This will certainly be a robust debate. I will summarize my comment thus: while I agree with the spirit of your proposal, agree that safety glasses that are worn properly on the eyes are far better than foggy goggles protecting the forehead, and I do exactly what you describe when I personally work in the lab, unfortunately, you can't plan when an accident will happen.

I have run into a few cases where goggles did work out better where glasses might have been used.

1. An undergraduate lab in which a waste bottle exploded during cleanup. A student on the other side of the lab was wearing his goggles even though he wasn't "doing anything". Glass bounced right off the lenses. Now, perhaps glasses would have protected him here, but if his head was at a slightly different angle, who knows. And I have seen or heard about several unexpected waste bottle explosions and runaway hotplate types of things that could generate the same scenario although those were in research labs where, presumably the risks and hazards are higher.

2. A student needed 2 mL of concentrated nitric acid. I assume under the proposed guideline that this would mandate goggles over glasses, but it creates a gray area - is any amount of something a goggle-level hazard and what concentration? I ask, because the student took a 10 mL graduated cylinder and tried to pour the concentrated nitric acid into it directly from a 4 liter bottle instead of using a beaker and/or pipette. He bent down close to the bench so he could read the scale and, predictably, poured concentrated nitric acid all over his face. I'm not sure if students were authorized to use that big bottle. The issue here is that students will not always follow predictable or best practices, finding new ways to endanger themselves that we might not otherwise anticipate.

My other concern is students will not be switching off properly when step 2 of a procedure requires goggles, but step 1 doesn't. And there=E2=80™s a group doing step 2 working across from a group still on step 1. And then there's the whole liability thing.

You know I have the utmost respect for you and value your contributions, Dave, but we have to be careful with comments like the statement about 38 years without incident. That's what all the teachers who burned their students with flaming solvents said - "I've done this before without any problems". Now, that's a bit of an unfair statement; I recognize the distinction, of course, regarding safety awareness, knowledge and vastly greater experience here, and you are right - the cases for always-goggles are luckily very few thanks to good risk assessment and mitigation policies for these kinds of labs, particularly at the post-secondary level where the instructors have far better training, resources, experience, and vetting.

Would I stand on the rooftops opposing this proposal? No, as I said, it's what most every researcher does (except for the biologists, it seems, who use no eye protection at all). But I am more circumspect in the undergraduate labs where one can not always monitor 24 sets of hands simultaneously.

Rob Toreki

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On Nov 7, 2019, at 11:14 AM, David C. Finster <dfinster**At_Symbol_Here**WITTENBERG.EDU> wrote:

I would like to query the group about eye protection.. As I understand it, the current and long-standing position taken by the ACS is the recommendation for the use of splash goggles and that using safety glasses is discouraged.

As a starter, Prudent Practices (2011) states:

"Researchers should assess the risks associated with an experiment and use the appropriate level of eye protection:

• Safety glasses with side shields provide the mini =ADmum protection acceptable for regular use. They must meet the American National Standards Insti =ADtute (ANSI) Z87.1-2003 Standard for Occupational and Educational Eye and Face Protection, which specifies minimum lens thickness and impact resistance requirements.

• Chemical splash goggles are more appropriate than regular safety glasses to protect against haz =ADards such as projectiles, as well as when working with glassware under reduced or elevated pres =ADsures (e.g., sealed tube reactions), when handling potentially explosive compounds (particularly during distillations), and when using glassware in high-temperature operations.

=E2=80=A2 Chemical splash goggles or face shields should be worn when there is a risk of splashing hazardous materials or flying particles."

I have always interpreted the ACS position to intend to apply to (at least) academic labs where:

1. It is desirable to require student to purchase only one kind of eye protection, and, therefore
2. Splash goggles are required since they will necessarily protect in "all labs" whereas safety glasses would protect <100% of the time since they would not provide adequate protection in the presence of liquid chemicals.

As a note in prelude to the rest of this email, I'll observe that at my college we have required safety goggles for at least the past 38 years. The main argument rests on the two statements above.

I make the following assertions:

1. Students must wear some form of eye protection in all labs that use chemicals.
2. If we wish to teach students how to use any form of PPE, they should be taught how to identify hazards and judge the level of risk.
3. In our general chemistry program, there are perhaps 1-2 experiments where, in a worst-case scenario it would be advisable to wear splash goggles instead of safety glasses.
4. Having taught general chemistry for 38 years, I can think of no episode where safety glasses would not have provided the necessary level of eye protection. Otherwise stated, in general chemistry we have never experienced a "splash episode" that threatened the face at large. (Frankly, I can think of no episode where any eye protection was actually "used" in the sense of protecting eye contact by a lab chemical - but I am surely not inclined to recommend "no eye protection".)
5. Wearing goggles is less comfortable than wearing safety glasses. "Comfort" does not trump "safety" but, particularly in light of the desire to wear "appropriate PPE" (based on a risk assessment,) it seems inappropriate to have students wear unnecessary PPE (ie, splash goggles).
6. While I know of no hard data in this matter, conversations with colleagues and the examination of websites suggests that wearing safety glasses is commonplace at many colleges and universities. Further, conversations with former students who went to graduate school and/or into industry suggest that safety glasses are much more common in these environments (despite the widely held view that "industry is safer than academia"). Thus, it seems that the ACS recommendation that is widely ignored.

Given these assumptions, I am considering a new recommended policy (that the ACS may wish to consider) that posits that student should purchase both safety glasses and splash goggles and then wear the appropriate eye protection during each lab. The choice of eye protection can follow an appropriate hazard and risk assessment for each experiment. There is a financial cost (to the student) for this recommendation, but since most students will progress on to organic chemistry (where the need for splash goggles in likely higher) the cost can be spread out over other parts of the curriculum. The clear advantage to this recommendation is that it fosters the use of RAMP on a regular basis and students are wearing appropriate eye protection all the time as determined by a needed risk assessment that minimizes the risks of hazards.

(The cost issue is not catastrophic: I found the splash goggles that we use online at $13 and the safety glasses look like about $7. Interestingly, our bookstore charges $24 for the goggles!)

Of course, any campus can adopt this policy irrespective of ACS recommendations. And, some campuses may decide that safety glasses are appropriate at all times (but this seems unwise to me).

I welcome the wisdom of the group on this matter.

Dave

David C. Finster
Professor Emeritus, Department of Chemistry
Wittenberg University

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