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#1 Posted : 16 April 2008 00:18:00(UTC)
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Posted By Ade Can anyone point me in the right direction on a recent article written about the wearing of safety helmets back to front. There has been a trend recently on work sites on crews wearing a peaked hard hat back to front with the inner lined also turned around. It is something that I have seen quite often and I remember reading an article that stated that as long as the inner liner was also turned round that it was safe to wear the hat that way. Thanks Ade
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#2 Posted : 16 April 2008 08:29:00(UTC)
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Posted By Mitch Ade, I think this has been discussed on this forum recently, however consider the situation of the wearer sustaining head injuries whilst wearing a hard hat backwards (not the way it has been designed to be used otherwise the liner and outer casing would be symmetrical). What would the wearers, and the supervisors position be in a court of law? Very trendy practise but not particularly safe I would suggest. Mitch
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#3 Posted : 16 April 2008 08:37:00(UTC)
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Posted By Dave Merchant There's a difference between 'safe' and 'legal'. In the US, it's common practice (on some sites you'll be pushed to find a guy with a hat the right way round.. I blame The Youth) but in the US there's no law on the correct way to use them. 29CFR 1926.100(a) specifies the type of helmet but nothing about use or maintenance. It's actually possible to argue that you don't need to wear the helmet at all - you just have to be 'protected by helmets'. You could hide under a box of them. In the UK you have a few layers to jump through:- 1) Construction (HP) Regs say you have to 'wear' head protection, that it must be 'suitable', etc. but don't define what type it is. The critical part is 6(4) which says "Every employee or self-employed person who is required to wear suitable head protection by or under these Regulations shall do so properly." There's no definition of 'properly' (legal oversight; the committee assumed everyone knew) but you can infer the direction your head should be pointing from the user instructions. 2) The PPE Regs require via the instructions supplied through EN397 that no modifications are made without authority of the manufacturer. There's no authority to swop the cradle so you can't do that, but the concept of wearing the entire thing backwards is covered more by the definition of "safe" in 2(2). FYI EN397 is vague enough to work 'backwards' but *only on some types of helmet*. The test headform is symmetrical, but terms such as "peak" and "nape strap" define the orientation relative to the eyes, so force a decision. Helmets made to different standards are sometimes asymmetrical.
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#4 Posted : 16 April 2008 09:15:00(UTC)
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Posted By Mitch Dave, Very concise, but is that a yes or no? Mitch
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#5 Posted : 16 April 2008 10:29:00(UTC)
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Posted By Dave Merchant "Very concise, but is that a yes or no?" It's a no for a UK workplace subject to the Construction (Head Protection) regulations.
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#6 Posted : 16 April 2008 10:49:00(UTC)
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Posted By Mitch Thanks, I thought that but I do struggle with words greater than 1 syllable! Not being a "brickie" I cannot understand why someone would put a peaked hard hat on backwards doesn't it chafe your neck?
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#7 Posted : 16 April 2008 10:55:00(UTC)
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Posted By Crim I often see contractors wearing their hat back to front and just tell them to wear it properly. Any further problem and they are off site.
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#8 Posted : 16 April 2008 11:00:00(UTC)
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Posted By Jonathan Breeze Not so much for brickies, but surveyors often find that a peak can obstruct the view when using the tools of their trade as well as restricting upward vision. Simple solution - specify a hard hat without a peak if it is not needed, there are plenty on the market.
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#9 Posted : 16 April 2008 11:15:00(UTC)
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Posted By Mitch What's the peak for, streamlining?
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#10 Posted : 16 April 2008 13:37:00(UTC)
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Posted By Ron Hunter Not acceptable. The peak of the hat is there to stop dust and light debris falling into the eyes/face. An assessment of need (as required by the PPE Regs) would confirm this risk on most construction sites. Surveyors can be issued with a hard hat with a reduced peak - this helps prevent display of a bad example which the more impressionable tend to follow. You really need to play hardball on this one.
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#11 Posted : 16 April 2008 13:59:00(UTC)
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Posted By Jonathan Breeze Valid point Ron, But I would counter that if wind blown dust was such a problem then safety goggles or specs would be a more suitable precaution offering better protection. That said, I would add my voice to the growing consensus that wearing a hard hat back to front is not acceptable and may even be deemed as misuse as per Reg 10(2) of the PPE at Work Regs 1992
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#12 Posted : 16 April 2008 14:22:00(UTC)
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Posted By Dave Merchant "...as per Reg 10(2) of the PPE at Work Regs 1992" That no longer exists. The 2002 edition doesn't have that clause, as it was re-written to apply less to the user and more to the supplier, given the non-workplace users of PPE vastly outnumber the workplace ones. PUWER is as close as you'll get to "a law on how to use stuff at work", but where the C(HP) Regs apply they win.
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#13 Posted : 16 April 2008 14:26:00(UTC)
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Posted By Jonathan Breeze I knew it as soon as I posted!
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#14 Posted : 16 April 2008 14:33:00(UTC)
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Posted By Jonathan Breeze In my defence I give this link which has not yet been removed. http://www.opsi.gov.uk/S...2/Uksi_19922966_en_1.htm So to clarify the point, do the PPE Regs 2002 now supersede the PPE at Work Regs 1992, they look a totally different beast to me?
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#15 Posted : 16 April 2008 15:22:00(UTC)
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Posted By Dave Merchant Yes. The 92 Regs were amended several times and were turning into a nightmare, so in 2002 the entire lot were repealed and the all-new version enacted. The layout's completely different, as between 92 and 02 the PPE Directive was battered about so much, most of the old stuff didn't make sense anymore. OPSI never remove expired statutes from their website as they're a valuable resource for researchers - but they could do more to point out someone's looking at an expired version!
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#16 Posted : 16 April 2008 15:33:00(UTC)
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Posted By Gerry I thought that the 92 regs were still in force. They are still listed on the HSE legislation pages http://www.hse.gov.uk/le...tion/statinstruments.htm I am sure the 2002 regulations are concerned with the manufacture of ppe not it's use at work. Regards Gerry
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#17 Posted : 16 April 2008 15:33:00(UTC)
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Posted By Paul Leadbetter The 2002 Regs did not revoke the 1992 Regs (see Schedule 11 of the 2002 Regs here: http://www.opsi.gov.uk/si/si2002/20021144.htm) and so the 1992 Regs are still in force. Confusion may have arisen because the Personal Protective Equipment (EC Directive) Regulations 1992 were revoked in 2002. Paul
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#18 Posted : 16 April 2008 15:38:00(UTC)
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Posted By Mitch Bingo! 2002 is part of the Consumer Protection legislation.
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#19 Posted : 16 April 2008 15:49:00(UTC)
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Posted By Jonathan Breeze Thanks for the clarification folks, it's all worth CPD! In any case, all Ade needs to do is get a copy of the suppliers hard hat instructions to show offenders the correct way to wear the kit. Ade, If I identify any articles on the net I'll post a link.
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#20 Posted : 16 April 2008 15:50:00(UTC)
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Posted By Angus232 What about H&S at Work Act Sections 7 and 8....misuse anything provided in the interests of health and safety etc.
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#21 Posted : 16 April 2008 16:00:00(UTC)
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Posted By Mitch If, as Ron has previously pointed out the RA identified the need for a peak due to dust and rubble they would be obliged to wear them correctly and any surveyors with little peaks would be required to wear supplementary PPE.
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#22 Posted : 16 April 2008 16:38:00(UTC)
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Posted By Garry Adams Ade This is a horses for coerces issue, I can recall in the early days of the Construction of the Offshore Installations (mid-70s) the Scaffs and other Construction Workers wore our hats back to front then we started too cut the peaks off with a hawk saw... this was not malicious damage on our part, we were modifying our P.P.E. to suit our Task...the reduced peak gave us improved vision while erecting under deck Scaffolds and reduced head impacts on Steel beams ect...So my advise is to assess the task and issue the appropriate Head Protection...if its a fashion statement the Operatives want to make tell them to get a Job with Armani or Gucci. regards, Garry...
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#23 Posted : 16 April 2008 20:14:00(UTC)
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Posted By GeoffB4 Just read through this thread with increasing alarm, I thought I'd missed a complete new set of PPE regs.
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#24 Posted : 17 April 2008 11:20:00(UTC)
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Posted By Dave Merchant I agree the legislation is confusing... I should've used the full titles in my original post as i was referring to the (EC Directive) Regs rather than the (at Work) regs. The PPE at Work Regs 1992 [PPEAW], now amended several times by everything from the Police Act to the 2002 Miscellaneous Amendments Regs, cover the concepts of "providing" and "enforcing use of" PPE. Because of bad timing, they arrived just before the PPE Directive stage 1 edit did, and so were almost instantly outdated in the way they handled *product* compliance and safety. The PPE (EC Directive) Regs 1992 [PPEEC] closed that hole, and defined that:- "...any question as to whether products to which the Directive applies are unsafe shall be determined in accordance with the Directive." This transfers _all_ product compliance, instructions and performance issues *from* PPEAW to PPEEC, and PPEEC has subsequently been amended over and over again, resulting in the Personal Protective Equipment Regulations 2002 [PPER]. It's no mistake that the 2002 version has a different title, and omits the words 'at work' - as it applies to products used anywhere and for any purpose, including personal and recreational. It also expands into some of the territory of PPEAW which isn't correctly mirrored in PUWER. Remember that despite the "consumer protection" title to the newer SIs, they all originate in amendments to PPEAW ad PUWER. The reason for the reclassification is that "consumer protection" covers both workplace AND personal users, but "health and safety" doesn't. PPEAW is, in effect, a backwater caused by Brussels updating something at the same time we tried to publish it into law. 75% of what it says is also in PUWER, and the rest is in PPER or the newer case-specific Regs such as COSHH, Control of Lead, Noise, etc. In terms of the topic of this thread, the question was not "Should a person be provided with a hat?" [covered by PPEAW and CHPR], or "Should that person be forced to wear the hat?" [PPEAW and PUWER], but instead it's "HOW can the person wear the hat?". _That_ is a PPER issue, as it relates to product safety compliance and modification, therefore takes the diversion to the PPER stream created by the quote above. {...goes to get another cup of coffee...}
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#25 Posted : 17 April 2008 11:46:00(UTC)
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Posted By Mitch Dave, I should make sure it's fully caff' after that!
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#26 Posted : 17 April 2008 13:12:00(UTC)
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Posted By Ron Hunter And after all of that Dave, I have to say I disagree with you! HOW can the person wear the hat? - Properly and in accordance with instruction and training. This is a work and workplace issue, entirely divorced from the PPER.
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#27 Posted : 17 April 2008 14:03:00(UTC)
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Posted By Dave Merchant With something like a harness or SCBA set I'd agree - but hard hats are Cat 2 and so don't have to be supplied with any user instructions, nor do the users have to be specifically trained in how to use them. They have to be told *when* to use them but the rest is assumed (in law) to be general common sense. It's like giving someone safety boots - you have to tell them to wear the things, but there's no law that you have to train them not to wear them on their hands. In the case we're discussing here it's arguable that wearing a hat backwards is actually an idea many people would find acceptable, given the shape of the hat and the head. Turning the cradle around is also something a sizeable proportion of people would probably think of as 'ok', and so to track down a place in statute which fundamentally answers the question we have to move away from the stuff on 'provision and use' and look at if wearing it backwards or flipping the cradle impacts on product safety. If it doesn't (which it does as I said earlier) then it would indeed be perfectly legal under PUWER and PPEAW. It's the technicalities of product compliance which are the only place you can actually find mention of which way your head should point.
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#28 Posted : 17 April 2008 14:24:00(UTC)
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Posted By Bob Shillabeer Not really a response just an aside. The hard hat is similar to the baseball cap. The game of baseball is actually a summer time thing in the states. And, as such it is normally played in hot weather, therefore the hat is a means of protecting the player from the efect of the sun. OK so far, I'm getting to the point don't worry there is more. As the game of baseball is a summer game and the sun shines in the summer (well in America anyway) there is a risk of sun burn so the hat is often worn backwards to cover the back of the neck and prevent burning the back of the neck. Ok so far? Well it seems to me that the hard hat is similar as when you wear one backwards it offers protection to the back of the neck. Perhaps that is why some people especially those working on building sites tend to wear them backwards. Has anyone asked such peiople why they are wearing it backwards???
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#29 Posted : 17 April 2008 14:33:00(UTC)
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Posted By johnwaterson2773 Hi all, When I first started doing this, H&S, the company I worked for, some of our operators wore the hard hat back to front. I asked why and they said we just did. I then explained about why the peak was there, it would assist in deflecting any debris falling and hitting the hat. Wearing it back to front, there was the possibility that the peak could be forced into the neck causing a severe injury, paralysed as anexample, loss of livelihood. Wasn't long before they were wearing them with the peak to the front and asking for the type with the smaller peaks.
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#30 Posted : 17 April 2008 14:58:00(UTC)
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Posted By Dave Merchant It's worth noting that the design of construction-style safety hats in the EU is noticeably different to those used elsewhere. In the USA the symmetrical brim design is the most common (think of the old WW2 British Army helmet), as seen in every disaster movie since Towering Inferno. The plan is as you suggested - to protect the ears and neck from impacts as well as the face. In Asia and Japan, the peaks are often absent or minimized to the point they're no more than a curved rim, and goggles or visors used instead. The argument of a peak protecting the face fails miserably when your face is this shape though:- http://www.zoomergear.com/
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#31 Posted : 17 April 2008 15:09:00(UTC)
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Posted By Mitch I'm going to buy a blind dog so that I can have one of those.
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#32 Posted : 17 April 2008 15:13:00(UTC)
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Posted By Mitch Try this for a matching set http://www.rescuepetstor...m/pet-supplies-500V.html
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#33 Posted : 17 April 2008 15:29:00(UTC)
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Posted By Ron Hunter (Hopefully) for the avoidance of any doubt, the employer and employee duties are covered in this scenario by Regulations 9 (employer) and 10(2)(employees) of the Personal Protective Equipment at Work Regulations 1992.
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#34 Posted : 21 April 2008 13:55:00(UTC)
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Posted By Glyn Phillips Having read through this thread can I make the following comments. Several people have fallen into the same trap I did some time ago. The information on the OPSI web site is very good and I use it often. However, generally this site only provides the text as it was enacted. If you want the amended text of legislation try the UK Statute Law Database (a link from OPSI is available). This gives the amended text of legislation with additions and revocations annotated. On the left hand side of the OPSI web page, select Legislation, then select Revised. This saved me from a potentially embarassing situation recently when I was about to quote an incorrect clause to my CEO. Hope people find the site useful (its not my site moderators)
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#35 Posted : 21 April 2008 14:25:00(UTC)
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Posted By CFT Ade See what was said in 2003! http://www.iosh.co.uk/in...view&forum=1&thread=6184 CFT
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#36 Posted : 21 April 2008 14:57:00(UTC)
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Posted By Mitch CFT-Good thread. CIS 50 clearly states (oops advises) that safety hats should be worn correctly and that "Safety comes before fashion" it also says that employees have a duty to wear PPE correctly and advises that they do not give proper protection when worn the wrong way round. Altering the inner cradle is also a modification of the original design & purpose. Source HSE.
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