IN THIS NEWSLETTER WE COVER
Eye Injury Prevention Requirements & Regulation

Use the right protection for eyes (Automotive Industry)

Prescription Glasses are not Safety Glasses

Policy, Training, and Enforcement Issues

CDC reports that more than 2000 workers sustain a job-related eye injury each day. About a third of the injuries require a trip to the hospital while hundreds of these require days away from work.  The cost of these injuries results in lost production exceeding $300 million.  Eye injuries can be prevented by using proper eye protection.  The harsh reality is that eye injuries can be permanent in nature.

Regulations: OSHA regulations mandate that employees wear eye protection where there is a risk of an eye injury.  Specifically, the regulation states in part that “the employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.”  See 29 CFR 1910.133 (a) (1) (Fed) or 8 CCR 3382 (CA).

Eye Protection: There are four general types of eye protection used in the automotive industry:

• Safety glasses
• Safety goggles
• Face shields
• Welding goggles & welding helmets

Before selecting an appropriate eye injury prevention device, the employer must complete a workplace hazard assessment. While safety glasses are the most versatile and commonly used injury prevention device, they have several limitations as discussed below.  Additional or alternative protection may have to be used.

Safety Glasses: Safety glasses are a base level protection against flying objects, tools, and relatively large particles.  Safety glasses do not provide protection from chemical splashes or prevent vapors entering the eyes. Safety glasses must meet the ANSI Z87.1 standard. Polycarbonate safety glasses with ultra-violet (UV) protection and scratch resistant and anti-fog coatings can be purchased for less than $3. Safety glasses have the limitation that they have small gaps at the top, side, and bottom.

Safety Goggles: Unlikesafety glasses, safety goggles provide 360-degree coverage around eyes with no gaps. Hence, they are ideal for protection from chemical splashes such as those caused by a battery explosion. For example, an electrical spark at the terminal may ignite the hydrogen accumulated inside the battery.  While a strap holds the goggles in place, the vents for air flow prevent fog from building up inside the goggles.

Face Shields:  Face shields are considered a secondary line of protection above safety glasses and safety goggles. Face shields alone are not considered adequate eye protection.

Welding Goggles & Welding Helmets:  Welding goggles and helmets are required to protect eyes during welding operations.  The minimum protective shade requirements depend upon the type of welding being performed. Welding helmets are versatile in that helmets are required for gas tungsten welding whereas a welding goggle can be used in oxygen cutting torches.  The gas welding and oxygen cutting requires a shade protection from 3 to 6 (depending on the plate thickness), gas tungsten arc-welding requires a minimum protective shade of 7 to 10 (depending upon the arc current).

American National Standards Institute (ANSI) Standards: ANSI standards are issued when equipment meets significant strength and endurance standards. All eye protection used in the shop must meet ANSI standards or not be used at the workplace.  ANSI standards are embossed on the protective equipment and can easily be verified.  For regular safety glasses the Z87.1 rating must be noted on the lens and the frame, along with the manufacturer’s name on frames.

Prescription Lenses:  Increased use of digital media has resulted in more adults using prescriptions lenses. The number of adults in the United States using prescription lenses is expected to increase beyond 75% of adults (165 million currently).  Prescription lenses and frames generally do not meet the safety requirements as they are not strong enough and have not undergone the testing procedures (ANSI standards).  Also, openings on the side and below the prescription lenses allow flying particles, liquids, and gases to enter the eyes and cause injury or irritation. 

Many employees are under the impression that prescription lenses provide similar protection to safety glasses.  This is not true.  The coverage area and the strength of the frame and lenses will always be suspect and hence they are not considered proper eye protection.  Some employees use the side shields on prescription lenses to get protection.  This is a false reliance as the strength of frame and lenses has not been established. Therefore, prescription lenses with side protection offer insufficient protection.

Prescription Safety Glasses:  Prescription safety glasses can be fabricated in a regular lens store or online.  Stores such as Costco or Walmart provide made-to-order safety glasses.  Online providers such as www.zenni.com, www.rx-safety.com and www.hi-techoptical.com  also ship prescription safety glasses.    Prescription safety glasses must be compliant with ANSI safety standards and carry a rating as well, for example ANSI Z87-2+.  

Over the Glasses Safety Glasses (OTG): Over the glasses safety glasses (OTG) may be worn as a substitute for prescription safety glasses.  OTG are available for a nominal price and should be made available to shop employees wearing prescription lenses.  Stock OTG in the same way you stock safety glasses.

Employer Policy:  Employer Eye Injury Prevention policies and programs must have integral elements as follows:

• Assess Hazards: Employees facing risks of flying objects must wear safety glasses.  Safety goggles must be worn where chemical hazards are present.  Bystanders must also be required to wear appropriate eye protection.
• Direct employees to keep safety glasses clean and store in sealed containers to protect from dust and scratches.  Damaged eyewear must be discarded for suitable replacement.
• Clearly explain the limitation of safety glasses, safety goggles and face shields to employees.  Also explain that prescription lenses are insufficient and unacceptable protection.
• Reduce hazards using engineering controls such as guards or other barriers.
• Communicate policies and train employees on eye injury prevention as part of EHS training programs.
• Enforce policies in a fair, consistent, and non-discriminatory manner. 
• OSHA requires that all personal protective equipment be made available to employees at no cost.  This should also be listed on employer policy.

Eye Wash Stations:  Proper eye wash station(s) must be positioned in the shop area and remain accessible at all times.  Inspection log and maintenance is a must.  See our earlier Newsletter on eye wash stations here.

DISCLAIMER:  The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas, and Virginia comply with EPA and OSHA regulations for over 34 years.  Sam is Certified Safety Professional (No. 16515) certified by National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com..