I would like to share with you another opinion about the proposed changes to the 29CFR1910.133. As you will see below, Christina Dillard, LSI Assistant Director, feels differently than I do about this issue. And I might add, a very healthy state of affairs!

I have great trust and respect for her point of view. She is LSI's representative on the ANSI Z87.1 committee (for the past two years).

So, I will differ to her with my fingers crossed that

1.      Not too many people mistakenly believe (once they see the uncorrected error in the 2010 Selection Chart) that safety glasses without side shields and a face shield is ok for chemical splash, and -

2.      The inclusion of the Z87.1 2010 edition provides, on balance, better protection.

Regards - Jim

Dear Jim and friends,

I'm sorry I feel differently - I support the OSHA adoption of the 2010 ANSI Z.87 standard. I feel instead of a letter to OSHA, the public needs a guidance document for the selection of properly fitted eye protection that is proportionate to the hazards posed. I would be happy to work on such a document with "all" your help.  

First, I feel that the 2010 addition of a test for splash is an improvement over the 2003 version which did not have such a test.

To address Jim's concerns directly:

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

a)     The selection cart is informative only. It is merely a tool to help aid the selector of eye protection in their decision. The chart is not meant as a standalone item for the selection of eye protection. J.11 states: The end user

should carefully match protectors with other personal protective equipment to provide the protection intended.

b)     Yes there is an error on the chart. The word googles is followed by a unpaired closed parentheses. When the chart was made something was not "cut and pasted" correctly. For an informative chart only I do not feel this is sufficient reason not to adopt the standard.

c)     There is inconsistent reference of spectacles with/without side protection throughout the selection chart. If the first listing suggests "spectacles with side protection" the "with side protection" is not stated again, but I feel is implied.

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

a)     This is for the face shield only, not for googles.  2003 had no test for splash hazards associated with a face shield. While the 2010 test may not be perfect it is better than no test.

b)     Goggles must be tested for "all directions" 9.16.1.3 Spray the mounted protector with approximately 5 - 10 ml of the spray solution, holding the atomizer at a distance of approximately 600 mm (23.6 in.) from the headform and spraying from all directions

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

a)     Note that 9.16 states: This test is intended to determine the capability of the protector to keep liquid splashes or sprays from reaching the wearer's eyes. This is not intended to evaluate the fit of the protector to the wearer's face. I feel that this test is not invalidated by permitting extra material to be built under the cheek area of the mannequin head. However, it does indicate that not all head shapes will be appropriate for the goggle that was tested. Fit is crucial for the appropriate outcome.  9.16.1.3 Adjust the number of layers of lint, as necessary, to ensure a good seal between the protector and the headform. The selector of eye protection now must also be responsible for ensure there is a "good seal" for the protector to the face. Section J.11 of the standard states Because of individual facial characteristics, care must be exercised in fitting goggles to ensure that a snug fit around the face is achieved in order to provide adequate protection.

b)     As this addresses specifically that the brand Visorgogs has been tested by an independent lab and met the requirements of this test. The goggle may now be sold with the D3 designation. But so may many other googles that range tremendously in size. An extra-large standard indirectly vented goggle while it will receive a D3 will only fit a select few individuals. The Visorgog will appropriately fit probably the same faces - large faces with heavily padded cheekbones.

c)      Note though the new test does eliminate the D3 designation on adjustable ventilation goggles. 5.5.1 If the goggle is equipped with adjustable ventilation, the protector shall be tested in the maximum open position

The 2003 version stated: 8.9 Ventilation Requirements When goggles are provided with openings to allow circulation of air, venting shall be consistent with the intended application of the goggles.

To address Ken's question about state goggle statutes: state goggles statutes will still be enforced?

So far I only know of 23 states that have such a statute. If you know of more than what is on my list attached, please include or direct me to your source of information.

Also note that most of these statutes were written in the 1950's or early 60's and reference what is now the z87 standard so the goggle statutes do not stand on their own.

In 1962 the Safety Standards Board approved the division of the Z2 Committee into three separate projects: Z87 - Industrial Eye Protection, Z88 - Respiratory Protection, and Z89 - Industrial Head Protection. In the Z87 Standards Committee, membership was reconstituted and broadened in 1973 to include all organizations with a substantial interest in the design or use of eye and face protection. The Committee revised the 1968 version, which was approved on February 27, 1979 as the American National Standard for Occupational and Educational Eye and Face Protection, ANSI Z87.1 - 1979.

Further support for my original statement about at least 2010 introduced a splash test:

1.      The 2003 version Relies solely on the interpretation of the selector to determine if the eye protection is appropriate for a splash. Guidance is offered through the following statements:

6.1.2 Goggles provide more protection than spectacles from impact, dust, liquid splash and optical radiation hazards.

Direct ventilated goggles permit the direct passage of air from the work environment into the goggle and are not recommended for

use in protection against liquid splash hazards.

Indirect ventilated goggles permit the passage of air and may prevent the direct passage of liquids and/or optical radiation. Goggles with no

provision for ventilation minimize passage of dusts, mist, liquid splash and vapor.

While I believe each of these statements is accurate it does not provide any definitive information about whether or not the googles will actually protect from a splash hazard. The selector then must be sure they understand what is indirectly vented.

2.      The 2003 version of the standard does not allow for development and us of new hybrid eyewear protection that may be a fitted spectacle that makes an eyecup seal to the area around the eyes and may also protect from liquid splash.

3.      In the 2003 version there was also no test for splash for the face shield.

My 2 cents,

Christina L. Dillard

Assistant Director

The Laboratory Safety Institute (LSI)
A Nonprofit International Organization for
Safety in Science and Science Education
www.LabSafetyInstitute.org

192 Worcester Road, Natick, MA 01760-2252
Phone: 508-647-1900 Fax: 508-647-0062 Cell: 781-789-1178

CDillard**At_Symbol_Here**LabSafetyInstitute.org

P We thank you for printing this e-mail only if it is necessary