June 25, 2002


Mr. Ken B. Harper
1120 S. Detroit Ave. #4
Russellville, AR 72801-6876

Dear Mr. Harper:

Thank you for your April 29 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs (DCP). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You are requesting information regarding the use of aluminum hard hats, which is addressed by the OSHA standard 29 CFR 1910.135, Head Protection.

Scenario: I deliver hardware parts to local industrial and construction sites. Prior to exiting my vehicle, these establishments or sites require that I don a hard hat before entering their property. I prefer to wear an aluminum hard hat. I have received numerous comments concerning the use of an aluminum hard hat versus a plastic hard hat.

Reply: In your situation, aluminum hard hats are acceptable. However, they would be unsafe in areas where you may come in contact with energized circuits. Information on head protection can be found at 29 CFR 1910.135, Head Protection, paragraph (b) Criteria for protective helmets, subparagraphs (1) and (2).

Subparagraph (1) references protective helmets purchased after July 5, 1994 and requires that they comply with American National Standards Institute, ANSI Z89.1-1986, American National Standard for Personnel Protection-Protective Headwear for Industrial Workers-Requirements or be demonstrated to be equally effective. Subparagraph (2) references protective helmets purchased before July 5, 1994 and requires that they comply with American National Standards Institute, ANSI Z89.1-1969, American National Standard for Industrial Head Protection or be demonstrated equally effective. You can purchase copies of the ANSI standards through ANSI at (212) 642-4900.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at www.osha.gov. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement] at (202) 693-1850.

Sincerely,



Richard E. Fairfax, Director
Directorate of Compliance Programs