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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

November 19, 1982

Honorable John Glenn
United States Senate
Washington, D.C. 20510

Dear Senator Glenn:

Thank you for your letter of October 26, 1982, on behalf of Mr. John A. Wilson, Sauder Woodworking Company in Archbold, Ohio, regarding the wearing of photo-grey safety lenses. Please accept our apology for the delay in response.

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's control and procedure in setting standards comes from section 6 of the Occupational Safety and Health Act of 1970 (copy enclosed). One way indicated in section 6 is to adopt a national consensus standard as OSHA did with the Z87.1 standard. Also, as indicated in section 6, any interested person may submit written information to the Secretary to be used as a basis for standard promulgation. Moreover, an interested person may send suggestions and seek participation in the national consensus group of the standard of interest to him. Suggestions for the improvement of the ANSI Z87.1 standard, should be sent to the American National Standards Institute, 1430 Broadway, New York, New York 10018. The Secretary of the Z87 Committee is Mr. Dennis Hirschelder, whose telephone number is 212-684-3505, should Mr. Wilson wish for more information.

OSHA standard 29 CFR 1910.133(a)(6) prohibits the use of photo-grey 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 versa 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 photo-grey glasses rather than monitor the use of this equipment under all conditions. This would be their prerogative in order to remain in compliance.

In view of the above, whether an employer is in compliance normally would be determined by the compliance officer when an inspection is conducted.

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


Thorne G. Auchter
Assistant Secretary