Published in the December 2013 Coal USA Magazine

Is that hat MSHA certified?

Since the introduction of the certified Low Pro in 2009, I’ve answered that question countless times. The first thing everyone needs to know about hard hat certification is this: the Mine Safety and Health Administration does not certify hard hats!

Unlike so many other things in the mines that have an MSHA approval number, hard hats do not have an explicit approval from analysts at MSHA. MSHA has no hard hat testing facility, doesn’t do annual audits of manufacturing facilities and processes, nor does it write or alter the standard for such testing and auditing.

However, do not take these facts to mean that MSHA is indifferent to what hard hat you wear to work – it most certainly is not.

Instead of recreating the wheel on hard hat certification, MSHA defers to other established standards for hard hat safety. The most common standard governing hard hats in any industry in the US is the American National Standards Institute’s ANSI Z89.1 standard.

Within the ANSI Z89.1 standard, there are different classes and types that go from “bump caps” to very heavy-duty impact absorbing hard hats.

In Public Information Bulletin P11-36, MSHA clarified its guidance on what qualifies as a “suitable hard hat” as required by 30 CFR Section 75.1720(d) and Section 77.1710(d) in the federal law. That PIB can be found on the MSHA website at http://www.msha.gov/regs/complian/PIB/2011/pib11-36.asp.

The most important things to keep in mind when either choosing your own hard hat or creating a policy for hard hats at your mine are these:

A) Does the hat have a sticker in it that says ANSI Z89.1?

Truly, the only hats you should be using underground should have a sticker that says “ANSI Z89.1 2009 Type I, Class G”.

This is the latest standard for the heavy-duty underground hard hat and can be found in an MSA Comfo-Cap or a Low Pro, which are the two most common safe and legal hard hats in the underground coal mining industry.

B) Has the hat or liner been modified in any way?

People in the coal mining industry commonly alter hard hat liners to make them lower.

It also used to be fairly common for people to “cut down” hard hat shells until the certified Low Pro came on the market in 2009, presenting a safe option for those who want to wear a lower profile hard hat. ANSI certified hard hats have to pass rigorous testing.

Altered liners and shells have not passed such testing, therefore, they cannot be trusted to protect you when you really need them.

C) How old is your liner and shell?

New hard hats should be logged into service by the operator when they are first worn and, according to the standard, the applicable component should be removed from service if: 1) The shell is older than five years; 2) the liner is older than six months; or 3) either the shell or liner show any signs of damage including cracks, holes, tears or similar.

Just because a hard hat is certified does not mean that it will protect you from anything that could ever happen underground. The hard hats mentioned above are specifically designed to significantly reduce the likelihood that being struck on top of the head by a falling object will break your neck or penetrate the shell, injuring your skull.

They are also flame resistant and can withstand low voltage electricity without transmitting it through the wearer.

I will close with the three most common quotes I get from coal miners related to certified hats and what I say in return.

Q: “If something big enough falls on me underground, I’ll be dead anyway, it doesn’t matter what kind of hat I’m wearing.”

A: That may be true but an ANSI Z89.1 Type I, Class G hat is made to turn more than 6000 pounds per square inch of impact into less than 800psi on the neck, even at extreme temperatures. A “cat head” or good sized rock can fall out at any time.

These hats absorb impact, protecting not only your head but also your neck. This is also true when getting in and out of a ride or smacking your head off of a low bolt. Certified hats (especially low ones) actually prevent more sore necks and common day-to-day injuries than you may think.

Q: “I can hit my hat with a hammer, park my truck on it, etcetera. It’s just as safe as a certified hat.”

A: The shell is only one part of the head protective system. There are a lot of tough materials that are not suitable for making underground head protection.

Impact and fire resistant additives improve extremely expensive polycarbonates to yield a tough, light shell that works together with a suspension liner to protect your head and neck. Good shell with a bad liner, bad shell with a good liner, or a good shell and liner that aren’t made to work together are all dangerous combinations.

Q: “I’ve been wearing this old hat since I got in the mines, it’s grandfathered in and I’m not taking it off for anyone.”

A: MSHA is getting tighter on uncertified, modified and even antique hats. The law requires the mine operator to assure a “suitable hard hat” is being used but inspectors are also giving personal citations to individuals who are wearing uncertified hats, including the old fiberglass ones.

According to ANSI, safety cannot be grandfathered in. If you are still wearing a cut-down, have cut or modified your liner, or still roll with an old turtle shell – watch out. Beyond being unsafe, many MSHA districts are out looking at this closely and it could cost you.