The specific "should" statement you refer to is in section III of Appendix A:
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10095 which states "Contact lenses should not be worn when working with this chemical." In my understanding (and I am not an attorney), in a regulatory sense, "should" is a recommendation and not compulsory. "Shall" is compulsory, and this is not a shall. So I agree with your reading.
However, in my mind the question becomes is there *really* anything special about methylene chloride (do we even know if it is an ophthalmotoxic material?) such that vapors could be absorbed into the contact lens itself and cause an issue or release the absorbed material over time? As far as I can find, there is nothing in the rule making for the standard to support its statement regarding contact lenses:
https://www.regulations.gov/docket?D=OSHA-H071B-2006-0839 In fact, I would turn your question on its head - is there ANY evidence whatsoever that
wearing contact lenses when working with methylene chloride (or any other chemical for that matter) presents some kind of appreciable risk that would not be present to a non-lens wearer? I sincerely doubt it, in which case there is no reason to have a special policy in place. Just go with your standard decision about contact use in general.
Speaking of which, as we are all aware, the use of contact lenses in laboratories has long been a matter of considerable debate which I hope we don't devolve into an extended rehashing here (the archives have a lot of discussion if you're interested: see, for example,
http://www.ilpi.com/dchas/2004/20041115b.html (and pay particular note to the the paucity of evidence for increased risk of injury being caused by wearing lenses). CCOHS has a lengthy article that summarizes the pro and con arguments, but the main reason I point to this their article is the last section titled "Who has "responsibility" for users of contact lenses?" - it is neatly broken out into Employer and Worker responsibilities to ensure their safe use:
https://www.ccohs.ca/oshanswers/prevention/contact_len.html A definite must read if you are drafting a policy on contact lens use.
Two other items worth quick mention:
Personally, I would encourage contact lens use in the laboratory because when lab workers need to use chemically protective splash goggles, those who have wear glasses are far less likely to use the goggles because of the difficulty involved. Vision correction surgery is even better, of course!
Rob Toreki
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Safety Emporium - Lab & Safety Supplies featuring brand names
Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
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 lensesshould 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
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