Robert Miller • January 27, 2025

Hard Hats

Hard Hat Replacement

Doing some research on our current model of hard hat, and it mentioned that the

shell lasts for 5 years, but the suspension is only a year.

 I was wondering if you had any

experience with this.

 I guess my question is: how seriously does OSHA take this?

 I don’t

mind changing out suspensions on a yearly basis, but that seems unnecessarily frequent

to me.

 I realize it is the manufacturer spec, so we want to use that for our standard, but I’m

guessing many companies aren’t tracking items such as this and their corresponding

expirations.

 Or, leaving it up to employees to do the necessary tracking.

Answer:

Rule: 437-003-0134(2)(a)

Division 3, Subdivision E, Personal Protective & Life Saving

Equipment

(2) Equipment.

(a) Where employees provide their own protective equipment, the employer is responsible

to assure its adequacy, including proper maintenance, and sanitation of such equipment.

(b) All personal protective equipment must be provided, used, and maintained in a sanitary

and reliable condition.

(c) Defective or damaged personal protective equipment must not be used.

(d) Each employer must maintain a regular system of inspection and maintenance of

personal protective equipment furnished to workers.


It was added, when setting up a PPE inspection program, reviewing  what the

manufacturer says is a good starting point, then build upon it. If you can show that you

have a good PPE inspection system in place that considers how the PPE is actually used

and what it has been exposed to, under certain situations you can go outside what the

manufacturer guidelines are and Oregon OSHA would not be able to allege a violation

simply because you exceeded the PPE manufacturer’s recommendation or written

limitations. However, you could still be cited if the hard hat or safety helmet  is damaged

and does not provided the necessary protection even though it has not reached the

replacement cycle established by the manufacturer.  From Oregon OSHA


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