usually range from around $10 for a basic hat with a replaceable styrofoam liner to $35 for the Cadillac of head protection. However, the old model typically costs only $5 to $10. "The public needs to understand there’s a reason for the increase in price," says McVittie. "You have to pay for research, development, tooling and testing."

Manish Gupta, product market specialist for MSA Canada Inc. in Toronto, a member of the CSA Technical Committee on Industrial Protective Headwear, adds, "Workers must recognize that a hard hat is just as important a piece of equipment as, say, a pair of safety boots, and it’s worthwhile paying the extra money for a better hard hat."

The American ANSI standard Z89.1-97 was revised just last year and now has requirements for two levels of head protection. One level is similar to the old CSA standard and the other is similar to the new standard, with its requirements for lateral impact protection. This may increase the acceptance and use of lateral protective headwear throughout North America. However, "given that ANSI has now come out with two levels, a lot of manufacturers are going to continue making the old style," says Kevin MacKenzie, a project manager for the CSA. (Many Canadian jurisdictions allow the lower-level protection under the ANSI standard. These hats, while providing the same protection hard hats always gave workers, do not carry a CSA label, since the CSA certifies only its new, improved standard.)

It’s important to check the current regulations in your jurisdiction (provincial, territorial or federal) to determine the requirements for compliance. Note that several jurisdictions have different regulations for industrial, mining or construction workplaces. But most observers agree that hats certified to the newest standard offer the best protection, even if the letter of the law does not yet require them.

The new standard is "a big improvement on the old standard," observes Gupta. "Canada was probably the first in the world to come out with a lateral impact standard. The U.S. has now copied that and I think probably more countries will," he says. "For a change we’re ahead of the game. We’re setting the standard rather than following it. I think a lot of workers have to recognize that this is not something to fight against. It’s something that’s been put in place for their benefit and is something they should embrace." 

Hayley Chandler is associate editor of safety purchasing for OHS CANADA.

PROPER USE AND MAINTENANCE

Workers should consider the following guidelines for use and maintenance of protective headwear:

* "Wear the peak forward at all times," advises Robin Kotyk, manager of Advisor Services North for the Alberta Construction Safety Association. It protects from the sun and wind and it can protect your face from falling objects.

* Don’t store cigarettes, lighters, pens, measuring tapes or any other items between the suspension and shell of a hard hat. "If you put anything between the shell and suspension you will affect the cap’s ability to protect you," explains Manish Gupta, product market specialist for MSA Canada Inc. The stitching in the harness is designed to tear out at a controlled rate to absorb energy. Anything between the harness and the shell would interfere with this action.

* "Hard hats should be inspected on a daily basis," says Kotyk. Replace your hat if the shell is cracked, dented, penetrated, stiff or brittle. You can test for brittleness by pushing the sides of the hat inward to deform the shell slightly. The let go, and note whether it returns immediately to its former shape. If it doesn’t, or if there is cracking or crazing, it’s time for a new hat. If the suspension is torn or broken, replace it.

* Hard hats are designed to absorb some of the energy from impact through partial destruction of their component parts. For this reason, discard a hard hat that has received any severe blow even if there is no apparent damage. Don’t toss hard hats around, says Baker.

* Any decals applied to the hat must be compatible with the surface material. Be sure the glue on stickers doesn’t degrade the plastic. Note that aluminum or metal decals undermine the electrical protection of the hat. Consider that stickers could hide cracks in the shell, says Larry Baker, senior loss management advisor for Syncrude Canada Ltd.

* Don’t leave a hard hat on the rear window shelf of a vehicle because the hat can become a dangerous missile if you brake suddenly or in the event of a collision.

* Don’t store the hat where it will be exposed to direct sunlight for long periods of time, since the heat and ultraviolet light can degrade the shell material.

HARD HATS AND THE LAW

Head protection is required in every Canadian jurisdiction for workers who may be exposed to a hazard of head injury. However, the regulations differ widely from province to province; many have different regulations for different industries; and some are more complicated than others. Anyone responsible for compliance with the safety legislation should take a few minutes to study carefully the requirements in his or her jurisdiction and industry.

However, a number of interesting requirements of the various regulations, from coast to coast, stand out.

* Several provinces (including Alberta, Saskatchewan, Ontario and Newfoundland), have an unusual provision in their safety legislation when it comes to personal protective equipment. It states that if an employer sets a standard for a given type of protection -- new standard hard hats, for example -- it becomes a legal duty for the workers to wear them. The employer’s policy essentially becomes the law as long as it meets the minimum requirements in the legislation -- but it can go beyond the written legal requirements and set a new, higher standard. Employees are then required by law to comply with the employer’s standard.

* The fact that a new, better hat is available has "due diligence" implications. In order to be "duly diligent" -- and to demonstrate the fact in court, if required -- an employer must take all precautions reasonable in the circumstances for the protection of a worker. An employer who has not required workers to use hats that provide the best available protection may have difficulty proving this.

* British Columbia’s new Occupational Health and Safety Regulation allows the new standard hats, old standard hats (with an ANSI Z89.1-1986 designation, since the CSA no longer certifies this type of hat), Japanese standard hats (which incorporate a chin strap) and "any other standard acceptable" to the Workers’ Compensation Board. However, the regulation also calls for "chin straps or other effective means of retention" when a worker is more than three metres off the ground or "exposed to high winds or other conditions that may cause the loss of the headgear." It does not specify what the "other effective means" are; but the improved retention capabilities of new standard hats would seem to be meet the requirement.

* The Yukon, Prince Edward Island and Newfoundland refer to Z94.1 without specifying a date. Since the current CSA standard -- really the only CSA headwear standard in effect -- is the 1992, or new standard, Z94.1-92 would seem to apply. (It’s a good idea to get an interpretation from the ministry or department of labour involved; the previous standard may still be considered acceptable for the time being.) The Yukon also requires "chin straps or other effective means" to ensure retention of the hat in "high winds or other conditions" that might cause the loss of the headgear. In PEI, the regulations also "recommend" -- but do not require -- that headgear be replaced every five years, and the suspension or harness be replaced annually. (This is most likely a reference to the five-year lifetime associated with previous CSA standards.)

* Alberta puts the onus on employers to assess the risk much more directly than any other jurisdiction. It specifically requires the new standard "when a significant risk of lateral impact to the head exists". It also states that the old standard is acceptable in other cases. Also, Alberta has an unusual clause allowing employers to dispense with hard hats if it is "impractical during a particular work process" as long as workers revert to wearing hats as soon as they complete the work process. It also requires hats worn by loggers or traffic signalers to be "blaze or fluorescent orange or red" in colour.

* Current Saskatchewan legislation requires "approved" safety headwear, and defines the word as "approved by an agency acceptable to the director for use under the conditions prescribed". It also includes a requirement for a "suitable liner when it is necessary to protect a worker from the cold" and "a retention system... in conditions that may cause the headwear to dislodge". As well, it calls for hats to be "fluorescent orange or other high visibility colour" where the workers is engaged in forestry or sawmilling, or if "visibility of the worker is necessary".

* In Ontario, the Industrial Regulation states that "where the hazard of head injury exists, head protection appropriate in the circumstances shall be worn." The legislation notes that hats that comply with CSA Z94.1-92 (the new standard) comply with the intent of the regulation; however, it does not say that hats meeting other standards (such as the previous CSA, either of the current ANSI standards and possibly others) are not acceptable.

Ontario’s Construction Regulation requires "adherence to Class B requirements of the Canadian Standard’s Association Standard Z94.1 M1 1977 Industrial Protective Headwear complies with the intent of this section." Unfortunately, that’s a reference to the old standard, which is no longer in effect.

"The entire set of construction safety regulations are up for review," says McVittie. Proposed revisions "will refer specifically to the 1992 CSA Class E level of protection for construction workers in Ontario," he says. "We’re [the CSAO] urging the ministry to reference the CSA standard in other regulations as well," he says.

Where does that leave Ontarians in the meantime? "We don’t have the ability to require it, but certainly our policy is now to encourage the parties to use Class E," explains John Vander Doelen, provincial coordinator of the industrial health and safety program for the Ontario Ministry of Labour. And "our performance oriented requirement would allow an ANSI hard hat to be used because the performance characteristics would be met," he says.

* Nova Scotia requires a hard hat "manufactured for the purpose of preventing" head injury. Department of Labour information specialist Cathy Riley points out that this is interpreted to mean CSA approved.

* The Northwest Territories, Manitoba, New Brunswick, Quebec and the federal jurisdiction all refer to the 1977 CSA standard; New Brunswick and the Ontario Construction Regulation even require "Class B, Type 2" headwear. The standard has been updated since 1977, and, presumably, any later standard headwear would comply with legislation in those jurisdictions. There is a curious legal contradiction involved: Since the 1977 standard hats still carried a five-year expiration date, the last of them would need to have been replaced long ago, and, thus could not now be in compliance with the very regulations requiring them!

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