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.

June 20, 1986

Roland Westerdal, President
Bilsom International, Inc.
11800 Sunrise Valley Drive
Reston, Virginia 22091

Dear Mr. Westerdal:

This is in response to your letter of April 10, 1986, which requested consideration of the Bilsom "VISION" welding helmet as providing equivalent protection to that required by the Occupational Safety and Health Administration (OSHA) standards.

Under the Occupational Safety and Health Act, manufacturers are not eligible to receive a variance relative to a product's use. However, when we are provided with adequate information concerning a new product, we offer an opinion regarding the product's anticipated compliance with the OSHA standards.

On the basis of the information presently available to us, OSHA has determined that your product can provide protection equivalent to that specified by OSHA standards. When properly used and maintained as directed by the manufacturer, OSHA would consider employers using this product to be in compliance with [29 CFR 1910.252(b)(2)] and such employers would not be cited.

Under the OSHA standards, the filter lens shade shall comply with the requirements of ANSI Z87.1-1968. Furthermore, in order to eliminate our concern for the possible leakage of reflected ultraviolet (UV) radiation around the non-lens area of the welding helmet, OSHA recommends that users be required to wear UV protective eye wear, in the form of safety glasses with side shields, under the helmet at all times. Since this is already a common practice, it is not considered to be objectionable.

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


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

[Corrected 05/28/2004]