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 https://www.osha.gov.

August 6, 1982

Mr. Terrill McGee
Safety Director
Motion Picture and Television Safety Committee
8480 Beverly Boulevard
Hollywood, California 90048

Dear Mr. McGee:

This is in response to your letter of July 8, 1982, petitioning for a change in the Occupational Safety and Health Administration (OSHA) standards to permit the use of readily available eyewash equipment, in some situations, as a substitute for using protection, as well as your recommendations for expanded requirements covering the location and accessibility of eyewash equipment.

I would be interested in receiving copies of the research you mentioned which seemed to indicate that protective eyewear and face shields cause eye problems, irritation and headaches. My office is aware of isolated complaints, but does not have research material indicating this to be a problem. In fact, the research material which we possess indicates protective eyewear to have optical qualities of an acceptable level (see pages 124-177 of enclosed report). Additionally, overall optical characteristics of protective eyewear exceed those of prescription eyewear.

Regarding your suggestion of substituting portable eyewash equipment for eye protection, we do not view this as equivalent protection. The purpose of the protective eyewear is to prevent the accident, whereas the purpose of eyewash facilities is to minimize the injury should the first line of defense fail to do the job.

Your suggestions relative to better defining the requirements for eyewash facilities seem appropriate. I am providing a copy of your letter to Dr. Leonard Vance, Director, Directorate of Health Standards for consideration by his staff who have responsibility for Section 1910.151.


Barry J. White
Directorate of Safety Standards Programs