OSHA’s Regulation for Eye and Face Protection
5/3/2021
One of the typical comments I receive from an audit or review of a safety and health document, such as a job hazard analysis – JHA (also known as an activity hazard analysis – AHA) or Safety and Health Plan, when the subject of eye protection is discussed, is the phrase, “please include side protection.” On a good day, I’ll just smirk and shake my head and even add the requested inclusion. The reason for my reaction is that when it comes to protecting our eyes during any work task, the typical language used in the S&H document is “to provide eye protection per 29 CFR 1910.133 requirements.” And this is my typical control for hazards where our eyes are concerned. I use this phrase; or some facsimile, as this provides latitude of what type of eye protection would be best – depending on the field hazard assessment.
As you might guess, the regulation cited above (29 CFR 1910.133), is the OSHA standard, “Eye and Face Protection.” And this regulation has the opening statement (29 CFR 1910.133(a)(1):
“The employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.”
This means that it is the responsibility of the employer to verify that each worker is wearing eye protection (and/or face protection) that is commensurate with the assigned task and the potential hazards associated with that task. In other words, during the hazard analysis portion of the field work planning stage, while the work task hazards have been determined (i.e. hazard identification), the employer shall establish controls that are proportionate to the specific hazard. The word, proportionate, is a critical factor here, as we can always take the extreme conservative approach and require a face shield and goggles for all potential eye hazards; such as while handling preservative reagents for water samples. And true, some of the preservative reagents can be nasty stuff, like, high concentrations of hydrochloric acid or nitric acid. And without a doubt, wearing such PPE would ensure the eyes of anyone handling these materials will be protected. However, due to the amounts being handled and by using proper work practices (i.e. transferring the preservatives below eye level and away from the face, simple safety glasses would be appropriate. In addition, having an extraordinary amount of PPE can reduce visibility and become a hazard while walking on uneven terrain.
In addition, the very next statement, 29 CFR 1910.133(a)(2), states the following:
“The employer shall ensure that each affected employee uses eye protection that provides side protection when there is a hazard from flying objects. Detachable side protectors (e.g. clip-on or slide-on side shields) meeting the pertinent requirements of this section are acceptable.”
So, according to this “Eye and Face Protection” regulation, side protection would be appropriate (and even necessary) when there is a potential for flying debris, such as dust particulate. When working around liquids where there is a potential splash hazard, goggles would be a better choice. Yet, there is a point that so many people seem to overlook when asking for a minor change to a S&H document when it comes to side protection. That is, today, just about all safety glasses are manufactured with side protection as part of the main frame. So, the comments that pertain to including “with side protection,” has become a rather moot point.
Many years ago, safety glasses were rather limited in styles and were frequently shunned by workers as they were aesthetically unpleasant or not fashionable. Another way to say it, is that they were Geeky! But manufacturers rose to the occasion and sometime during the late 1990s, safety glasses began looking quite stylish. So stylish that many workers would wear them outside of work: maybe to mow their own lawn or to perform household tasks as working with hand tools. And when it comes to goggles, many prefer to wear these fashionable pieces if eyewear while riding a motorcycle!
The advent of stylish safety glasses was definitely a big help to S&H professionals everywhere as now, there is a reduced burden to enforce wearing these items. Of course, there are still problems with fogging and scratches; both of which can hamper visibility. And while manufacturers offer various models of anti-fog and anti-scratch lenses, these articles can be ineffective during extreme conditions, as many of us experienced during the winter months while the recent Covid-19 pandemic required face coverings to be worn. The warm air that was exhaled from our mouths would rise upward (due to the masks) and quickly condense on the safety glass lenses. This was a constant concern, even when wearing anti-fog safety glasses or applying anti-fog solution.
Maybe the only applicable consideration for requesting side protection comes when personnel are wearing prescription lenses. Prescription eyewear would typically need side shields as manufacturers only produce the safety requirements that meet ANSI Z-87 requirements (that’s the testing protocol recognized by OSHA in the “Eye and Face Protection” regulation (29 CFR 1910.133) for the lens; thus the employee would need to talk with their S&H professional about obtaining proper side shields. A major consideration is that the side shields need to be fit properly on the glass frame with no gap between the side shield and the front lens. This is often a problem; even with manufactured prescription safety glasses. This is primarily due to manufacturers merely placing stock side shields on to the prescription safety glasses as opposed to producing side shields that are specific to a corresponding pair of prescription safety glasses. One way to combat this dilemma is to use over-the-glasses safety glasses. Therefore, bona fide safety glasses would fit over prescription glasses, offering the appropriate eye protection – with fixed side shields. The cost-saving is also quite significant as over-the glasses safety glasses cost about $10.00 when compared to hundreds of dollars for prescription safety glasses that may not even offer the appropriate side protection!
By failing to prepare, you are preparing to fail.