Try This Recipe for Eye & Face Compliance

OSHA's guidance and state plans' regulations spell out the duties of employers in this area.

OSHA's PPE standards and its handy eTool are the first stops to make when the question concerns eye and face protection. 29 CFR 1910.132 (general requirements), 1910.133 (general industry), 1915.153 (maritime), and 1926.102 (construction) say employers must ensure each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids, caustic liquids, chemical gases or vapors, and potentially injurious light radiation. The standards and eTool are available online. Try www.osha.gov/SLTC/etools/eyeandface/index.html for the latter.

This PPE category includes spectacles with and without sideshields, goggles, faceshields, and welding helmets. Innumerable operations demand their use, including acetylene cutting, welding, chipping, chemical handling, grinding, lab work, carpentry, cleanroom tasks, dentistry, and many more. The basic requirements for these protective products are, as Oregon OSHA and federal OSHA list them:

1) They shall provide adequate protection against the particular hazards for which they are designed.
2) They shall be reasonably comfortable when worn under the designated conditions.
3) They shall fit snugly and shall not unduly interfere with the movements of the wearer.
4) They shall be durable.
5) They shall be capable of being disinfected.
6) They shall be easily cleanable.
7) They should be distinctly marked to facilitate identification only of the manufacturer.

Also, eye protection products should meet ANSI Z87.1-2003, the current edition of the American National Standard for Occupational and Educational Eye and Face Protection Devices.

To order a copy of ANSI Z87.1-2003 or the Eye and Face Protection Use and Selection Guide published as a companion to it, contact the International Safety Equipment Association, 1901 North Moore St., Arlington, VA 22209-1762 (phone 703-525-1695, fax 703-528-2148, e-mail info@safetyequipment.org).

Hazard Assessment, PPE Maintenance
Employers should conduct a comprehensive hazard assessment to make sure they are addressing workers' exposures to those hazards. Providing adequate training for all workers who require eye and face protection is mandatory. When employees are trained to work safely, OSHA says, they should be able to anticipate and avoid injury from job-related hazards.

The training in proper care, maintenance, and disposal of PPE is covered in 29 CFR 1910.132(f)(1)(v). PPE must be used and maintained in a sanitary, reliable condition, and defective PPE should not be used at any time. This means eyewear with pitted or cracked lenses should be replaced. Cracked hard hats definitely should be replaced without delay. If a hard hat's suspension is frayed or worn, replace it. Remind employees who are assigned PPE for extended periods or own it themselves to clean and disinfect it frequently.

OSHA says the most effective way to disinfect eye protection equipment is to disassemble the goggles or spectacles and thoroughly clean all parts with soap and warm water. Rinse off the soap carefully. Replace all defective parts.

Goggles should be kept in a case when they are not in use, the agency advises, adding, "Spectacles, in particular, should be given the same care as one's own glasses, since the frame, nose pads, and temples can be damaged by rough usage."

Check Your State Plan, If You Have One
It's always a good idea to check your own state plan's regulations, if you live in a state that has such an approved plan in place. (You can visit www.osha.gov/fso/osp/index.html to find a list of them.)

In its Spring 2005 newsletter, the Michigan Occupational Safety and Health Administration (MIOSHA) noted that its three PPE standards require employers to provide, at no expense to the employee, the initial issue of the type of personal protective equipment that is suitable for the work to be performed. OSHA's PPE standards do not address who must pay for personal protective equipment, and the federal agency has been trying since early 1999 to clarify the payment responsibility through rulemaking.

Michigan's MIOSH Act says an employer must provide PPE at its own expense when required by a rule or standard. MIOSHA noted the act provides guidance for determining who should pay, including these criteria:

* Whether the equipment is transferable between employees
* Whether the employer maintains the equipment
* Whether the equipment generally remains at the work site after the work activity has been completed
* The amount of personal use involved with the equipment.

MIOSHA and other state plans are watching OSHA's PPE rulemaking activity closely. At this writing, federal OSHA has not announced how it will settle the "tools of the trade" question it raised when it reopened the record for additional comments in 2004.

This article appeared in the March 2006 issue of Occupational Health & Safety.

This article originally appeared in the March 2006 issue of Occupational Health & Safety.

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