The meaning of “should” and “shall” in the OSHA regulatory context is clear and long established.

“Should” is advisory and “shall” is mandatory.

The MeCl standard you quoted is recommending that contacts not be worm, it is not forbidding. It is not requiring some additional assessment before they can be  permitted.  It is merely recommending.

I believe the American Ophthalmological Association issued a position paper a good many years ago saying that use of contacts in a chemical lab is not a hazard in the vast majority of situations, but is not a substitute for safety glasses or goggles.

Peter Zavon, CIH
Penfield, NY

PZAVON**At_Symbol_Here**Rochester.rr.com

Hello,

Our chemistry lab currently does not allow anyone to wear contact lenses in the labs.  I’d like to propose that we allow contacts under safety glasses, goggles or face shields.  We do use methylene chloride, many different corrosive chemicals and potent compounds (mostly in chemical fume hoods but sometimes on the open bench top if dilute or in very small quantities).  The dilemma I’m facing is that OSHA states in 1910.1052 for Methylene Chloride that contact lenses should not be worn when working with this chemical.  I take this a recommendation not a hard rule.  Some of my safety colleagues interpret “should not” to mean that contacts can be worn as long as I can prove that a hazard does not exist (which I don’t think I can do but I feel comfortable with the risk level, citing NIOSH recommendations and scientific studies but not all studies are well enough designed to prove there is no hazard). 

My hazard evaluation would include listing the chemicals that are more of a hazard and training the chemists accordingly and letting the chemists decide if they want to take the risk or decide not to wear contacts and order the prescription safety glasses that the company will buy.  Some safety people want me to limit contact lens use only for chemical use that will pose no hazards.  However, in a very large lab with hundreds of chemicals that are constantly changing this would be more work than I feel value added and would confuse the chemists leading to non-compliance. 

I would like your thoughts,

Mary

Mary Biersack

Lab Safety and Chemical Hygiene Specialist

West Pharmaceutical Services, Inc.

P: +1 610-594-3278

530 Herman O. West Drive | Exton, PA 19341 | United States

mary.biersack**At_Symbol_Here**westpharma.com

Find West on Twitter and LinkedIn.

The contents of this message are confidential and may be privileged. If you have received this message in error, please permanently delete it, along with any files that may be attached to this message, without reading, printing, copying, forwarding or otherwise distributing it. Please notify the sender of the error immediately so that we can prevent it from happening again.

--- This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety. For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org