“What we see depends mainly on what we are looking for.” — John Lubbock
Every chemical plant I have ever been in has these minimum requirements for personal protective equipment (PPE): hardhat, safety shoes, and safety glasses with side shields. OSHA tells us that it is the employer’s responsibility to assess the workplace for hazards and decide what PPE is necessary. In the case of plant minimum requirements, I’m not sure there is an assessment to support the choices.
Not that I object. In truth, if I were in a plant without a hardhat, safety shoes, and safety glasses with side shields, I would feel naked. Assessment or not, that is the decision and I’m glad to comply.
Eye and Face Hazards Requiring Protection
OSHA starts the Eye and Face Protection Standard (29 CFR 1910.133) with a list of hazards against which protection must be provided:
- Flying particles
- Molten metal
- Liquid chemicals
- Acids or caustic liquids
- Chemical gases or vapors
- Potentially injurious light radiation
Basically, solids, liquids, and gases, and light radiation. Everything. The assessment that safety glasses with side shields are required in a chemical plant seems like it is on solid footing, then. After all, there are solids, liquids, or gases in the plant. (Never mind the redundancy of listing both “liquid chemicals” and “acids or caustic liquids.”)
If everything is covered, however, then what isn’t covered.
For instance, I’ve never seen someone operating a deep fat fryer at a fast-food restaurant wearing safety glasses, with or without side shields, and certainly not with a face shield. However, a similar operation in an industrial setting would certainly require safety glasses and face shields.
It turns out that we really do have to make assessments.
Protection Against Radiant Energy
OSHA does provide prescriptive requirements for protection against radiant energy. The regulation has two tables, one for arc welding and cutting, and one for torch welding and cutting. These tables list various tasks and then specify the minimum protective shade for the filter lenses.
OSHA advises starting with a shade that is too dark to see the weld zone, then going to successively lighter shades until it is sufficient to view the weld zone, without going below the minimum.
When it comes to protection for welding and cutting, then, it is not enough to require weld goggles. The employer must also decide on the shade of the lens.
Side Shields
OSHA does not automatically require side shields. They are required when the hazard is from flying objects. Even then, however, OSHA does not require that the side shields be permanently attached. The standard says, “Detachable side protectors (e.g., clip-on or slide-on side shields) meeting the pertinent requirements of this section are acceptable.”
The Pertinent Requirements
The regulation states that eye and face protection must comply with one of three different consensus standards:
- ANSI Z87.1 1989 (R-1998)
- ANSI Z87.1-2003
- ANSI/ISEA Z87.1-2010
But those standards are obsolete. Since 2010, ANSI issued an updated standard in 2015 and the most current standard is ANSI/ISEA Z87.1-2020. Any new pair of safety glasses is going to comply with the current standard. OSHA has made no effort to keep up with the evolving Z87.1 standard. Are new safety glasses okay?
Yes, safety glasses that comply with the current standard are acceptable to OSHA. Why? Because OSHA allows for eye and face protection that is “at least as effective” as provided by the listed consensus standards, and ANSI has not been relaxing its standards as it has made revisions.
This goes for detachable side shields as well. The manufacturers of safety glasses provide side shields with those glasses that are also marked “Z87.” If they have been designed to go with the glasses and are detachable, they meet the pertinent requirements.
My safety glasses aren’t marked with a “Z87”. Instead, they are marked with “CSA Z94.3”. They, too, are okay with OSHA, for the same reason that new Z87 safety glasses are okay. CSA Z94.3 is the Canadian standard for eye and face protection. CSA issued the most recent version of this standard in 2020. It is not identical to the ANSI standard, but it is “at least as effective.”
Contact Lenses
Some employers prohibit wearing contact lenses where eye protection is required. That is their prerogative, but it is not because of any requirement by OSHA. When contact lenses first became popular, some feared that harmful materials that got into the eye would become trapped between the lens and the cornea, aggravating the injury. Based on that fear, they prohibited contact lenses. Studies have since shown that contact lenses do not have this effect.
On the other hand, contact lenses do not provide protection, and OSHA does not accept them as a substitute for eye protection. If someone is wearing contact lenses, they still need to wear safety glasses, but they don’t need to be prescription safety glasses.
A Thoughtful Assessment
There is more to eye and face protection than simply stating “Safety glasses are required.” It does require an assessment. Except for exposure to radiant energy, safety glasses with side shields (permanent or detachable) will protect the eyes. They won’t protect the face, so face shields may be an additional requirement for some hazard. The key to good choices for eye and face protection is a thoughtful assessment of the hazards. Make sure you’ve done one.
