It depends what a person means when they say headroom. There is a big difference between having enough power for your average db vs having enough power for transients. There is no need to have “headroom” more than you need for transients but in the OPs case it clearly does not do that.

If OP listens at 80 db average at 90-97% volume then the peaks in the music will be cut off. Depending on the type of music you listen to you could have anywhere for say 15-30 db transients. The rub is that the power needed is not linear with the increase in db but instead exponentially. So where you may only need 50mW of power at 80db you will need 150mW at 85 db (I made up those numbers but a headphone power calculator can tell you exactly what they are depending on your headphone).

My suggestion would be to use a headphone power calculator and input your resistance (ohms) and sensitivity (db/mW) and then see how much power it needs at 115db. I typically listen at around 80-85 so this covers me for an additional 30-35 db of “headroom” for transients. That way even if you typically only listen at 70 you know you are covered if you want to really go crazy for a bit (but be sure to limit your time doing this if you do).

It is also worth noting that if you plan to EQ (and you should if you can because why not) that you will need to take into account your negative preamp into the equation. So it you listen at 80 but have a negative preamp of -5db you will need to include that in your power calculation by adding another 5db to your listening level.

So if people mean they want headroom so that they can listen at 95db with full transients for 1 song well then maybe? But otherwise there is no headroom needed past what your headphone requires to fully show transients. Just another warning that while listening at this kind of level for a short time is “ok” but definitely don’t do it for long periods of time and you can always see what OSHA says as far as exposure at certain levels that is a good reference.