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.

August 30, 1985

Mr. Joel G. Kaufman
Quality Control Manager
Glendale Optical Co., Inc.
130 Crossways Park Drive
Woodbury, New York 11797

Dear Mr. Kaufman:

This is in response to your July 31, 1985 request for consideration of your new 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 Gleneagle spectacle with 2-mm thick polycarbonate plano lenses, 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 your product continues 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]