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Scenario: You are the site safety manager for a large heavy industry facility. You have used adhesive stickers on hard hats to identify key individuals such as first responders and EMTs, as well as awards for workers achieving certain safety milestones. The stickers are well-received by employees and it is your belief that, in many instances, they wear them with pride.
The new corporate safety director pays you a visit and expresses significant concern that the workers are allowed and even required to have adhesive stickers on their hard hats. He demands that you remove them, not due to company policy, but rather because OSHA doesn’t allow them.
Question: Is he correct or does OSHA allow the use of adhesive stickers on head protection of any type?
Answer: In a letter of interpretation from Federal OSHA to Ms. Johanna Cohan in October 27, 2009, OSHA makes the following statements:
“Both 29 CFR 1910.132 and 1910.135 do not contain provisions that explicitly prohibit painting or the placement of adhesive stickers on helmet shells. However, the employer’s ability to comply with the existing requirements of these standards may be adversely affected by the painting or placement of adhesive stickers on the helmet’s shell.”
The letter goes on to reference 29 CFR 1910.132(a) which requires that PPE be “maintained in a sanitary and reliable condition”. The OSHA respondent states to ensure a helmet is, and remains, in a “reliable” condition, the helmet must be inspected prior to use for signs of dents, cracks, penetration, and any damage due to impact, rough treatment, or wear that might reduce the degree of protection originally provided, and used and maintained in accordance with the manufacturer’s instructions. Paints and stickers may eliminate electrical resistance and – depending on the location and quantity – conceal defects, cracks, penetration, and any damage that would be otherwise readily identifiable during the employee’s inspection to ensure reliability.
OSHA then goes on to state “For these reasons, painting or applying stickers must be performed in accordance with the manufacturer’s instructions, unless the employer can demonstrate that the altered protective helmet is equally as effective and protective as those meeting the requirements of Z89.1”.
As you see, OSHA falls just short of saying “no” and basically puts it back on the manufacturer as to whether paint and/or stickers are acceptable. So, what does the manufacturer say? We were able to find an article on the National Safety Council website from Jeanette Gaunce, the head and face protection product manager with E. D. Bullard in Cynthiana, KY. Ms. Gaunce states that they really don’t encourage the use of stickers, but should stickers be placed on the helmet, they should be at least three quarters of an inch away from the edge of the helmet, and the area covered should be kept to a practical minimum to permit regular inspection.
We took a look at the instructions that came with our hard hats here at the office and they read as follows “Do not use paints (unless approved in writing by manufacture’s name), solvents chemicals, adhesives, gasoline, or other like substances on this hat.”
Based on this information, it is strongly recommended that stickers not be used. If they are used they must stay away from the edge, and should be kept to a minimum.