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 From:
Christina Dillard [mailto:cdillard**At_Symbol_Here**labsafetyinstitute.org]
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 CDillard**At_Symbol_Here**LabSafetyInstitute.org P
We thank you for printing this e-mail only if it is necessary
Sent: Monday, March 23, 2015 1:02 PM
To:
'Safesci'; 'Jim Kaufman'
Cc: 'Brian Wazlaw'
Subject: RE:
OSHA Eye Protection Update
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