Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

January 7, 1976

Mr. Frank L. Jamison, Manager
Professional Optical Company, Inc.
P.O. Box 64689
Baton Rouge, Louisiana 70806

Dear Mr. Jamison:

This is in response to your letter of August 25, 1975, addressed to Mr. Powell of our Baton Bouge Office, regarding the use of photochromic lenses in industrial safety eye-wear.

The Occupational Safety and the Administration (OSHA) in administering the Act is required to enforce applicable OSHA standards and regulations. 29 CFR 1910.133, in part, states that an employee is required to use suitable eye protectors provided where machines or operations present the hazard of flying objects, glare, liquids, injurious radiation, or a combination of these hazard.

Where the employer is required to have eye protection, the design, construction, testing, and use of the device for eye protection shall be in accordance with American National Standard of Occupational and Educational Eye and Face Protection, ANSI Z87.1-1968.

OSHA Field Information Memorandum #75-43, dated June 27, 1975, in part, makes the following statement: "The purpose of this memorandum is to remind you that the design, construction, testing and use of devices for eye and face protection must be in accordance with ANSI Z87.1-1968."

In "Section 2: Exceptions" of ANSI Z87.1-1968 the following statement is made: "When reference is made to this standard for statement(s) of compliance must include all performance requirements in their entirety." Emphasis added.

From the foregoing one can conclude that photochromic (variable tint) safety lenses are not in compliance with ANSI Z87.1-1968, and, in turn, not in compliance with the related OSHA standard.

The Act provides several ways to seek relief from a particular standard. Section 6(d) of the Act affords an opportunity for an affected employer to apply to the Secretary for a rule or order for a variance from a standard. Section 6(b) of the Act gives the opportunity for an interested person to petition the Secretary to promulgate, modify, or revoke any occupational safety and health standard.

If I may be of any further assistance, please feel free to contact me.


John K. Barto, Chief
Division of Occupational Safety Programming