Are adhesive stickers or paints allowed on protective helmets (hard hats)? The specific requirements for head protection (hard hats) are outlined in 29 CFR 1910.135, which incorporates by reference American National Standards Institute (ANSI) Z89.1-1986, Z89.1-1997, and Z89.1-2003. However, 1910.135 does not contain wording that explicitly prohibits painting or the placement of adhesive stickers on hard hat shells.
OSHA standard 29 CFR 1910.132(a) requires that PPE be “…maintained in a sanitary and reliable condition…” To ensure a hard hat is and remains in a “reliable” condition, the hard hat 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. 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. Another concern is that paints, thinners, and solvents may also attack or damage the shell of a hard hat and reduce protection.
For these reasons, painting or applying stickers must be performed in accordance with the manufacturer’s instructions. Hard hat manufacturers usually provide very specific instructions regarding paints, stickers, or decals that will not negatively affect the performance of a protective helmet. OSHA would consider painting or placing adhesive stickers acceptable if the manufacturer authorizes the alteration or the employer can demonstrate that the reliability of the helmet is not affected by the paint or the adhesive on the stickers; and the paint or placement of stickers would not reduce the ability to identify defects (i.e., use of see-through stickers) or other conditions that would indicate a reduced reliability.
It is permissible to use pressure-sensitive stickers or tape with self-adhesive backing AS LONG AS THEY ARE NOT closer than 1/2” from the helmet’s edge. MSA’s studies indicate that such stickers or tape in such locations will not affect burn-through (i.e. dielectric classification) or a MSA helmet’s structure. However, because it is impossible for MSA to test all pressure-sensitive adhesives, caution should still be taken when using such materials. Also, be sure that when stickers or tape are applied, they do not cover any helmet damage.
The use of self-adhesive stickers by individual users to “personalize” their hard hats or for other marking or identification purposes is a common practice. Because of the type of adhesive used in typical pressure-sensitive stickers, there is very little potential for chemical interaction between the adhesive and the helmet shell, and their use would not be expected to negatively affect the performance of the helmet under normal conditions. Adhesive stickers should be placed at least ¾” away from the edge of the helmet, and the area of the helmet covered in this way should be kept to a practical minimum to permit regular inspection of the helmet shell for signs of damage from use or aging.
The use of self-adhesive stickers for identification purposes is a very common practice nowadays. There is very little or no interaction between the adhesive, on pressure sensitive stickers, and the shell of the hard hat because of the type of adhesive or glue used. Of course the use of adhesive stickers should always be kept to the minimum in order to permit regular inspections of the hat’s shell for any signs of damage from use and/or deterioration…
Do not paint, imprint, apply decals or stickers without the written permission of North Safety Products. Paint can attack the shell and cause degradation and stickers can cover cracks or damage on the shell.
Stickers and labels may be added to the hard hat shell, as long as none is over 0.5 inches from the bottom of the hard hat. Keep in mind that adding stickers and labels to a hard hat makes it much more difficult to inspect the shell for cracks and damage. Pay close attention to the areas around and under the labels or stickers. You may have to remove the suspension and carefully check the underside of the hard hat shell in order to properly inspect the site of the label or sticker. d. Painting the hard hat shell: Paint contains chemicals that will interfere with the performance and integrity of the hard hat shell. Do not, under any circumstances, paint the shell of a hard hat.
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