Q: Some of our workers want to wear metal eyeglass frames with side shields for doing electrical work.
Is this allowed by OSHA or NFPA 70E®?
A: The question often arises about conductive eye wear for electrical workers
(We wanted to play the Guess Who’s “These Eyes” for you while you were reading our response, but our copyright department nixed it!)
Let’s take a good long look at the subject.
What OSHA Says
OSHA covers conductive apparel in 1910.333(c)(8), which states, “Conductive articles of jewelry and clothing (such a watch bands, bracelets, rings, key chains, necklaces, metalized aprons, cloth with conductive thread, or metal headgear) may not be worn if they might contact exposed energized parts. However, such articles may be worn if they are rendered non-conductive by covering, wrapping, or other insulating means.”
A second reference appears in 1910.335(a)(1)(v), stating, “Employees shall wear protective equipment for the eyes or face wherever there is danger of injury to the eyes or face from electric arcs or flashes or from flying objects resulting from electrical explosion.”
OSHA again hints at the subject of electrical PPE in 1910.335(a)(1)(i), where the standard states, “Employees working in areas where there are potential electrical hazards shall be provided with, and shall use, electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed.
Note: Personal protective equipment requirements are contained in subpart I of this part.”
Subpart I, referenced in 1910.335, reduces down to wearing safety eyewear compliant with ANSI Z87.1 ( ANSI/ISEA Z87.1-2010, ANSI Z87.1-2003, or ANSI Z87.1-1989 (R-1998)) when exposed to “eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.”
As for getting more specifics from OSHA on eyewear for electrical workers, this is as good as it gets.
What NFPA 70E® Says
Looking to NFPA 70E® makes things clearer but still leaves room for interpretation in the previous versions.
See below:
NFPA 70E® 2021, Article 130.7(C) covers Personal Protective Equipment. Section (4) of this article addresses eye protection, and echoes what OSHA states above, stating that protective eyewear must be worn whenever a danger of injury exists from arc flashes, explosions, flying objects, etc.
But in 130.8 (D), NFPA 70E states:
Conductive articles of jewelry and clothing (such as watchbands, bracelets, rings, key chains, necklaces, metalized aprons, cloth with conductive thread, metal headgear, or metal frame glasses [our italics]) shall not be worn within the Restricted Approach Boundary or where they present an electrical contact hazard with exposed energized electrical conductors or circuit parts.
In previous versions, this applied to the Limited Approach Boundary, so it was VERY clear that conductive frames could not be worn since the minimum Limited Approach Boundary is 42 inches (1M). But with the change to this applying ONLY to the Restricted Approach Boundary, it becomes a little more fuzzy for low voltage from a standards perspective.
OSHA Interpretation
The question was posed to OSHA in 1993 and 1994, and two official letters of interpretation were issued. These are included in the links below. The summary of these letters is again a little vague and simplistic: Wear a non-conductive means of restraint, NEVER a metal chain or other metal keeper for your glasses, and wear either a faceshield in front of your conductive eyewear, or appropriate safety glasses over the metal frame optical glasses. Both letters of interpretation state these requirements.
We at e-Hazard prefer an even simpler solution: follow a common-sense approach and get non-conductive frames for your safety eyewear. Many of today’s safety glasses are thin, lightweight, carry a proper ANSI 87.1 rating, and as well pose absolutely no risk from electrical shock. These plastic frames prevent your glasses from slipping off, falling into the electrical equipment, and increasing the risk of a shock or arc flash event, and they are non-conductive.
K.I.S.S.
We’ve heard it all over the years – from wearing an arc-rated keeper, which we support, to wearing a keeper AND a large pair of plastic glasses over your metal-framed eyewear. I learned from my military years the principle of KISS – Keep It Simple, Silly (actually the word in the military was “Stupid,” not silly). The KISS solution here is — bring nothing that could cause or increase the likelihood of a shock or arc flash into the electrical work area. This way, you can keep those big brown eyes (or blues, or whatever color you may have) working into retirement, and not pose a hazard to yourself or your co-worker. This is our best practice solution.
Several companies even offer prescription safety eyewear in a non-conductive frame to meet your needs.
We often get asked about the small amount of metal in the hinge and screw. There are few if any conditions that a screw that small could cause an arc flash or shock issue. We know of NO incidents which could cause an arc flash or shock from the small screw in a pair of safety glasses. Remember KISS!
Here’s to good eyesight and long-range vision! Enjoy the song “These Eyes” as a great reminder to actually wear your PPE any time you are exposed to a hazard. PPE works when it is worn. Those glasses do no good hanging on your front shirt pocket!
Ken provides good advise, but misses one point. Some people, like myself, have thicker corrective lens. Wearing the available (non-corrective lenses) safety glasses over them will quickly scratch the lens, requiring annual lens replacement. Taking a page from NFPA 70E (2018), the Likelihood (Probability) of Occurrence is less likely than Seldom (Remote possibility; could happen sometime; most likely will not happen) but slightly more likely than Unlikely (Rare and exceptional for all practical purposes; can assume it will not happen). This coupled with my limited exposure to energized components make it unnecessary for me to damage my lenses by adding the extra protection of wearing (non-corrective lenses) safety glasses over my safety glasses.
Being a prescription lens wearer myself, I opted for the prescription plastic safety glasses with glass lenses many years ago. This negates the need for wearing anything over a conductive frame. OSHA specifically prohibits any conductive articles in the electrical area, without covering them (faceshield, etc.). Utilizing NPFA 70e and its hazard assessment and risk reduction techniques to justify introducing a conductive hazard into the electrical workplace seems a bit counter intuitive in my opinion when much easier solutions are available.
Excellent, common sense answer! Thank you.
Much appreciated, Keith. Thanks for your comments.
Our company allows only non-conductive eyewear for anyone exposed to electrical hazards. The explanation I give for why is the same as Ken’s above with one added fillip: “All of us have had the experience of our safety glasses slipping off our nose while working in a panel. If they are metal, and cause an arc-flash, then the very thing you are depending on most to protect you from being blinded is missing at the very moment you are leaning face-first into the arc blast.”
Thanks for the job you all do at e-Hazard. Keep it up!
Very good company policy. I do like your reasoning. Why give electrical current any options besides the intended and designed circuit path?
Great article Ken
I use the Osha letters when needed
Also have a non conductive restraint
Ron Hughes
NTT INSTRUCTOR
Thanks Ron. Great hearing from you!
I looked for the non-conductive restraint in the OSHA letters – could have sworn that it stated that previously, but could not find it anywhere. Of course, common sense should apply.
Ken,
I had a question about who pays for prescription safety glasses? How would you interpret the OSHA term “non-specialty” relating to prescription safety eye-glasses? Who pays? These items can cost from $150 – $250 from the few I have seen online.
1910.132(h)(2)
The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job-site.
I have never dealt with any employers who have not provided prescription safety eyeglasses. I love that term about “to be worn off of the job-site.” Who in their right mind wants to wear prescription safety glasses at home? I certainly do not! (Ha ha). I suppose if an employer had employees who desired this, those employees could be required to purchase their own. This is certainly not a common theme, at least in the USA.
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For those working in the electric utility industry, NFPA 70E, OSHA 1910 subpart S and 1926 subpart K, is often “ignored”, albeit unfortunately, due to the covered and not covered limitations. This is primarily because electric power transmission, distribution and generation falls under the auspice of 1910.269 subpart R or 1926 subpart V. However most generating plants, especially in the nuclear power industry, have voluntarily adopted NFPA 70E at one level or another which has made our industry much safer for our electrical workers.
From an OSHA subpart R and V perspective, conductive objects being handled or worn by workers are contained in 1910.269(i)(3) and 1926.960(1)(iii).
1910.269(l)(3)(iii)
The employer shall ensure that no employee approaches or takes any conductive object closer to exposed energized parts than the employer’s established minimum approach distance, unless:
1910.269(l)(3)(iii)(A)
The employee is insulated from the energized part (rubber insulating gloves or rubber insulating gloves and sleeves worn in accordance with paragraph (l)(4) of this section constitutes insulation of the employee from the energized part upon which the employee is working provided that the employee has control of the part in a manner sufficient to prevent exposure to uninsulated portions of the employee’s body), or
1910.269(l)(3)(iii)(B)
The energized part is insulated from the employee and from any other conductive object at a different potential, or
1910.269(l)(3)(iii)(C)
The employee is insulated from any other exposed conductive object in accordance with the requirements for live-line barehand work in paragraph (q)(3) of this section.
Leaving the live line barehand work for another thread, we can see OSHA’s permissive practice to allow “the employee is insulated from the energized part (rubber insulating gloves…….)” is probably not the best practice for anyone working on or near exposed energized conductors.
So, while wearing a gold rings under your rubber insulating gloves is “permissible”, I have to ask, is it a wise or prudent choice to do so? And the same can be said and asked of metal frame safety glasses being restrained by a non-conductive lanyard such as ‘Chums’. With the plethora of ANZI Z87.1 safety glasses (prescription and non-prescription) out there made completely of non-conductive materials, why would a qualified electrical worker choose a metal frame pair of safety glasses?
All it takes is for your lanyard to slip off when your metal framed glasses fall from your face because you’re sweating profusely then land on energized parts.
For this reason I’ve implemented the requirements from NFPA 70E into our safety procedure at my nuclear power plant for our electrical workers to wear only non-conductive safety glasses, period.
A very wise man once said: “All things are permissible for me but not all things are beneficial”. And when it comes to electrical safety we must focus on the beneficial.