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.

July 17, 1985

Mr. William J. Heaps
Uvex Winter Optical, Inc.
10 Thurber Boulevard
Smithfield, Rhode Island 02917-1896

Dear Mr. Heaps:

This is in response to your June 13, 1985 request for consideration of your Ultra-Spec 2000 eye protective device as meeting the intent of the Occupational Safety and Health Administration (OSHA) Eye and Face Protection standard.

OSHA's standards at [29 CFR 1910.133(b)(2)] provide that "design, construction, testing, and use of devices for eye and face protection shall be in accordance with American National Standard for Occupational and Education 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 Ultra-Spec 2000, does provide 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(b)(2)] and such employers would not be cited, if this equipment was being used and maintained properly. It is extremely important, however, that the Ultra-Spec 2000 continue to be permanently marked with the "2S" logo to 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.

If I may be of further assistance, please let me know.


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

[Corrected 05/28/2004]