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Equivalent protection from Vision Guard safety eyewear

Summary An eyewear manufacturer asked whether its Vision Guard device could meet the intent of OSHA’s eye protection rule despite differing from the referenced ANSI standard. OSHA found the complete device provided equivalent protection, provided employers used and maintained it properly, and stressed that it must be permanently marked. OSHA labels the letter undated and archives it.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1984-01-01
Date issued
January 1, 1984
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

(Letter Undated)

Mr. Donald K. Hannaman
General Manager-Operations
Jackson Products
[Recipient address omitted]

Dear Mr. Hannaman:

This is in final response to your request for consideration of your Vision Guard eye protective device as meeting the intent of the OSHA Eye and Face Protection standard.

OSHA's standards at 29 CFR 1910.133(a)(6) provide that "Design, construction, testing, and use of devices for eye and face protection shall be in accordance with the American National Standard for Occupational and Educational 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 Vision Guard does provide protection equivalent to that provided by eye 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(a)(6) and such employers would not be cited, if this equipment was being used and maintained properly. It is extremely important, however, that the Vision Guard 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.

Thank you for your patience in this matter. If I may be of further assistance, please let me know.

Sincerely,
Thorne G. Auchter
Assistant Secretary

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