master66... you are correct, there isn't an OSHA regulation that specifically addressses this issue.
But, as a compliance officer, I can tell you that Trumps "hit the nail on the head" (pun intended) with his comment:
I'm assuming that the hat testing is done with the brim to the front of the head.
That is exactly the point from an enforcement standpoint of this issue. ANSI Z89.1 standard essentially requires that the manufacturer test the hardhat in the manner it will be worn in the workplace. Most manufacturer's only submit their helmets to testing with the brim forward. However, having said that, a small handful do submit their equipment for testing from both directions.
A manufacturer must indicate in their instructions whether or not the helmet can be worn with the brim to the rear. If they do not have a specification for that in the instructions... you can not do it.
Just as an FYI, the employer would likely be in violation of one or more of the following OSHA standards if they are allowing employees to wear their helmets "backwards."
1926.21(b)(2)
The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.
1926.95(a)
Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.
1926.100(b)
Helmets for the protection of employees against impact and penetration of falling and flying objects shall meet the specifications contained in American National Standards Institute, Z89.1-1969, Safety Requirements for Industrial Head Protection.
If you are interested in how OSHA actually enforces this issue, there are two "Letters of Interpretation" specificially on this question. You can read them on-line at:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=243 65 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=207 66 [This message has been edited by safetygem (edited 03-03-2005).]
