Rethinking Head Protection: The Case For Type 2 Hard Hats & Chin Straps On Today’s Worksites
By Lauren McFarlane
Noggin? Melon? Bowling Ball? Skull? Dome?
No matter what you call it, your head needs protection when you’re working in the construction sector, and that thought hit me hard one fine day. Literally.
Walking down the street while on vacation this past week, I was hit on the ‘noggin’ (an informal term for head, often suggesting a small or protective container—my personal favourite). By what, you ask?
Well, I was hit straight down, dead-center, assaulted by an acorn formerly attached to a branch high up in a tree. It landed with a bang and a resounding ‘crack’. I heard it in my head, ear-to-ear and all around, and that got me inspired.
It just so happened, I had planned on writing my next article about Type 2 hard hats once I returned from my trip, but I feel compelled to write about them right now! It must have been that acorn…it was telling me something.
So, my light bulb moment was replaced with a hard-shelled nut. So much for the vacation with my thoughts redirected back to work. So, I sat down to write. The bottom line is – even without new provincial legislation, the industry standards and best practices are rapidly shifting, driven by major contractors demanding the use of Type 2 hard hats with integrated chin straps.
At Act First Safety, the number one provider of certified training programs in Ontario, we take such legislation very seriously. In fact, we recently covered the new AED update, too, and today we’re ready to talk about hard hats!
No new legislative change, but change nonetheless
I had heard a rumour that there were some legislative changes to hard hat requirements on construction projects, but after a bit of research, I have since learned that there are no legislative changes. However, many large construction companies have already made or are about to make changes to hard hat requirements that apply to workers, subcontractors, service providers, and visitors. Let me walk you through that change.
Change has arrived
It won’t be an exaggeration to say that change is already here. Take, for example, Aecon’s new policy on PPE and the inclusion of hard hats in it.
When bidding on projects with Aecon, bidders are now required to comply with their enhanced personal protective equipment (PPE) standard. Vendors must recognize this change in the scope of work to align with Aecon’s revised PPE standard. All bidders engaging in construction activities must wear a Type II Class E hardhat with a 4-point chin strap citing the concern around traumatic brain injuries.
That’s how important it is now.
Type 1 versus Type 2 Hard Hats
The difference between Type 1 and Type 2 hardhats is highlighted below:
- Type 1: Effective in protecting against top or vertical impact only.
- Type 2: Meant to protect workers against impact from all sides – vertical, lateral (side), front, and rear impacts.
Hardhats are assigned different classifications to suit specific worker needs, including Class E Electrical (20,000V), Class G: Electrical (2,200 V) and Class C: No electrical protection.
Current legislation
Currently, the section regarding hard hats, under the O. Reg 213/91 Construction Projects, states:
- That every worker must wear protective headwear at all times (Section 22 (1))
- The protective headwear shall be a safety hat (Section 22 (2)(a-b)):
o Made from materials that adequately protect a person’s head against impact from flying or falling small objects and can withstand a dielectric strength test of 20,000 volts.
Traumatic brain injuries and how hard hats prevent them
Traumatic brain injuries are the construction industry's most significant head injury concern. The hazards are not only impacts from falling objects and falls from height, but also include being struck by objects or succumbing to falls. Typical hard hats cannot protect workers against such trauma in most cases, unless they are very lucky. Statistics paint the same picture. Here’s what they say about traumatic worksite brain injuries:
- 25% construction-related fatalities (approximate)
- 68% from falls
These incidents commonly arise when one is working at heights, which makes working at heights training so critical. During this program and other courses, such as swing stage training, boom lift training, and hoisting and rigging training, hazards that can cause brain injury should be thoroughly reviewed and understood.
More client requirements in 2026
Just like Aecon, companies such as Ellis Don and Bird have launched enhanced PPE programs, which will be effective January 1, 2026. They will make Type 2 hard hats with integrated chin straps mandatory for all workers, subcontractors, and visitors, citing the same reasons as indicated earlier, due to the risk of traumatic brain injury on construction sites.
Advantages of Type 2 hard hats
Research shows that CSA/ANSI Type 2 hard hats, particularly those with integrated retention systems, provide significantly greater protection and help reduce the risk of serious and fatal head injuries because of:
Enhanced Protection: CSA/ANSI Type 2 hard hats protect against both vertical and lateral impacts, making them essential for dynamic construction environments.
Secure Fit: Integrated chin straps ensure the hard hat stays in place during slips, falls, high winds, or while working in awkward positions, providing reliable protection when it's needed most.
Dropped Object Prevention: Properly secured hard hats reduce the risk of becoming a falling object hazard.
Why the Change?
| More Protection | Side, front, back, and top impacts covered
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| Secure Fit | Chin straps prevent helmets from dislodging (when fastened at all times)
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| Fewer Risks | Reduces struck by and fall injury potential
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What does 'integrated' chin strap mean?
This is one of the most critical aspects of the new requirements. An integrated chin strap is not just any strap you can buy and attach. It features:
- Manufacturer-Approved System: An integrated chin strap is one that is manufacturer-approved and explicitly designed for a specific hard hat model.
- Safety System Tested Together: The chin strap is designed and tested as part of the hard hat’s overall safety system to ensure it contributes to meeting the specific CSA/ANSI Type 2 standard requirements.
Crucial Compliance Summary
| Type of Strap | Status | Reason |
| Integrated | ✅ Acceptable | Factory-installed or designed/tested by the manufacturer for the specific helmet model. |
| Third-Party/Generic | ❌ Not Acceptable | Using a generic accessory strap (even if it fits) can compromise the hard hat's tested protective ability and is not manufacturer-approved as part of the system. |
Why the strict requirement?
Using a non-integrated, third-party chin strap may seem cheaper, but it creates a compliance and safety risk because:
- Testing Integrity: The hard hat's ability to withstand side impact (the core benefit of Type 2) is certified with the approved retention system. A different strap may pull or stress the shell differently during impact.
- Warranty and Liability: Using non-approved accessories can void the manufacturer's warranty and increase liability in the event of an injury.
Hardhat Classifications
Vendors should check with their clients to determine the Class of hard hat they need to perform the type of work being done. Examples include:
- Class E: Electrical (20,000V)
- Class G: Electrical (2,200 V)
- Class C: No electrical protection.
Obviously, the classification must match the hazards and the client's requirements.
Accessories for hard hats
Accessories like cooling products, sweatbands, sunshades, and hearing protection are allowed as long as they are compatible with the chosen model and don’t create any new hazards.
What’s Next? Time to Update Your Hardhat Program
This ‘wind of change’ is more than just a passing rumor. It's a reminder for employers to proactively review their Personal Protective Equipment (PPE) programs and procurement processes. Ideas on how to address the issue can be reviewed among members of the Joint Health and Safety Committee to determine what, if any, changes are required. But, don’t be surprised if other large construction operators begin to ask more from their vendors when it comes to hard hats and other PPE.
While legislative changes may take time, the market is already setting a new, higher safety standard. Major clients like Aecon, Ellis Don, and Bird, are clearly prioritizing worker protection by mandating Type 2 Class E hard hats with integrated retention systems well ahead of any potential regulation.
If you want to stay ahead of the curve and ensure maximum safety for your crew of workers, you can turn to us. Act First Safety’s worker safety programs in Scarborough, Ontario, are known for being thorough, engaging, and compliant. Contact us to schedule a class for your crew.
FAQs
Is the use of Type 2 hard hats mandatory as per Ontario law?
No, not currently. No legislative changes have been made to Ontario’s hard hat requirements. However, major contractors have made them a mandatory part of their PPE guides.
Can third-party chin straps be added to Type 1 hard hats?
No. Using such a makeshift hat can seriously compromise worker safety on construction sites. Furthermore, it can void the helmet’s warranty.
Do visitors need to wear Type 2 hard hats?
Yes, anyone on a construction site must wear a Type 2 hard hat at all times till they exit the site.
