In this installment of “Voice of Experience,” we will take a look at the wording in OSHA 29 CFR 1910.133, “Eye and face protection.” A review of this standard is a great opportunity to gain a better understanding of what OSHA requires of both the employer and employee in order to properly protect these vital body parts in the workplace.
The standard begins with general requirements. Rule 1910.133(a)(1) states, “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.”
The injurious light radiation referenced in the preceding paragraph is a result of welding. In order to protect the employee’s eyes, the correct light filter shall be identified by the type of welding performed. We will discuss the UVA and UVB rays emitted from an electrical arc a little later in this article.
The Employer’s Responsibility
Before we get to that, though, I want to remind readers that as of May 2008, the employer is responsible for providing all PPE to employees when the written PPE hazard certification requires eye protection for the task being performed and the exposure. The employer must, at a minimum, provide nonprescription safety glasses that meet the 2003 ANSI Z87.1 standard for eye and face protection devices. The current OSHA PPE standard still references the 2003 high-impact standard even though the ANSI Z87.1 standard was updated in April 2010.
Note that an employee may provide their own eye protection if they so choose, but the employer must inspect and approve the PPE to ensure it meets the minimum OSHA and consensus standard requirements. The inspection and approval must take place before the employee is exposed to any job-related hazards.
The ANSI Z87.1 Consensus Standard
If you ask most utility employees about workplace eye protection, they will usually mention the ANSI consensus standard that describes the type of eye protection that is mandated. OSHA requires ANSI Z87+ glasses by reference as stated in 1910.6, “Incorporation by reference.” Specifically, 1910.6(a)(1) states, “The standards of agencies of the U.S. Government, and organizations which are not agencies of the U.S. Government which are incorporated by reference in this part, have the same force and effect as other standards in this part. Only the mandatory provisions (i.e., provisions containing the word "shall" or other mandatory language) of standards incorporated by reference are adopted as standards under the Occupational Safety and Health Act.” ANSI Z87.1 is then directly named in 1910.6(e).
Unfortunately, many employees fail to understand what the ratings on safety glasses mean and how important they are. The plus sign on the label indicates a difference in polycarbonate lens strength. Since, again, safety glasses have to meet the 2003 Z87.1 standard, the plus sign indicates that the lenses have twice as much protective strength as lenses that only meet the 1989 standard. The standard was revised again in 2009, and the 2010 extensive testing assures the protection required by the OSHA PPE standard. Impact-rated protectors must meet the established high-mass and high-velocity tests, and defined, continuous lateral coverage is now mandatory. Protectors that satisfy the requirements carry the Z87+ mark on both the lens and the frame or housing. This is the same type of marking found on 2003 glasses that are being provided, and will likely be picked up by OSHA in the future.
The bottom line is that nothing less than Z87+ protectors should be used by employees. The Z87.1 or Z87+ lenses also filter 99.99 percent of all UVA and UVB light from electrical arcs. These ultraviolet rays can cause damage to the retina, a light-sensitive layer of tissue found at the back of each eye that receives images and sends signals to the brain about what is seen. Damaged retinas can lead to total blindness.
Prescription Lens Rules
Per rule 1910.133(a)(3), “The employer shall ensure that each affected employee who wears prescription lenses while engaged in operations that involve eye hazards wears eye protection that incorporates the prescription in its design, or wears eye protection that can be worn over the prescription lenses without disturbing the proper position of the prescription lenses or the protective lenses.”
This means that if an employee wears prescription lenses, the employer must furnish an over-the-glass type of goggle that provides the same protection as nonprescription safety glasses. There is no requirement that an employer has to provide safety-rated prescription safety glasses. It’s also important to keep in mind that, unlike arc thermal protection apparel, eye protection cannot be provided in layers; the full requirements must be met by the outer layer of eye protection. Across the U.S., prescription eyewear programs vary between investor-owned utilities, cooperatives, contractor companies and municipal utilities. Some employers have negotiated benefits that provide prescription safety glasses, while others simply provide protective goggles that are worn over the employee’s personal prescription lenses.
New Final Rule Requirements
The new final rule that affects 1910.269 and 1926 Subpart V also requires arc-rated face shields for arc exposures equal to or greater than 9 cal/cm2 on single phase-to-ground arcs, and equal to or greater than 5 cal/cm2 on three-phase arc exposures. Rule 1910.269(l)(8)(v)(C) states that “[a]rc-rated protection is not necessary for the employee's head when the employee is wearing head protection meeting § 1910.135 if the estimated incident energy is less than 9 cal/cm2 for exposures involving single-phase arcs in open air or 5 cal/cm2 for other exposures.” A company’s written PPE hazard assessment should be updated to include these additional PPE requirements.
Once an employer provides the necessary training to all employees expected to wear PPE, the employees are then responsible for wearing eye protection when it is required by a standard, an employer policy or both. Employees must also keep their eye protection in a clean, sanitary condition, as well as request replacement PPE if theirs becomes damaged or has been used for its expected life cycle.
Safety-rated eyewear is included in the PPE standard and is also referenced as a subject to be covered in job briefings per 1910.269(c)(2). Workers should always perform hazard analyses as required to identify when eye protection is necessary, and they should always wear the protection when it is required. If employees have questions or need additional information about eye and face protection, they should contact their supervisor or company safety and training specialist.
About the Author: Danny Raines, CUSP, safety consultant, distribution and transmission, retired from Georgia Power after 40 years of service and opened Raines Utility Safety Solutions LLC, providing compliance training, risk assessments and safety observation programs. He is also an affiliate instructor at Georgia Tech Research Center OSHA Outreach in Atlanta. For more information, visit www.electricutilitysafety.com.
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