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 http://www.osha.gov.

December 12, 1984

John E. Engelberger, President
Enerjee, Ltd.
32 South Lafayette Avenue
Morrisville, Pennsylvania 19067

Dear Mr. Engelberger:

This is in response to your letter of October 3, 1984 , requesting an official opinion as to whether the zHornell Elektrooptik Speedglass welding helmet meets the intent of the Occupational Safety and Health Administration (OSHA) requirements at 29 CFR 1910.252 and ANSI Z87.1-1968. Your letter addressed to our Director of Safety Standards was forwarded to this office for reply.

OSHA does not approve or certify equipment for use in the workplace. However, when we are provided with adequate information concerning a new product we do offer an opinion regarding the products anticipated compliance with our requirements for employee safety and health. Therefore, this letter is not an approval or certification of your product, but is an interpretation of our standards as they apply to the use of your product in United States workplaces.

The equipment described by your company's brochure, "New Look at Welding" meets the intent of OSHA standards which specify minimum acceptable eye protection during arc welding. Your provision for power-off filter density corresponding to filter shade S, as a minimum, meets the specification of ANSI Z49.1-1973, table 2 (Notes) for minimum acceptable arc welding filter density. Full protection at all times, powered and unpowered, from UV and IR is specified and necessary by our standards. Power-on filter density equivalent to filter shade S or greater is noted in 0.01 seconds and is acceptable since high intensity transmission of only green and yellow light is permitted during a very brief moment.

OSHA does not possess facilities in which to verify lens compliance with the specifications of ANSI Z87.1-1968. Therefore, OSHA must rely upon your assurance of such compliance. However, you may elect to have your lens tested and certified by an independent laboratory.

If we may be of further assistance, please contact me.

Sincerely,



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