Jim -

Thanks for raising this comment period.

The bigger objection that I have is that googles are rated (D3) for chemical splash protection after successful testing of a hand-operated atomizer to spray a test solution on to the googles. If no colorimetric change occurs under the googles they pass.  To me this is a good valid test that is reflective of real-world applications. (The wadding that you mention is essential to the test methodology.)

However the face-shield also receives the same designation (D3) however its test is completely different. A laser pointer is used to shine a beam on the test dummy face. A Ôpass' occurs when the face shield intercepts the laser beam before it reaches a specified area around the eyes. To me this straight line test is not reflective of fine droplets travel.

I believe since they are two separate tests , ANSI should really have two different names (Droplet Test) and two different classification markings (D3). By marking them the same most folks, including out regulators, assume their equivalency. I would like to suggest that DCHAS officially response to the comment request.

Ken

Please look very carefully at the proposed change to 29CFR1910.133. 

http://www.gpo.gov/fdsys/pkg/FR-2015-03-13/html/2015-05521.htm

I hope you all will object strenuously to the adoption of the ANSI Z87.1-2010 version.  LSI is a member of the Z87.1 committee and was in the minority.

I have three major concerns:

1.      The selection chart says that safety glasses (without side shield) and face shield are sufficient protection for chemical splash.

2.      The splash test does not go further than 90 degrees from the front. 

3.      Wadding material into spaces between the device and the face as permitted in the splash test.

The next edition, 2014, has addressed the first issue. 

Please let me know if you need more information.   É Jim

James A. Kaufman, Ph.D.

President/CEO
The Laboratory Safety Institute (LSI)
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