Trim carpenter set up to work by himself with his hard hat parked at the door. Hmm… Please don’t hang your hat on the switch wiring even though it’s not hot, and don’t run your cord across the metal door frame unless you protect it. (Photo: Jan Thomas)

I keep a list of what I call “challenge questions.”  When I’m looking for a blog topic I can always find inspiration as well as frustration by looking at my list.  When I’m walking a construction site and encounter crews who have not worked with me before—and don’t already know my response, I’m often asked one of these questions.

Here is an example:  “So, I’ve always been told I don’t have to wear a hard hat if no one is working around me.  Why are you telling me different now?”

Those of you who have been reading my blog know my bottom-line answer to this and similar questions is – “Our company/site policy goes beyond OSHA standards.  In this case, our policy is to wear hard hats 100% of the time with only a few exceptions.”  It’s the part about “a few exceptions” that leads to long discussions, which I try to use as “teaching moments.”

I start by acknowledging that the main OSHA hard hat requirements are found in two places – General Industry’s §1910.135 & Construction’s §1926.100.  Both require employers to determine the need for PPE and sometimes this leads to the evaluation that there is no possible danger if a person is working alone, or in the cab of a well-protected piece of equipment, or under a cabinet fitting a fixture.  And, yes, OSHA said in 1983 that “where employees are not exposed to possible head injuries, head protection is not required by OSHA standards.”

Yet, typical hazards are not always anticipated, such as the hot electrical connection not seen yet touched by the worker’s head, or the rock that ricochets into the open window of the excavator’s cab, or the worker’s own dry wall hammer bouncing off a stud into his forehead.  Ouch.

Believe me, I’ve seen all of these happen more than once.  That’s why I try to convince my clients and all I contact in workplaces to wear their hardhats all the time (okay, except for maybe when they are sitting in the lunch trailer or in their car taking a nap).