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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

January 31, 1984

W. C. White, President
Glendale Optical Company, Inc.
130 Grossways Park Drive
Woodbury, New York 11797

Dear Mr. White:

This is in response to your letter of December 19, 1983, requesting acceptance of your 2-mm thick polycarbonate plano lens and an UL-TEMA (7800 series) spectacle as meeting the intent of 29 CFR 1910.133(a)(6).

With regard to your 2-mm thick polycarbonate plano lens, we can make a determination only for complete products, not lenses alone.

In reviewing the data enclosed with your letter on the spectacle, we find that the data is still lacking in the following guidelines:

1. A comparison of data in the "as worn position" of the protector (on a head form) to demonstrate equivalent protection. It is not clear if this was done or not.

2. A description of your quality assurance program for the protector to assure continued high levels of protection.

3. A distinctive marking on the protector clearly identify it from all other protectors.

4. A clearer claim of equivalent protection.

Should you have any further questions, please contact us.


John B. Miles, Jr., Director
Directorate of Field Operations