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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.
|MEMORANDUM FOR:||JOHN A. GRANCHI
Assistant Regional Administrator Office of Technical Support
|THRU:||JAMES W. LAKE
JOHN B. MILES, Director
Directorate of Field Operations
|FROM:||EDWARD J. BAIER, Director
Directorate of Technical Support
|SUBJECT:||Wodelic Electronic Welding Helmet|
As you are aware, no provisions exist in the OSHA 29 CFR 1910.252 standards specifically for electronic welding filter devices such as the Wodelic helmet. Further, both the current version and proposed revision of the applicable ANSI Z87.1 standard have no provisions regarding the proper performance of electronic welding helmets.
An important parameter of the filtering component of these helmets is the response time. This is the time a filter takes to react to a welding flash and provide suitable protective shielding for the flash. The Electronics article (included with your inquiry of February 5) on the Wodelic helmet claims a response time of 3 milliseconds.
Section 1910.252(e)(2)(ii)(i) provides a guide for the selection of the proper shade for a particular welding operation. The standard also allows for variation to suit individual needs. In our research we have found no data that enable us to determine whether the electronic helmet in question provides as much protection as the available if a user complied with the current OSHA requirements. Additionally, section 1910.252(e)(2)(ii)(j) calls for compliance with the transmission of radiant energy test requirements prescribed in ANSI Z87.1-1968. Again, no data were found to assert compliance with the radiation transmission requirements.
The American Welding Society Radiation Committee (American Welding Society, 550 N.W. LeJeune Road, P.O. Box 351040, Miami, Florida 33135) issued a statement two years ago that testing and research are necessary to determine the suitability for use of these devices. Mr. Marvin E. Kennebeck of the American Welding Society Safety and Health Group was informed of the Electronics article on the Wodelic helmet. He has advised that the Radiation Committee will include the article on the agenda for its upcoming April 23 meeting.
The shortest response time of any such device predating the Wodelic helmet has been 10 milliseconds by the Swedish "Hornell" product. It is our understanding that alleged cases of eye burns have been reported with the use of this product. It is not known, however, if the product was used correctly in these cases. In conclusion, we cannot advise on the suitability of the Wodelic helmet without proper testing performed by a recognized laboratory. Such tests must be requested by the manufacturer of the helmet. Please feel free to contact Raymond G. Kunicki of my staff (FTS 523-7065) for additional information.