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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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


May 13, 1982

Mr. Raymond T. Johnson
Dubois Optical Company
8 South Brady Street
Dubois, Pennsylvania 15801

Dear Mr. Johnson:

Thank you for your letter of April 21, 1982, requesting a copy of OSHA's present ruling for the use of photochromatic lenses in industry.

OSHA's standard for design, construction, testing and use of devices for eye protection is 29 CFR 1910.133(a)(6) (copy enclosed) which adopts the American National Standard for Occupational and Educational Eye and Face Protection, Z87.1-1968.

OSHA standard 29 CFR 1910.133(a)(6) prohibits the use of photochromatic lenses for safety glasses at inside work locations, which have variable lighting conditions, because the variable tint lenses would cause temporary vision impairment when the light changes from bright to dim or vice verse in the work area. However, they are allowed inside when the lighting conditions do not change substantially and the employees constantly stay in the area, particularly if glare or bright lights is a problem. They may also be used by employees working outdoors, provided there is no ultraviolet or infrared hazard.

Obviously, this becomes complicated for an employer to monitor, particularly if employees go in and out of a building. Thus, some employers will prohibit their employees from using photochromatic glasses rather than monitor the use of this equipment under all conditions. This would be their prerogative in order to remain in compliance.

Article (copy enclosed) of the new Z87.1-1979 version specifically addresses the variable-tint plano (noncorrective) and corrective-protective (Rx) phototropic (photochromic) lenses, forbidding their use outdoors in the absence of hazardous ultraviolet or infrared radiation. The use of the variable-tint lenses, which violates the requirement of fixed shade lenses in the reference standard, Z87.1-1968, currently being enforced, may be considered a de minimis violation without a citation by the compliance officer, in light of the outdoors allowance of the 1979 edition of this reference standard. This is permissible by OSHA Instruction CPL 2.11A, De Minimis Violations (copy enclosed), which discusses OSHA's possible acceptance of provisions in a new edition of a reference standard on a de minimis violation basis.

If we may be of further assistance, please feel free to call or write.


John K. Barto
Division of Occupational Safety Programming

[Corrected 10/23/2007]