Ontario’s July 1, 2027 Type 2 Hard Hat Rule: What Employers Need to Know
Ontario’s construction headwear amendment takes effect July 1, 2027—not July 2. It links the required impact protection to side-impact exposure and adds a retention requirement where conditions may cause headwear to come off. It is not a rule that every worker in Canada must wear the same Type 2 helmet.
This guide separates the legal requirements from the practical questions employers should resolve when selecting helmets and planning company logos or wraps.
What changes, and where does it apply?
O. Reg. 112/26 amends section 22 of O. Reg. 213/91, Construction Projects. The amendment comes into force on July 1, 2027. It concerns Ontario construction projects; requirements for other provinces or sectors need their own review.
| Condition on the project | New requirement |
|---|---|
| The worker may be exposed to side-impact hazards | Headwear manufactured in accordance with and meeting the design, performance and test requirements of CSA Z94.1 Type 2 or ANSI Z89.1 Type II, or protection at least equal to that level. |
| The side-impact condition does not apply | Headwear manufactured in accordance with and meeting CSA Z94.1 or ANSI Z89.1 design, performance and test requirements, or protection at least equal to that level. This provision does not specify Type 2. |
| Conditions may cause headwear to dislodge | A chin strap or other retention system must be used to prevent dislodgement. |
These are additions to the existing headwear provisions—not replacements for the rest of section 22. The existing requirement that every worker wear protective headwear at all times on a project remains, as do the requirements for an adequate shell-and-suspension system and a shell that can withstand a dielectric strength test at 20,000 volts phase to ground.
Type 2 describes impact protection, not electrical class
CCOHS describes Type 1 as protection against impact and penetration at the crown, and Type 2 as protection at the crown and laterally at the sides and back. Electrical classes are separate: CCOHS lists Class E, Class G and Class C. A Type 2 designation alone does not establish Class E or satisfy every requirement of Ontario’s construction regulation.
Do not choose from silhouette alone. A full-brim hard hat can be Type 2, and a climbing-style shape does not establish its certification. Check the exact product markings, documentation and configuration. Do not transfer the ratings of a non-vented model to a vented version bearing a similar family name.
Assess exposure before choosing a model
The amendment does not define “side impact hazards.” It is not appropriate to invent a universal list of jobs that automatically pass or fail the requirement. Review actual tasks, movement, surroundings and foreseeable contact, with your safety team and competent advice where needed.
- Map the work: document where workers move and the objects, structures and activities around them.
- Review possible side impacts: consider the direction of potential contact rather than only falling objects overhead. These are assessment prompts, not a legal definition.
- Review dislodgement separately: assess conditions that could cause headwear to come off. Type 2 and retention are distinct questions.
- Check other requirements: electrical shell performance, accessory compatibility, eye/face/hearing protection, fit and any additional site rules.
- Record the selection: retain the exact SKU, markings, instructions, compatible retention components and the reasoning for the chosen configuration.
Headwear is one part of hazard control. Choosing a helmet does not replace eliminating hazards, controlling access, safe work procedures or training.
Retention: confirm the complete system
The new subsection 22(5) requires a chin strap or other retention system where project conditions may cause headwear to dislodge. It does not say that an unrelated strap can be fitted to any helmet. Verify manufacturer-approved compatibility, attachment points, adjustment, use and inspection instructions.
Some models include a strap; others need an optional compatible component. A photograph without a strap is not a demonstration of suitable retention for a task where dislodgement is possible. Train wearers in the complete system rather than buying headwear and accessories as disconnected items.
Three current Keyline models to compare
| Exact model | What the current listing says |
|---|---|
| RZRBack HP1242R | Non-vented; CSA Z94.1 Type 2 and ANSI Z89.1 Type II, Class E listed; four-point magnetic chin strap. |
| Traverse HP1491R, non-MIPS | Non-vented; ANSI Z89.1-2014 Type II, Class E listed; four-point chin strap. Do not transfer these specifications to vented or MIPS variants. |
| PIP Dynamic Kilimanjaro HP642R | Full brim; ANSI/CSA Type II, Class E listed; four-sided custom logo imprinting documented. The listing identifies optional four-point strap 280-HP542C; confirm the complete ordered configuration. |
The specifications above were checked against the exact Keyline product pages on November 7, 2026. They are starting points for assessment, not an approval for every Ontario project. Check the supplied product’s markings and current manufacturer documentation. No stock position, price or delivery commitment is implied.
Custom logos and wraps: protection first, artwork second
You can plan company identification alongside helmet selection, but customization cannot convert an unsuitable helmet into suitable head protection. Our custom hard hats page explains logo-versus-wrap choices. The HP642R listing documents imprinting on all four sides; that does not establish the same printing or wrap permissions for HP1242R or HP1491R.
The custom-wrap program lists selected Type 1 and Type 2 options and a minimum of 107 hats per design. Confirm the exact base helmet, compatible materials and approved application. Historical wrap images illustrate design possibilities, not a certified configuration of the three models above.
CCOHS recommends checking with the manufacturer before adding stickers, tape or accessories. Do not drill or modify a shell, use unapproved paint, solvents or adhesives, or cover markings and inspection areas. The artwork proof should identify the actual helmet and permitted positions.
For apparel logo placement, sample work and a complete purchasing checklist, read our custom-branded safety gear guide for Canadian workplaces. Keep wrap quantities separate from any qualifying apparel or logo promotion.
A practical employer action plan
- Review now: inventory current headwear by exact model, rating, condition, accessories and task—not just colour.
- Assess: document side-impact and dislodgement exposure and confirm how the amended requirements apply to the work.
- Trial the fit: check the helmet with the worker’s other required PPE and manufacturer-approved accessories.
- Confirm procurement: get written product and retention details; seek evidence rather than relying on a “2027 ready” label.
- Approve artwork: check logo/wrap compatibility, markings, inspection access and quantities before approving production.
- Train and maintain: cover adjustment, retention, inspection, care, replacement and reassessment when tasks change.
The effective date is not a supplier purchase deadline. This article makes no claim about a grandfathering exemption or a requirement to buy by a particular date. Plan enough time for assessment and verification without assuming that a helmet purchased today will automatically meet every requirement when used later.
Frequently asked questions
Is July 2 the start date?
No. Section 2 of O. Reg. 112/26 states July 1, 2027.
Must everyone on an Ontario construction project use Type 2?
The new Type 2/Type II-or-equal requirement is tied to workers who may be exposed to side-impact hazards. Other headwear requirements still apply to workers outside that condition.
Does a chin strap make a Type 1 hard hat Type 2?
No. Retention does not change impact type. Check the helmet’s actual standard and markings.
Is a Type 2 helmet automatically electrically suitable?
No. Type and electrical class are separate. Section 22’s existing 20,000-volt phase-to-ground dielectric shell test wording remains relevant.
Can all three featured models be wrapped?
Not established. Confirm manufacturer-approved customization for the exact model. HP642R’s documented logo imprinting is not permission for an arbitrary full wrap.
Where can we start a quote?
Browse eligible logo hard hats and safety helmets or wrapped hard hat options, then provide the assessment requirements, exact model, retention needs, quantity and artwork.
Primary sources and care guidance
Reviewed November 7, 2026. The legal text controls; this guide does not replace employer obligations, manufacturer instructions or professional advice.
