On December 29th, 1970, President Richard Nixon signed the Occupational Safety and Health Act. This landmark bill created the Occupational Safety and Health Administration, or OSHA, a regulatory body whose mission is to prevent work-related injuries and illnesses by creating and enforcing standards for workplace safety and health, including directed references to standards for Personal Protective Equipment, or PPE.
OSHA sets policies for implementing inspection programs to identify and mitigate workplace hazards, and provides guidelines on enforcement policy. While it is vital for safety professionals to be familiar with the regulations set down by OSHA, it is equally important to be aware of circumstances in which PPE may need to go above and beyond the referenced standards.
Letter of the Law
For federal regulations dealing with PPE, 29 CFR 1910, Subpart 1, is the relevant OSHA guidance document for general industry. Section 1910.133 specifically addresses Eye & Face protection:
“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. Such equipment shall be durable, fit properly and be reasonably comfortable.”
While OSHA regulations establish a firm’s responsibility to protect its employees, they do not detail the specific performance requirements that PPE must meet; i.e. what impact force a lens should withstand, or how much UV radiation it should absorb. Rather, they cite recognized product standards, which in the case of eye and face protection is ANSI Z87.1. The American National Standards Institute, or ANSI, is an independent, non-profit agency that adopts consensus standards which set minimum product performance requirements.
All ANSI standards are updated periodically, and Z87.1 was most recently revised in 2010. Companies generally demand PPE products that are up to the latest Z87.1 standard. Producers of PPE, keen to stay on top of the competition, stick to the latest version as well. All products offered as compliant will be marked with the manufacturer’s mark and Z87 as described in the standard.
Brace For Impact
Z87 is a performance based standard, addressing the primary hazards of heat, chemical splash, dust, optical radiation and, very importantly, impact. Impact resistance is a priority with good reason: OSHA estimates that 70% of eye-related incidents are caused by flying objects or particles striking the eye.
Two levels of impact resistance are defined: products labeled Z87 that provide a minimum level of impact resistance, and high-impact products, labeled Z87+, that provide elevated protection against high mass and high velocity projectiles.
(Note: Companies seeking more assurance against impact from their eyewear should look for products that meet the US Military’s MIL V0 standard, which provides resistance against shrapnel-like particles moving at speeds of at least 650 feet per second—projectiles that deliver seven times the energy of those used to test for the Z87+ standard.)
Other Hazards, Other Rules
Z87.1-2010 now defines requirements for eyewear offering protection against chemical splash and dust, and also provides guidance on the applicable product categories. Test methods have been defined and products in conformance will carry specific markings.
OSHA gives explicit requirements with regard to “injurious light radiation”—for example filters to block the ultraviolet and infrared radiation produced by welding and other industrial processes. A listing of the appropriate shade rating for injurious radiation sources can be found under OSHA regulation 1910.133(a)(5), accessible online at at osha.gov. Z87.1-2010 provides information on lens filters and markings reflective of the radiation type and protection level.
Penalties, Legal & Otherwise
OSHA regulations clearly reference product performance standards, and the consequences for violating them can be severe. Violators can be fined up to $70,000, and a willful violation that results in the death of a worker can lead not only to a hefty fine, but potentially a jail sentence for the responsible party. On top of these legal penalties, one must remember the financial burden that accompanies all injuries. Huge costs can mount in lost time, damaged equipment and increased insurance premiums.
Conclusion: Above & Beyond
In summary, OSHA has created regulations pertaining to hazard identification and requires that employees be provided with appropriate PPE. Section 1910.133 of 20 CFR 1910 defines specific requirements for eye and face protection. This equipment shall be in conformance with ANSI Z87.1 which is incorporated by reference, effectively giving it the weight of law. The most recent edition of Z87.1, just released in 2010, is hazard based, and covers the performance and marking requirements for compliant PPE. Manufacturers are a valuable source of information and their products will meet, and often exceed, minimum requirements.
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