For decades, PPE programs were often built around a straightforward objective: identify the applicable OSHA requirement, purchase equipment that meets the minimum standard, and replace it when it wears out.
That approach can miss an important question:
Has the PPE improved while your specification stayed the same?
Hard hats are a good example.
Traditional Type I hard hats remain appropriate for many applications, but newer Type II helmets address impact hazards that Type I helmets are not designed to address. At the same time, improvements in hand protection, respiratory protection, visibility, fall protection, arc-flash PPE and integrated head/face protection give safety managers an opportunity to reconsider specifications that may have remained unchanged for years.
Modernizing a PPE program does not mean replacing everything with the newest or most expensive equipment.
It means using the workplace hazard assessment to determine whether higher-performing PPE can address hazards that the existing specification does not adequately address.
Start With the Requirement OSHA Actually Makes
OSHA's general-industry PPE standard, 29 CFR 1910.132, requires employers to assess the workplace for hazards that are present or likely to be present. When PPE is necessary, employers must select PPE that protects workers from the identified hazards, communicate the selection decisions and ensure the equipment properly fits affected employees.
The employer must also document that the hazard assessment was performed.
For head protection specifically, 29 CFR 1910.135 requires protective helmets where employees face potential head injury from falling objects and requires electrically protective helmets when employees work near exposed electrical conductors that could contact the head.
Construction employers have similar obligations under 29 CFR 1926.100 for hazards involving impact, falling or flying objects, and electrical shock and burns.
That distinction matters because OSHA does not simply say:
Every worker must wear a Type II helmet.
The appropriate question is:
What head-impact hazards did our assessment identify, and what helmet is designed to address those hazards?
That leads directly to the difference between Type I and Type II.
ANSI Z89.1: Type I vs. Type II Is About Impact Direction
ANSI/ISEA Z89.1 classifies industrial head protection by Type and electrical Class.
Those are two different things.
Type I
Type I helmets are designed to reduce the force resulting from an impact to the top of the head.
Think of hazards such as a tool or material falling from above.
Type II
Type II helmets are designed to reduce impact forces from blows to the top or sides of the head.
That additional lateral-impact performance becomes relevant when the hazard is not limited to something falling vertically onto a worker.
Examples can include:
- A worker falling and striking a structural member
- Swinging equipment or materials
- Flying or falling objects approaching at an angle
- Contact with machinery or structures
- Slip, trip and fall incidents involving head impact
NIOSH points out an additional concern with lateral impacts: side impacts can produce rotational acceleration of the brain, one mechanism associated with concussion and traumatic brain injury.
That does not make every Type I hard hat obsolete. It means safety managers should determine whether top-impact protection alone matches the actual hazard profile of the job.
Read Novarlo's guide to Type II hard hats and construction head protection.
The Numbers Behind the Head-Injury Problem
This isn't a theoretical hazard.
NIOSH reports that work-related traumatic brain injuries account for approximately 20% to 25% of work-related trauma.
Construction is particularly concerning.
NIOSH identified 2,210 construction-worker deaths involving traumatic brain injury between 2003 and 2010, representing 25% of construction fatalities during that period. More than half of fatal work-related TBIs in construction involved falls.
NIOSH also found significant differences among worker populations. Workers at construction companies with fewer than 20 employees were more than 2.5 times as likely as employees at companies with at least 100 workers to die from a TBI.
OSHA has cited more recent Bureau of Labor Statistics data showing that head injuries represented nearly 6% of nonfatal occupational injuries involving days away from work in 2020. Almost half involved contact with an object or equipment, while roughly 20% resulted from slips, trips and falls.
Those statistics help explain why head protection design has received renewed attention.
OSHA Made the Switch for Its Own Employees
In 2023, OSHA announced that it was replacing traditional hard hats used by its employees with modern safety helmets.
That announcement is sometimes interpreted as OSHA requiring employers nationwide to make the same switch.
It does not.
OSHA performed a Job Hazard Analysis of its own employees and concluded that Type II, Class G safety helmets were the appropriate head protection for its personnel.
More importantly for employers, OSHA's subsequent Safety and Health Information Bulletin recommends considering Type II helmets in situations such as:
- Construction sites with falling-object and debris hazards
- Environments involving potential equipment impacts
- Work involving awkward positions
- Jobs with slip, trip and fall hazards
- Oil and gas environments involving severe impact hazards
- Work performed at heights
OSHA also recommends considering chin straps where keeping the helmet on the worker's head is important.
The takeaway isn't "OSHA switched, therefore everyone must switch."
It's that OSHA used the same process employers should use:
Hazard assessment → identify exposure → select appropriate protection.
NIOSH Research Shows Helmet Design Can Matter
One of the strongest arguments for periodically reevaluating PPE specifications comes from NIOSH research into helmet performance.
NIOSH researchers have evaluated construction helmets using laboratory testing designed to examine shock absorption and fall protection.
In research summarized by NIOSH, newer helmet designs incorporating an additional foam layer between the suspension and shell provided significantly greater protection than basic Type I helmet designs and reduced the estimated probability of serious head injury by nearly 30% under the studied conditions.
NIOSH also conducted testing in which manikins wearing different construction helmets were dropped approximately five feet onto different surfaces. The agency reported that all evaluated helmets performed well, but newer helmet designs provided substantially better fall protection than basic Type I designs.
That does not mean a specific helmet automatically reduces every worker's injury risk by 30%.
It demonstrates something more useful:
PPE products that technically occupy the same general category can perform differently.
That principle extends well beyond hard hats.
Don't Confuse Helmet Type With Electrical Class
This is one of the most important distinctions when specifying head protection.
Type describes impact protection.
Class addresses electrical performance.
Class G - General
Class G helmets are tested for electrical protection up to 2,200 volts.
Class E - Electrical
Class E helmets are tested at 20,000 volts and are intended for applications where higher-voltage electrical exposure is a concern.
Class C - Conductive
Class C helmets provide no electrical protection.
Therefore:
Type II, Class E means lateral/top impact protection plus Class E electrical performance.
Type II, Class C means lateral/top impact protection without electrical protection.
A purchasing specification that simply says "Type II hard hat" may therefore be incomplete.
For electrical utilities, electrical contractors and facilities with exposed electrical hazards, the electrical class can be every bit as important as the impact type.
OSHA also specifically warns that vented helmets cannot be used for electrical work requiring electrical protection.
Explore Novarlo's head and face protection options.
Modernization Doesn't Stop at the Hard Hat
The same question should be asked throughout the PPE program:
Are we buying PPE because it matches the hazard, or because it's the SKU we've always ordered?
Here are several areas worth auditing.
1. Replace "Cut-Resistant Glove" With an Actual Performance Requirement
A glove specification that simply says "cut resistant" tells a purchasing department very little.
ANSI/ISEA 105 provides standardized performance classifications for hand protection, including cut resistance.
Current ANSI cut classifications run from A1 through A9, with increasing levels corresponding to increasing cut-force performance.
That means two gloves marketed as "cut resistant" can provide substantially different levels of protection.
But simply purchasing the highest cut level isn't necessarily the answer either.
A safety manager should consider:
- Cut hazard
- Puncture hazard
- Abrasion
- Impact exposure
- Grip
- Dexterity
- Contact heat
- Chemical exposure
- Frequency and duration of use
For example, a high-cut glove that prevents an employee from properly gripping a small component can introduce another problem.
Modernization means replacing vague specifications with measurable performance requirements based on the task.
Compare Novarlo cut-resistant gloves by ANSI cut level.
2. Stop Treating Every Respirator as Interchangeable
Respiratory protection is another area where product category alone is not enough.
A disposable filtering facepiece, elastomeric half mask, full-face respirator, PAPR and supplied-air respirator are not interchangeable solutions.
Selection depends on factors including:
- Contaminant
- Concentration
- Exposure limit
- Oxygen concentration
- Assigned Protection Factor
- Cartridge/filter limitations
- Whether the atmosphere is immediately dangerous to life or health
- Work duration
- Environmental conditions
A PAPR may improve comfort and provide a higher level of respiratory protection in certain configurations, but "PAPR" does not automatically mean appropriate for every atmosphere.
The respirator must be NIOSH-approved in its complete configuration and selected as part of a compliant respiratory protection program.
Explore Novarlo respiratory protection systems.
3. Review Whether Visibility Specifications Actually Identify a Standard
"Hi-vis yellow" is a color description.
It is not a complete PPE specification.
ANSI/ISEA 107 high-visibility apparel is classified according to factors including the intended work environment, garment design and quantities of background and retroreflective material.
A fluorescent shirt may be extremely bright and still not satisfy the performance class required for a particular roadway or work-zone application.
A modern specification should identify the appropriate ANSI/ISEA 107 Type and Performance Class, where applicable, rather than simply specifying a color.
This becomes even more important when workers need multiple forms of protection simultaneously.
For example, electrical and utility crews may require both arc-rated clothing and high visibility. A garment can be selected to address both hazards rather than layering an inappropriate garment over properly rated FR/AR clothing.
4. Evaluate PPE as a System, Not a Shopping List
A worker rarely wears only one piece of PPE.
A realistic setup might include:
Helmet + safety glasses + face shield + hearing protection + respirator + gloves + protective clothing.
Every item could individually meet an applicable standard and still create problems when worn together.
Examples include:
- Earmuffs that don't properly interface with a helmet
- Safety glasses interfering with respirator fit
- Face shields incompatible with helmet mounting systems
- Winter liners affecting helmet fit
- Multiple pieces of head-mounted PPE creating pressure points
- Accessories that compromise electrical protection
- A chin strap interfering with other equipment
That is why accessory compatibility deserves to be part of the PPE selection process.
Browse helmet and hard-hat accessories available through Novarlo.
5. Look for Situations Where One Piece of PPE Must Address Multiple Hazards
Higher-performance PPE becomes particularly valuable when workers face overlapping hazards.
Consider a utility worker who may simultaneously face:
- Electrical exposure
- Arc-flash hazard
- Traffic exposure
- Falling objects
- Cut hazards
- Weather
- Noise
The answer isn't necessarily to pile seven unrelated products onto the worker.
The better approach is to identify products and systems that meet the necessary performance requirements while remaining compatible and wearable.
That could mean:
- Type II, Class E head protection
- Arc-rated and ANSI-compliant high-visibility apparel
- Gloves selected for both mechanical and electrical tasks
- Integrated face and hearing protection
- FR/AR cold-weather layers instead of non-rated outerwear
A Practical PPE Modernization Audit
A safety manager doesn't need to replace the entire PPE program at once.
Start with the jobs carrying the greatest risk.
For each task, document:
1. What is the hazard?
Don't write "head injury." Identify whether the exposure is falling objects, lateral impact, electrical contact, falls, or multiple hazards.
2. What standard applies?
Examples might include ANSI/ISEA Z89.1 for industrial head protection, ANSI/ISEA 105 for hand protection, ANSI/ISEA 107 for high visibility, or a NIOSH respiratory approval.
3. What rating or classification does the current PPE have?
Don't assume. Check the product markings and manufacturer documentation.
4. What does that rating actually test?
This is where many programs fail.
A certification or standard number only helps if the person specifying the PPE understands what was tested.
5. Does the rating correspond to the hazard identified in the assessment?
A Type I helmet may be compliant head protection but may not address the lateral-impact hazard identified for a particular job.
A high-cut glove may provide excellent cut protection but inadequate puncture resistance.
An FR garment may resist ignition but not necessarily have the arc rating required for an electrical exposure.
6. Does all of the PPE work together?
Test the complete configuration employees will actually wear.
7. Will employees wear it correctly for an entire shift?
Protection that is routinely removed, loosened, modified or worn incorrectly because of poor comfort or compatibility deserves another look.
The Goal Isn't Newer PPE. It's Better Hazard Control.
PPE sits near the bottom of the hierarchy of controls for a reason.
Where hazards can be eliminated, substituted or controlled through engineering or administrative measures, those approaches should come first.
But when PPE is necessary, the equipment should reflect the actual hazard assessment—not an old purchasing specification.
The move toward Type II helmets illustrates the larger opportunity.
Safety technology continues to evolve. Materials improve. Testing improves. Manufacturers develop equipment capable of addressing multiple hazards. Research gives safety professionals better information about how products perform.
A PPE specification written five or ten years ago may still be perfectly appropriate.
Or it may simply have never been questioned.
Modernizing a safety program starts by asking the question.
Build a Hazard-Based PPE Program With Novarlo
Novarlo works with utilities, contractors, manufacturers, foundries, infrastructure crews and industrial facilities to help identify PPE for demanding workplace hazards.
Whether you're evaluating Type II helmets, ANSI cut-rated gloves, respiratory protection, FR/AR apparel, high-visibility clothing or complete PPE systems, start with the hazard and work backward toward the appropriate protection.
If you're reviewing your current PPE program or aren't sure which ratings, standards or products are appropriate for a specific application, contact the Novarlo team. We're always happy to help you work through the requirements and find the right protection for your team.