November 14, 1979
||GILBERT J. SAULTER|
REGIONAL ADMINISTRATOR, REGION VI
||Herbert M. Kurtz|
Assistant Regional Administrator for Technical Support
Acting Field Coordinator
||GROVER C. WRENN|
Director, Federal Compliance and State Programs
||Photochromatic/Phototropic (Variable Tint) Lenses in Safety Eye Wear.|
Any lens that dose not pass the drop test as required by ANSI Z87.1-1968 is
in violation of 29 CFR 1910.133 and shall be cited as an alleged violation.
However, the new Z87.1-1979 version in Article 184.108.40.206.4 addresses the
variable tint lens (copy enclosed) forbidding its use indoors entirely and
allowing its use outdoors in the absence of hazardous ultraviolet or infrared
The variable tint lenses do not meet the requirements of the American
National Standard for Occupational and Educational Eye Face Protection,
Z87.1-1968, referenced in 29 CFR 1910.133(a)(6), and 29 CFR 1926.102(a)(2) in
at least one important respect, viz. they can not be assigned a Z87.1 shade
(tint) designation due to their constant change in depth of tint (shade).
The lenses would also have to meet the detailed requirements in Article 6.3.3
of lens thickness, marking, transmittances of ultraviolet and infrared
radiations, and lens strength.
In regard to establishing a de minimis violation, the Field Operation
Manual, Chapter VIII and the OSHA Instruction CPL 2 11A (formally identified
as Program Directive 200-67, Revision 1) provide the appropriate guidelines.
In this regard, due consideration should be given to the outdoor use
permitted by Z87.1-1979, provided there is no ultraviolet or infrared hazard.