Seeing a Safer Way
Published: 19th Nov 2012
I would like to take a general look at eye safety through my personal experience regarding the introduction of safety eyewear into the workplace. Reluctance may be encountered in the workplace from some employees with regard to the use of safety equipment. I have included at the end of this article a short history of the relevant regulations in the UK.
There are many different types of workplace environments and each presents its own unique hazards: chemical or metal splash, dust, projectiles, gas and vapour, or radiation - to name just a few. Each situation will also have its own specific solution and some of the options for eye protection are safety spectacles or goggles, face shields, or possibly visors.
So, you have identified the hazard and the people that it affects. You’ve looked at every way of eliminating the hazard or reducing it to an acceptable level. You have consulted with the workforce and after all this you have to use PPE. Never a very satisfactory conclusion in my opinion, but unfortunately it goes with the territory in some workplaces. The only thing I would say is that whatever the industry norm, you should never take it for granted that PPE is the only answer.
I teach health and safety and when we talk about the hierarchy of control with regard to risk assessment, I regularly find that even workers of 20 years or more experience often cite PPE as their first control measure, rather than last. This begs the question ‘How many of your workforce have actually seen and digested your risk assessments’? Just as important, how many were actually involved in the formulation of your risk assessments?
I don’t need statutory requirements to convince me of the positive effect it has right across the board for all concerned to involve staff in the risk assessment process. As a consultant, it never ceases to amaze me that many companies not only don’t go down this route but some are positively hostile to the idea.
A specific example
Safety eyewear is a case in point. I was first introduced to safety glasses back in the late 1980s. Of course fitters and technicians in the steelworks where I worked already used various eye protection that was available at the time. Welding, grinding and burning activities were common, but if I’m honest, apart from welding you would often find these workers’ eye protection laid next to where they were working, rather than on their heads. That is if they bothered to get them out of their locker.
I look back now over the Seventies and Eighties and I’m amazed that there weren’t more accidents related to these activities.
The part of the site I worked in was involved in the processing of slag from steelworks. Slag is a byproduct of iron making. The slag arrived molten in ladles and would be tipped into a trough of water that was fed under pressure. This resulted in a material not unlike sand - granulated blast furnace slag. This was the first hazard.
Within this material are small needle-like particles. Once this granulated slag had dried out it could become airborne and a particle of this in the eye was a painful experience. I should know as I have spent the evening sat in the waiting room of the local hospital and then several days’ absence from work ensued - wearing an eye patch.
There was another issue with regard to eye injuries on the site that I worked at. One of the processes required the grinding of the granulated blast furnace slag to the level that it became a fine white powder, not unlike cement. This was alkaline to the point where if you perspire and got the powder on your skin it would burn and cause a rash.
Although this was pre-risk assessment, we had a health and safety committee I sat on. Due to regular incidents of minor eye injuries we decided upon the route of providing safety glasses. There are a few issues that instigated this.
Firstly, it was common for members of the workforce to have an injury of the eyes due to airborne particles. There is the pain and suffering that has to be taken into consideration. This ranged from slight pain and the flushing of eyes with sterilised water, to a visit to the local hospital with either a scratched eyeball that could lead up to a week of incapacitation, or to penetration of the eyeball with a sliver from the ground regulated blast furnace slag. This of course was much more painful, difficult to treat and the considerably greater lost time accident.
The safety eyewear we finally settled on were a type that the dust would not destroy within a few days. There was many a complaint about lack of visibility once the dust started to act on lenses, and we had to have impromptu toolbox talks about cleaning of the protective eyewear and storage. Still, there was often a reluctance to wear them, and the period being what it was, often disciplinary action was taken against those caught without their protective eyewear.
You would think the people would want to safeguard their eyes against injury, but if PPE is not comfortable and easy to use, there is often resistance, regardless of the risk of injury.
Overall, however, the end result was a month on month reduction of the incidence of injuries to the eyes.
Much has changed since then and we now have the Personal Protective Equipment regulations 2002, the details of which I have included below.
How can we get workers to wear their PPE and in this case specifically eye protection, when the risk assessment stipulates that it is obligatory?
I would say that it is of the upmost importance to have a robust policy with regard to PPE and ensure that it is communicated to the workforce.
Look at brochures and talk to suppliers as they may be able to give advice on other companies they supply who are in a similar line of business. Get expert advice if you are not sure.
Then purchase the most comfortable eyewear that is available on the market and trial various types to find what is most suitable for the job in hand, and that the workforce finds comfortable and easy to use. By involving them in the selection and trialing various models where possible, you have a greater chance of compliance success. Staff certainly have no argument if they are caught not wearing eyewear, but remember, ultimately it has to be fit for purpose and that is your responsibility.
Where prescription lenses are needed try to give them the choice frames. Remember, safety eyewear that fits over workers’ glasses is only a temporary measure and can cause additional problems.
Try toolbox talks periodically, reinforcing the message and the importance of wearing safety eyewear. Use case histories, especially ones that your workforce can relate to. Almost everyone knows somebody who has suffered an injury at some time, even though it may not have been at work or that serious. I find when I am teaching if I can relate to real-life experience I am halfway there to getting them on my side and wanting to learn. It’s a sad fact of life that one man’s injury can serve to illustrate what may happen to you.
Re-evaluate the suitability and the wearability of the eyewear if you really are coming up against heavy resistance and you feel that the criticism is valid.
If all else fails you will have to resort to the company’s disciplinary procedure, but if you are not consistent and methodical in your approach to ensuring compliance you may cause yourself some difficulties with this.
A short history of PPE legislation
The need to supply safety eyewear to employees in the UK was contained within regulations drafted in 1974 to replace Section 49 of the Factories Act, 1937, and The Protection of Eyes Regulations, SI 1974/1681. These officially came into force on April 10, 1975.
These regulations cover 35 different processes for which approved eye protection would be required, and five additional situations where persons could be at risk even when not specifically engaged in the particular processes.
In line with a European Directive, on January 1, 1993, the UK government introduced new legislation on Health and Safety at Work that effectively replaced those of April 10, 1974.
There were six areas considered within this legislation, one of which was PPE. The regulations were published under the Health and Safety at Work Act, 1974, as Personal Protective Equipment (European Community (EC) Directive) Regulations, 1992 SI 1992/3139.
The current regulations came into force on January 1, 1993. They have subsequently been amended by the Police (Health and Safety) Regulations 1999 SI 1999/860, the Ionising Radiations Regulations 1999 SI 1999/3232 and the Health and Safety (Miscellaneous Amendments) Regulations 2002 SI 2002/2174.
Eye protection is included in the regulations along with protective aprons and other clothing, such as garments for adverse weather conditions, gloves, safety footwear, safety helmets and high visibility waistcoats as well as equipment like life jackets, respirators, underwater breathing apparatus and safety harnesses.
The Personal Protective Equipment at Work Regulations 1992 is based on European Council (EC) Directive 89/656/EEC requiring similar basic laws throughout the European Union on the use of PPE in the workplace.
The outcome of the publication of these rules is that the Protection of Eyes Regulations 1974 SI 1974/1681 as amended by SI 1975/303, were completely revoked. The regulations relating to eye protection are now taken as the European norm.
They are more commonly known as the EN standards. These are: • EN 165 Personal eye protection: Vocabulary • EN 166 Personal eye protection: Specifications • EN 167 Personal eye protection: Optical test methods • EN 168 Personal eye protection: Non-optical test methods • EN 169 Personal eye protection: Filters for welding and related techniques:Transmittance requirements and recommended use • EN 170 Personal eye protection: Ultraviolet filters: Transmittance requirements and recommended use • EN 171 Personal eye protection: Infrared filters: Transmittance requirements and recommended use • EN 172 Sunglare eye protectors for industrial use • EN 207 Filters and eye protectors against laser radiation • EN 208 Eye protectors for adjustment work on lasers and laser systems • EN 379 Welding filters with transmittance variable by time and zone
The provision of glasses, goggles and shields
It is a statutory requirement that safety eyewear issued in the UK has to conform to the European standard EN166: 2002. This is comprised of many different levels of impact resistance.
It should be noted that if medium energy impact resistance, denoted as EN166 B, is required, or if the need arises for protection against corrosive materials, electrical arcs or welding materials, then prescription glasses are not sufficient and goggles or visors carrying the appropriate EN specifications must be used instead.
Visors or face shields will be required for high energy impacts as defined by EN166 A.
If protection is required over a wider area than just the eyes then full-face protection may be the only suitable solution. Health and safety managers can complain that this is impractical because of the tendency to misting, but this can be counteracted by the inclusion of respiratory equipment.
EN166 F, classified as low energy impact grade, is the highest level of resistance offered by safety spectacles or glasses, and will resist a 6mm, 0.86g ball travelling at 45 metres per second.
Safety glasses will usually include side shields to offer lateral protection, although these should not unnecessarily restrict the field of view.
Typically, polycarbonate lenses offer the greatest impact resistance, combined with the lowest weight.
In many working environments a temporary solution for glasses’ wearers is the issue of appropriate over-goggles, or eye shields. These should not be thought of as a long term solution for employees who are required to use them regularly. It is doubtful that they will provide a suitable level of comfort.
The reason for this is twofold. The effect of light refraction through two sets of lenses can be a distraction, and there is little chance of achieving a good, acceptable standard of physical comfort due to supporting two sets of frames. The end result will be a reluctance to wear them and can lead to injury. Another downside is that in the event of an impact this can be transmitted to the face via the wearer’s glasses underneath the over-goggles.
Frames and lenses
Frames are available in both metal and plastic form with nickel alloys - the most commonly used metal. Polyamide, polycarbonate and cellulose acetate are the most common plastic materials.
Styling of safety eyewear is necessarily limited by its functionality, but it is still possible to enjoy a limited range of male, female and unisex styles in a variety of colours and finishes.
There are other industry-specific considerations, such as the unsuitability of metal frames for food preparation environments, which may further limit the choices available.
It is always worth remembering the importance of providing appropriate safety eyewear to guests and visitors, however brief their exposure.
Regular wearers with a prescription requirement should be provided with glasses of the type that they most commonly wear. The dispensing of safety eyewear is not the ideal opportunity for a bifocals’ wearer to suddenly experiment with varifocals, and similarly it would be irresponsible for an employer to only fund the provision of single vision glasses when the employee is a regular wearer of varifocals.
It is not a requirement for employers to provide an eye test prior to the selection of glasses, but it is wise to make sure that the prescription is up to date, otherwise the safety glasses will have a shortened shelf life if a re-test leads to a new prescription.
Maintenance of safety glasses
Not all of the responsibility rests with the employer, as the wearer also has an obligation to wear the safety glasses provided in the manner for which they are intended.
Under no circumstances should the side shields be removed. These are an integral part of the protection offered. Selecting glasses with riveted rather than screw-in or clip on side shields that are so easily removed can significantly reduce the likelihood of staff succumbing to this temptation.
Broken or damaged safety glasses must be returned, usually via an optician’s practice to the EN166 licensed manufacturers, who can repair or replace as appropriate.
The lenses should not be retained for more than three years and the frames should be subjected to a maximum of five years’ use, meaning that the typical eye test cycle of two years provides a suitable interval for most employees to have their needs evaluated and their employer to fund a replacement pair.
Particular care should be taken in the cleaning and disinfection of polycarbonate lenses, which can have a very dramatic reaction to solvents such as acetone or Methyl Chloride.
Avoiding extremes of heat and humidity will also help to preserve the life of safety glasses and simplest of all, replacing them in their protective casing when out of use will keep scratches to a minimum.
Choosing the right options
The starting point for the provision of prescription safety eyewear has to be a health and safety audit and risk assessment to establish the precise requirements for the working environment.
It is the Management of Health and Safety at Work Regulations, 1992, that require employers to identify and assess workplace risk to health and safety and to establish necessary safeguards for employees.
In practical terms this means that the person responsible for the health and safety audit needs to assess whether the hazards warrant a plastic, glass or polycarbonate lens, whether a tinted lens is appropriate or to be avoided, and whether any other coatings should be included in the requirement. These are not decisions that can be made by someone who is not in a position to evaluate the specific risks.
The Personal Protective Equipment at Work Regulations, 1992, state that “every employer shall ensure that suitable personal protective equipment is provided to his employees who may be exposed to risk to their health or safety while at work, except where and to the extent that such risk has been adequately controlled by other means which are equal or more effective.”
The Health and Safety at Work etc Act, 1974, (HSWA) places a general duty of care on employers for ensuring the safety of their employees and others, and requires that no charge be made for the providing of PPE.
Published: 19th Nov 2012 in Health and Safety International