A Primer on Eye and Face Protection

the Synergist

Understanding and Implementing a Workplace Program

BY PAUL ALLEN, CURTIS HINTZ, AND KEVIN MAHONEY

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Protective eyewear can take on many purposes as well as many shapes and colors. Its purpose is self-explanatory: due to our eyes’ critical role in our lives, protecting these two organs from hazards must be a priority at work and at home. A query on the NIOSH website found approximately 90,000 eye-related emergency room visits in 2020, primarily for contusions, abrasions, and foreign body-type injuries, and a smaller percentage for burns and dermatitis. These numbers do not include eye injuries treated at non-emergency-room facilities. The critical nature of our eyes and the volume of cases reinforces the need for an effective eye protection protocol. STANDARDS OSHA’s standard for personal protective equipment (29 CFR 1910.132) sets the groundwork for all PPE. The hazard assessment section of this standard is a big part of the foundation. The standard outlines training in the proper use, maintenance, and cleaning of PPE, which is another important piece of a PPE program. The standard stipulates that PPE must be provided at no cost to the employees but lists several exceptions, including shoes, everyday clothing, and PPE that an employee has lost or intentionally damaged. In a final rule issued in 2007, OSHA clarified the requirements of employers to pay for PPE. The summary of the rule notes:

In this rulemaking, OSHA is requiring employers to pay for the PPE provided, with exceptions for specific items. The rule does not require employers to provide PPE where none has been required before. Instead, the rule merely stipulates that the employer must pay for required PPE, except in the limited cases specified in the standard.

Prescription eyewear is among the exceptions that employers don’t have to pay for as it is considered something that can be used on and off the job. OSHA’s standard for eye and face protection (29 CFR 1910.133) provides more specific guidance. This standard lists the exposures that eyewear must protect against and requires side shields for safety glasses in the presence of flying materials. This standard specifically notes that employees requiring prescription eyewear must wear eye protection that incorporates the prescription in the design, or protection must be worn over the prescription eyewear without disturbing the position of the prescriptive lens or protective lens.

The standard also stipulates the protective shade that must be used when welding. See the chart titled “Filter Lenses for Protection Against Radiant Energy” on OSHA's website.

In addition to these base-level standards, additional eye protection requirements are outlined in the OSHA standard for welding, cutting, and brazing (29 CFR 1910.252). Eye protection requirements for construction are found in the Personal Protective and Life Saving Equipment standard (29 CFR 1926.95) and the Eye and Face Protection standard (29 CFR 1926.102).

The construction standard differs from the general industry standard in that it does not include the provision for a PPE assessment, but this practice would benefit any operation. In addition, Table E-1 in the construction eye protection standard provides slightly different shade numbers for protective eyewear worn during welding. Optical densities for use with lasers are also found in the construction standard in Table E-2.

The OSHA eye protection standards include references to several ANSI standards. All eye and face protection must comply with these consensus standards, often referred to collectively as Z87: • ANSI/ISEA Z87.1-2010, Occupational and Educational Personal Eye and Face Protection Devices, incorporated by reference in 29 CFR 1910.6

• ANSI Z87.1-2003, Occupational and Educational Personal Eye and Face Protection Devices, incorporated by reference in 29 CFR 1910.6 and 1910.133(b)(1)(iii)

• ANSI Z87.1-1989 (R-1998), Practice for Occupational and Educational Eye and Face Protection, incorporated by reference in 29 CFR 1910.6

These standards provide the requirements for construction of the protective eyewear and how it must perform against potential exposures. All protective eyewear must be marked with an ANSI Z87 reference to confirm it meets these requirements.

The ANSI standards and the OSHA PPE and eye protection standards provide a foundation for an eye protection program. The most recent edition of Z87 is ANSI/ISEA Z87.1-2020, American National Standard for Occupational and Educational Personal Eye and Face Protection Devices. According to the ANSI website, this standard “provides criteria and requirements for selection, use, and maintenance of the different face and eye protectors to promote the most effective materials and methods of use.”

While this article focuses on the OSHA approach to eye protection, Europe has similar regulations. EU Directive 89/656/EEC from November 1989 provides the requirements for using PPE in the workplace and follows a risk assessment and hierarchy-of-controls approach in determining the need for PPE. This directive requires employers to provide PPE free of charge, select PPE based on the risks, conduct employee training, and ensure proper storage, cleaning, disinfection, and maintenance of all PPE.

In 1992, the United Kingdom’s Health and Safety Executive (HSE) published the Personal Protective Equipment at Work Regulations, which were amended in 2022. These requirements follow a similar risk assessment and hierarchy-of-controls approach, making PPE the control of last resort. There are also provisions covering the need for training, proper storage, cleaning, and maintenance of any assigned PPE.

OSHA, the EU, and the U.K. have many similarities in their PPE approaches. Risk assessment is a common theme in all these regulations, so we must look at how assessments play an important role in effective eye protection programs.

RISK ASSESSMENT A risk assessment must be performed within the work environment to identify if eye or face protection is necessary for specific areas or during specific tasks. Risk assessments evaluate the physical work environment (that is, hazards inherent to the work environment) and tasks that may be infrequent, intermittent, or transient. A risk assessment consists of an initial survey of the work environment, a risk evaluation, recommendations, and routine re-evaluations to ensure the existing program and recommendations are followed. It is often beneficial to involve the employees performing the task in the risk assessment process. (Note that manufacturers’ recommendations, as well as OSHA requirements, should be used to determine the minimum level of protection during these tasks.)

Initial Survey The first step of the risk assessment is to survey the work environment to identify and document potential eye and face hazards. Hazards may include impacts, chemicals, vapors, dusts, nonionizing radiation hazards, or other eye or face hazards. While performing the survey, you should document the location, source, and type of the hazard and existing controls, such as engineering or administrative controls. Hazards should also be categorized as either area-specific (hazards inherent to the work area) or task-specific (hazards present only during specific tasks). Thorough documentation during this process is important for establishing an eye and face protection program. The risk assessment should be revalidated after a change has been made to the work process or environment.

When selecting PPE, try to offer variety to achieve employee buy-in. Different brands and models fit individual users differently.

Risk Evaluation After the survey has been performed and thoroughly documented, the next step is to evaluate the risk for each identified hazard using a risk matrix similar to the one shown in Figure 1. Consider the existing controls in place when using this tool. The risk matrix uses the likelihood of an event and its expected outcome to generate a risk rating. Figure 1 is just an example; the scoring within the matrix can be adjusted based on the company’s risk tolerance and past practices. It is recommended to begin with area-specific hazards, which will establish the minimum level of protection for the area. A risk rating of II or above should be reevaluated to ensure the current engineering and administrative controls are adequate to protect the workforce. If the controls are not adequate, then PPE or additional control measures are considered.

Recommendations and Implementation The next step in the risk assessment is to implement recommendations based on your survey and risk evaluations.

Figure 1. Use an eye protection matrix like the one shown here to evaluate the risk for each hazard. Assume no eye or face protection when evaluating the risk. Source: Kevin Mahoney. Click or tap on the figure to view a larger version in your browser.

Using your risk rating as a guide, make recommendations for eye and face protection requirements commensurate with the identified hazards. Your recommendations for the work environment will establish your standard level of eye protection. Task-specific requirements may require an employee to upgrade to a higher level of protection. Recommendations should be specific, manageable, and realistic. Examples of recommendations for area- and task-specific hazards appear in Tables 1 and 2. See also Appendix B to Part 1910 Subpart 1, “Nonmandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection.”

Routine Reevaluations Reevaluations may be required when a change is made to the process, tasks are added, or at an established frequency to validate past assessments.

ADMINISTRATION OF A PROGRAM A workplace program for eye and face protection typically comprises five elements: PPE selection; PPE procurement; training, inspection, cleaning, and maintenance; storage; and program evaluation.

Selection of PPE. As discussed above, the risk assessment will generally note what PPE is required, such as “safety glasses,” “chemical goggles,” and more. This list of generic PPE types should be narrowed down to specific manufacturers, model numbers, and part numbers from among the myriad options. Generating a list is best done collaboratively with a multifunctional team, including the manufacturing and maintenance personnel who are the end users. Establishing relationships with PPE manufacturers and distributors can greatly aid this process through their detailed knowledge of the PPE market and associated products. When selecting PPE, try to offer variety to achieve employee buy-in. Different brands and models fit individual users differently. Some will mesh better with other PPE, such as half-face respirators. And don’t discount overall looks and stylishness, especially with safety glasses. Before making final decisions, it is best to conduct wear trials of the PPE being considered. Gaining the buy-in of those wearing the PPE is important to ensure it will be worn as required. Once selections have been made, a method is required for clearly communicating to employees what PPE is required for each task. This communication can be as simple as writing the PPE into each task procedure or work permit, provided personnel are required to read and adhere to them. This specification must be detailed enough, including the manufacturer, model, and part number, to remove any question about what is required. Some organizations include a photo.

Table 1. Examples of Recommendations for Eye and Face Protection, Area-Specific Hazards

Table 2. Examples of Recommendations for Eye and Face Protection, Task-Specific Hazards

Click or tap on the tables to open larger versions in your browser.

Another method is to create a spreadsheet or grid specifying the required PPE for the tasks, which can be printed in large format and placed on the control room wall or another location where personnel congregate. This low-tech option can work well as long as changes to the required PPE, which would make the grid obsolete, are infrequent. Good document management practices must be in place for this method to be effective. It is common to place the grid on a computer server available to everyone in the facility. Still, even that practice isn’t foolproof, as people can forget how to quickly locate the electronic file. When conducting audits and program reviews, a good spot check is for the evaluator to ask an operator or other facility employee to pull up the PPE grid. You might be surprised how often they struggle with the search or must ask for help from other personnel.

PPE procurement. Clearly address how the selected PPE will be purchased and stocked. Adequate stocks of the identified nonprescription safety glasses, goggles, and face shields must always be on hand to replace lost or damaged items. While variety is desirable, there must be a limit to the number of offerings to keep the purchasing and stocking of the PPE manageable. Try to work with a limited number of suppliers or distributors so they can help the facility manage the offerings and provide preferential pricing. Limit who in the organization can order PPE for a workgroup; this will help control costs and ensure the purchased PPE aligns with the specific PPE selected as part of the risk assessment. Building a master list of all required PPE for the facility can greatly assist in purchasing, stocking, and using the PPE.

A separate process is required for obtaining prescription safety glasses. Usually, this is done by utilizing local resources to obtain the eye exams and order the eyewear, with the employer picking up all or most of the costs. A prescription eyewear policy defines what the employer will pay for regarding types of lenses, any additional treatments applied to the lenses, and replacement frequency.

Training, inspection, cleaning, and maintenance. For all PPE, even safety glasses, the packaging includes basic precautions and information on cleaning and any authorized maintenance or replacement of parts. Training on this information as well as the details of the facility’s procedures for stocking, issuing, and replacing PPE can easily be provided to all users through a safety meeting, a training class, or computer-based training methods.

Storage. Proper storage is not difficult but can be one of the weaker aspects of many PPE programs. Lack of proper storage can contaminate or damage the PPE, endangering employees and driving up costs. One typical method of storing eye and face protection includes designating compartments or “cubbyholes” in a common area not subject to contamination or adverse environmental conditions. A fully enclosed box or locker can be utilized for more exposed locations. Equipment that is often shared, like a face shield in a maintenance shop, is typically stored in an enclosed box.

Auditing and program evaluation. The old saying “What gets measured gets done” applies to PPE programs. Are employees using the correct PPE for the specific task they are performing? Are they properly inspecting, cleaning, and storing their PPE? It can be easy to become complacent and overlook discrepancies unless there is a deliberate process to actively check for and correct issues.

MAXIMIZING EFFECTIVENESS The use of eye and face protection is ubiquitous in our workplaces as a means of protecting against injuries. The aspects discussed in this article—understanding and complying with applicable regulations and standards, conducting a risk assessment and selecting appropriate eye and face protection, and careful implementation and management of a PPE program—are important in maximizing the effectiveness of your eye and face protection.

PAUL ALLEN, CIH, CSP, ARM, CRIS, AOEE, is the product consulting director, industrial hygiene, commercial risk control with CNA Insurance in Chicago, Illinois.

CURTIS HINTZ, CIH, CSP, FAIHA, is a retired industrial hygienist previously employed by The Dow Chemical Company.

KEVIN MAHONEY, CIH, CSP, is an industrial hygienist at PBF Energy’s Paulsboro Refinery.

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Disclaimer: The information, examples, and suggestions presented in this material have been developed from sources believed to be reliable, but they should not be construed as legal or other professional advice. CNA accepts no responsibility for the accuracy or completeness of this material and recommends the consultation with competent legal counsel and/or other professional advisors before applying this material in any particular factual situations. This material is for illustrative purposes only.

Philip Steury/Getty Images

RESOURCES

American National Standards Institute: “ANSI Z87.1 Eye and Face Protection Devices Standard” (March 2020).

European Agency for Safety and Health at Work: OSHwiki, “PPE.”

OSHA: “Employer Payment for Personal Protective Equipment,” Final Rule (November 2007).

OSHA: Occupational Safety and Health Standards, Personal Protective Equipment, Eye and Face Protection.

OSHA: Occupational Safety and Health Standards, Personal Protective Equipment, General Requirements.

OSHA: Occupational Safety and Health Standards, Personal Protective Equipment, Nonmandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection, 1910 subpart 1 appendix B.

OSHA: Occupational Safety and Health Standards, Welding, Cutting and Brazing, General Requirements.

OSHA: Safety and Health Regulations for Construction, Personal Protective and Life Saving Equipment, Criteria for Personal Protective Equipment.

OSHA: Safety and Health Regulations for Construction, Personal Protective and Life Saving Equipment, Eye and Face Protection.