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.

October 21, 1985

Mr. James P. Kline
Engineering Manager
Willson Safety Products
P.O. Box 622
Reading, Pennsylvania 19603

Dear Mr. Kline:

This is in response to your September 3, 1985 submission of test data and information on the SPECTRA safety spectacle and the subsequent data forwarded on October 3, 1985. The material was submitted for consideration of the SPECTRA 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 SPECTRA, 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 SPECTRA 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.

If we may be of further assistance, please let us know.


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

[Corrected 05/28/2004]