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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

(Letter Undated)

Mr. Donald K. Hannaman
General Manager-Operations
Jackson Products
5801 Safety Drive, N.E.
Belmont, Michigan 49306

Dear Mr. Hannaman:

This is in final response to your request for consideration of your Vision Guard eye protective device as meeting the intent of the OSHA Eye and Face Protection standard.

OSHA's standards at 29 CFR 1910.133(a)(6) provide that "Design, construction, testing, and use of devices for eye and face protection shall be in accordance with the American National Standard for Occupational and Educational Eye and Face Protection, Z87.1-1968." The referenced ANSI standard, however, states in paragraph 2 that "Variations from the requirements of this standard may be granted by the authority having jurisdiction only when it is demonstrated to the satisfaction of the administrative agency that equivalent protection is afforded."

On the basis of the information which you have presented to us, OSHA has determined that your product, the Vision Guard does provide protection equivalent to that provided by eye protection which meets all the requirements of ANSI Z87.1- 1968. Therefore, OSHA would consider employers using this product to be in compliance with 29 CFR 1910.133(a)(6) and such employers would not be cited, if this equipment was being used and maintained properly. It is extremely important, however, that the Vision Guard be permanently marked in a manner that would easily allow employers, employees and our compliance personnel to distinguish it from other types of protective eyewear. Otherwise, employees could mistakenly use eyewear providing insufficient protection.

Thank you for your patience in this matter. If I may be of further assistance, please let me know.


Thorne G. Auchter
Assistant Secretary