International Influence

Will the Z87.1 Committee take an entirely new approach when the eye and face protection standard is revised in 2008?

PUBLISHED in August 2003, ANSI Z87.1-2003, the revised American National Standard for Occupational and Educational Eye and Face Protection Devices, brought end users, eye care practitioners, and PPE suppliers a new classification system--"Basic Impact" and "High Impact" protectors--with testing requirements and performance criteria to support it. Z87.1 Committee members spent much of the year after the 2003 version came out educating those communities about how to use it.

Now, members are thinking seriously about making more substantial changes in the standard as soon as May 2008, its next date to be reaffirmed, revised, or rescinded.

Some want to seize the opportunity to harmonize this U.S. standard with the ISO eyewear standards that are being revised on the same schedule, and more broadly to move it closer to eyewear standards used in Europe and other countries. There's enthusiasm on the committee for making the U.S. standard more application-specific--that is, putting language in the body of the standard that tells users what protection they should use in specific situations. While a pull-out Selection Chart in Z87.1-2003 already does this, saying what types of goggles, spectacles, faceshields, and other protectors should be used for five specific hazard categories (impact, heat, chemical, dust, and optical radiation), some committee members want to go further.

"I think the Europeans to their credit do a pretty good job of that. They put them into categories, more than ours but not so many that they kill you," said Phil Johnson, who leads the Z87.1 Committee goggles work group and also leads a work group for the ISO standards.

Perhaps the standard should classify all eyewear by the type of hazard a user is trying to protect against, said Nancy Yamasaki, who heads the work group on terminology/definitions. "What are the proper things we should be protecting against? Welding light? Splash? Biohazard? High-speed impact? Splatter from solder?" asked Yamasaki, who is director of intellectual property at Younger Optics of Torrance, Calif., and is involved in her company's R&D. She said she wants the standard ultimately to have some kind of decision tree for making product selections.

John Salce, who leads the spectacles work group, agreed some committee members think a standard should be written not around a device, but around a hazard. European and Australian eyewear standards do this, he said, by containing sections devoted to specific hazards. Salce, an Aearo scientist in Southbridge, Mass., said there are many issues to address as the committee meets again in Baltimore next month and moves ahead with the next revision cycle. The decision to adopt a hazards-based format will take time.

"That's going to be a long one," he said. "We've really got to resolve what are the pros and cons to that approach. What's the impact on the end user? We need to make something that is really useable by the end user. My personal opinion is that a product selection chart like we have in the 2003 standard is a giant step toward that."

Implications of a Global Approach
Following the European course raises two issues, said Johnson, who is vice president of research and development and quality assurance for Bacou-Dalloz Eye & Face Protection Inc. of Smithfield, R.I. First, can you get the U.S. technical experts to agree on the test methods? Second, will U.S. eyewear manufacturers buy into the test methods?

"I could picture some of them saying, 'We don't have that many dead bodies now. Could there be that many problems with our standard as it is?' " Johnson said he answers by saying a good test method is good no matter where it comes from, and a manufacturer benefits if its product meets that test. End users benefit, too.

The U.S. system of marking protective eyewear would have to change. European markings are much different: Their markings are 10-12 characters long, with letters engraved on the product to show each hazard it protects against. Australia, with similar test methods, has different markings; so do Canada and Japan. What Johnson wants is one international standard and one set of marks that are accepted in every country. You could pick up a product anywhere and know exactly what it would protect against, he said. "That would be nice. It's certainly selfish and I don't know if I'll live to see it . . . . We may not get there in the next iteration, but that's certainly the direction we're heading."

It was Z87 Committee Chair Dan Torgersen's idea to divide the 31-member committee into work groups earlier this year. "The work groups are giving us a chance to focus in more closely on critical areas," Salce said. "Each section of the standard will get its full share of attention. We are really aiming. Rather than shooting a shotgun, we're shooting a rifle."

MIA: Eye Injury Report Forms
A question still unanswered one year after the 2003 standard's completion is this: Where are the Eye Injury Report Forms? In the event of an employee's eye injury, the standard asks employers to submit one via Z87.1's Secretariat (originally the American Society of Safety Engineers, but the International Safety Equipment Association took over in June 2004). When interviewed for this article in August 2004, Torgersen said neither ASSE nor ISEA had received a single form.

"That's one of the last things you think of," he reasoned, "because the 2003 standard is not regulatory. And the 1989 standard did not contain that requirement. Since that is not an obligatory item, you can choose to ignore it without penalty." Also, end users are not as familiar with the EIR form as they are with the OSHA injury report form, which they know--or should know--to complete after an eye injury, he said.

"I am still hopeful" the EIR forms will be used, added Torgersen, who is vice president of information systems and special projects for Walman Optical Co. of Minneapolis and technical director for the Optical Laboratories Association.

He said the 1989 standard arose because of the U.S. Bureau of Labor Statistics information indicating lots of eye injuries were being caused by impact from an angle. The standard's committee responded by recommending side impact protection, which OSHA later made mandatory. "So we could find out [from the reports] something the standard could be modified to address," he said.

Salce noted eyewear manufacturers are notified about many eye injuries, even if Eye Injury Report Forms aren't filed. "We get some stuff like that, but it would be wonderful if we got these eye injury reports," he said. "That would tell us exactly where to aim that rifle, instead of us committee people saying, 'This is where we think we should go.'"

'Very Unexpected' Test Failures
The committee's 31 members are representatives of labs; frame, lens, and goggle manufacturers; end users; ophthalmologists and surgeons; NIOSH and OSHA; and more. Beyond the looming questions of splitting Z87.1-2003 into sub-standards, each about a specific eye and face protector type, and whether it should follow the international models, the members have been discussing a new test fixture for high-impact tests of prescription lenses.

Polycarbonate lenses with some abrasion-resistant coatings and anti-reflective coatings are failing, which was "very unexpected," Torgersen said. Naturally, the committee did not want its test method to fail what is normally considered a very safe product, the polycarbonate lens. Three members have been actively studying the failures and will present findings and recommendations in Baltimore; Torgersen said he expects they'll recommend modifying the test fixture. The 150 feet per second impact will remain, and the same steel plate with beveled edge will be used. To be valid, the lens has to be edged evenly, he said, but what's happening is the lenses that fail sit unevenly, resting at two or three points that are highly stressed on impact. The committee will look at the FDA's test mounting, which uses a fixture with a thin neoprene gasket that gives to some degree, he added. Assuming it is done through a technical addendum, the earliest the change could be made in the standard is June or July 2005.

A big question addressed at the May 2004 meeting involved high-mass testing for lens retention in a frame. (The test uses a one-pound conical weight dropped from 50 inches. If displacement of the lens or detachment of lens material occurs, the frame fails.) A lab sent in a photo showing how the projectile had embedded itself in a lens with no material detached. "It passed. But if a microgram of coating had flaked off, it would've failed," Torgersen said. Committee members debated this and informed the lab it could tell its manufacturer customer that the frame had passed the test. He said the committee may add explanatory text in the 2008 revision to explain why such a result would pass.

Salce has been compiling a chart comparing all standards worldwide that address the optical properties of spectacles, and Yamasaki has been studying Australian and European impact standards. "The Australian one bridges it [the U.S. standard]" with three categories: low, medium, and high impact, she said. But Australia uses a much faster impact for its high and just 31 feet per second for its low, suggesting they are looking at different hazards, she said. And Europe doesn't have high-velocity testing for prescription lenses, only a deflection test that lowers a 10-kilogram weight onto a lens to see how much it deflects.

"Mostly, I just want to make sure that the tests are rational. Just because they've been there for a long time doesn't mean they work for today's users," Yamasaki said. "You can't approximate reality, but you come as close to it as you can."

Additional Issues
Asked what else of importance the December meeting will accomplish, Torgersen said the work groups are just cranking up now. The committee's members talked in May 2004 about candidate issues for discussion and potential revision; the December meeting will involve more concrete planning of what they'll address, he said.

"You never run out of ideas to pursue," Salce said. For example: Should the standard contain separate sections for prescription versus nonprescription spectacles? Style also arises. The current style of ophthalmic prescription eyewear utilizes very thin, small lenses--should the safety market go that way? Can a small lens be made that can give enough protection? Maybe the frame can be designed to compensate, he said, asking, "Should the standard comment on it? Should it be controlled?"

The United States tests 20 sites on an eye protection device for high impact, while Europe and other countries use different sites. Which method is better? "There's a million little things like that within the standard to address," he said. What about the "reader" portion of the plano lens that is coming into the safety market? Though these are being manufactured, the standard doesn't speak to them at all. Also, Z87.1-2003 says the "manufacturer" does the testing. Salce and Yamasaki are asking whether the standard should define "manufacturer." When assembly, lens cutting, frame manufacture, lens blank manufacture, and distribution are separate functions, they said, who is the "manufacturer"?

It is conceivable the committee even may add some breathing room in the 2008 standard for manufacturers. That question arose during the May 2004 meeting, Salce said.

"Some people feel that we're the tightest in the world. We are fairly tight. Do we need to be?" said Salce. "Are we too loose?" But at the same time, he's wary of relaxing Z87.1-2003 because that would send the wrong signals. "You want a lot of research and data before doing that," he said. "You're very careful about relaxing a standard."


For More Information
International Safety Equipment Association (ISEA)
Janice Comer Bradley, CSP, Technical Director
www.safetyequipment.org
Phone: 703-525-1695
Fax: 703-528-2148
jbradley@safetyequipment.org

This article originally appeared in the November 2004 issue of Occupational Health & Safety.

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