ML20246J380
| ML20246J380 | |
| Person / Time | |
|---|---|
| Issue date: | 06/05/1989 |
| From: | Congel F, Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), Office of Nuclear Reactor Regulation |
| To: | Jim Hickey, Knapp M, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8907170352 | |
| Download: ML20246J380 (7) | |
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JtM 051989 Malcolm R. Knapp, Director, DRSS, Region 1 IKEMORANDUtl FOR:
J. Philip. Stohr, Director, DRSS, Region 11 John W. N. Hickey, Acting Director, DRSS, Region III Arthur B. Beach, Director DRSS, Region IV Ross A. Scarano, Director, DRSS, Region V FROM:
Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety Office cf Nuclear Meterial Safety and Safeguards
SUBJECT:
CONTACT LENSES USED WITH RESPIRATORS
REFERENCES:
(a) Lawrence Livermore National Laboratory report of 16, 1985 (DE86001775, UCRL-53653) by August Robert A. da Rosa and CLtherine heaver, entiticd, "Is It Safe to Wear Contact Lenses with a full-Facepiece Respirator?"
(b) U.S. Departnent of Energy menorandum of St.ptember 23, 1986 Amenda nt of the Occupa-f rom Mary L. Walker,
Subject:
tional Safety and Health Administration (OSHA) Prohibition on Wearing Contact Lenses in Contaminated Atmospheres with full-face Respirators.
(c) U.S. Departnent of Labor, Occupational Safety and Health Administration, memorandum of February 8,1988 from Thomas Shepich,
Subject:
Contact tenses Ustd with Respirators (29 CFR 1910.34(e)(5)(ii)).
(d) ANSI 2Ef.2-1989, American National Standard Practices For Respiratory Protection.
Peferences (c) and (b) abcve accompanied the June 3,1986 menorandum fron Rctert L. Baer, Office of it.spection ard Enforcement to the Regional Branch Chief:, of the Emerpttcy Preparce'ress and Radiological Protection of the Divi-sion of Radiatior. Safety and Safeguards. These references shed ocw light on CONTACT:
- Robert A. Meck, NRR A S149' 3 g f0 l D 0 kh
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thitiple Addressees JllN 0 51989 -
,the NRC policy.on the use of prescription lenses with respirators. As refer-enced in Regulatory Guide 8.15 and stated in NUREG-0041, the policy states:
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" Contact lenses shall not be worn with full face respirators. These devices present a distIEEtlazard to thETndivicual owing to the -
possibility of the lenses slipping because of pressure on the outside corners of the eyes from a full face mask or a speck of' dirt getting under them while the respiretor is being worn. Corrective action would entail. removing the respirator, which would mean that the individual would either have to leave the contaminated atmosphere,or run the risk of exposure if he removed the respirator in the contami-nated area."
On the basis of references (a) and (b), the June 3, 1986 memorandum contem-plated a policy change that would permit NRC licensees to use contact lenses with respirators. However, at that tisae the U.S. Department of Labor, Occupa-tional Safety and Health Administration (OSHA) prohibited the use of contact lenses with respirators in nonradioactive environments. The NRC staff post-poned the contemplated policy. charge, rather than implementing different policies and regulations for radioactive and nonradioactive environments.
Subsequently, OSHA revisited this subject.
The enclosed copy of the February 8,1988 memorandum from OSHA, reference (c),
modified OSHA enforcement procedures so that, among others, violations involv-ing the use of gas permeable and soft contact lenses shall be documented but citations shall not be issued.
In view of this modified enforcement procedure of OSHA', the previously contemplated NRC policy change to permit the use of contact lenses with respirators was reconsidered. The staff continues to believe that the use of contact lenses with respirators will enhance overall worker safety by improving the vision of those persons who regularly wear contact lenses and who are required to use respirators in the course of their jobs.
In response to requests from NRR, the Office of Nuclear Reguintory Resenrch has budgeted for comprehensive revisions of.10 CFR Part 20 and Regulatory Gu'ide 8.15. These revisions will incorporate updated standards including those developed by ANSI Committee 288.2. Specifically, the ANSI Comittee draf t report, reference (d) (in publication)',' states:
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"6.5.3.3 Use of cor. tact lenses is permitted with respirator wear provided the individual has previously demonstrated that he or she has had successful experience wearing contact lenses.
The contact lens wearer shall be required to have practice wearing the respirator while' wearing the contact lenses."
Accordingly, the NRC staf f position is changed to permit the use of contact lenses with respirators by adoption of the above draft ANSI standard as oboted.
We expect that licensees will be informed of this policy change by manifold sources including the NRC Regioral Offices, Industry Organizations, and documents made available to the Public Document Rooms.
7 Multiple Addressees JUN 051989 c.1 The NRC staff contact in NRR on this subject is Robert. A.' Meck (492-1111), and in NMSS the NRC staff. contact is Donald A. Cool (492-3422). Please report any technical problems stenning from the.use of contact lenses with respirators to the appropriate contact. Such information may be useful.in rulemaking.
Original signed by Frank J. Congel
. Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation Glen L. Sjoblom A.
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards
Enclosure:
As Stated cc:
T. Shepich, OSHA P. Womback, DOE R..DaRoza, ANSI R. E. Masse, INPO N. Bollinger, NIOSH L. Fairobent, NUMARC CONTACTS:
Robert A. Meck, NRR 492-3149 3.u n
.;n a Donald A. Cool, NMSS
- o 492-3422 Distribution:
FJCongel, NPR LJCunningham, NRR
'JEWigginton,LNRR n THEssig, NRR.
FEeck, NRR WDTravers, NRR RJBarrett,'NRR" FJHebdon, NRR AKRoeckitin, RES LCRouse, NMSS DACool, NMSS SSoong, NiiSS WSPennington, NMSS RLAndersen, TTC PDR Central Files RPB R/F JLieberman, OE 0:IMN M i '
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'" 8 nn MEMORANDUM FOR:
REQIONAL'AD INIpTRATORS eo Car &ey, Director
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THROUGH:
( Office of Field Programs FROM Tnomas Snepich, Director
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Directorate of Compliance t
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SUBJECT:
Contact Lenses Used Witn espirators (29 CFR 1910.34 (e) (5) (ii)
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Section 1910.134 (e) (5),11), in part, reads, "... Wearing.of contact lenses in conc.sminated atmospheres witn a respirator snall not be allowed...."
Tnis wording was adopted in 1971 into OSHA's standards without enange from the American National l
Standard " Practices for Respiratory Protection,"
ANSI Z88.2-1969,,in accordance witn Section 6 (a) of tne Occupational Safety and Healtn Act of 1970.
Tne current ANSI Z88.2-1980 standard also includes tnis restriction on ene wearing of contact lenses.
OSHA has frequently been asked wny the prohibition on contact i
lenses is incluced in our requirements and, as a result, the
-l matter has been investigated, including the fcnding of a researen project on tne wearing of contact lenses by firefignters using j
full facepiece respirators.
Current members of tne ANSI Z88.2 j
Committee nave suggested hypothetical scenarios wnien they believe would nave supported tne prohibition.
However, actual j
inciden'ts resulting in employee erposure to inhalation hazares or to eye nazards wnich were aggravated by the use of contact lenses were not forthcoming from the ANSI Committee members contacted.
Tne uncertainty of reasons for tne prohibitioncoa contact lens use prompted funding of tne researen project concucted by Lawrence Livermore National Laboratories (LLNL).
A copy of tne final LLNL report is attacned for your information.
Recommendations contained in the LLNL report read, " Based on a 3
numerical analysis of the responses to the questionnaire, our l
follow-up interviews witn tnose incicating tne worst problems, reading tne 829 comments on positive or negative experiences and
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witn contacts, we believe the prohibition against wearing con-tacts while using a full-facepiece respirator should be revoked or withdrawn.
Wearers of corrective lenses would have the option of wearing eitner contacts or eyeglasses witn their full face-piece respirators.
One must keep in mind, however, that some people do not adapt well to contacts.
If tne person cannot comfortably wear contacts in everyday non-work situations, tnen he will probably not adapt well to using tnen with a full-facepiece respirator.
Also, a person's facial snape and eyeglass prescription may be such that he cannot obtain and retain a proper alignment of his eyeglasses inside the full-facepiece.
In tnis case, he would have to wear contacts, or no
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corrective lenses at all....
Considering the severe con'ditions under whicn firefighters must work, we believe it is unlikely tne working conditions of any other SCBA users would pre-tnat clude the similar use.of contact lenses.
Tnis would also include negative-pressure air purifying respirators."
Other reports and articles (list attacned) have been reviewed which further support that the pror,1bition in tne current standards is unwaranted.
Altnougn, tne LLNL report deals specifically with firefignters and full-facepiece SCBA's, OSHA knows of no reason why other work
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situations and types of respirators would present greater nazards relevant to wearing contact lenses.
Tnerefore, this memorandum applies to all respirator use in all workplaces unless specific information snould become available which indicates a hazard wnien nas not been considered.
Even thougn mucn of tne material mentioned above applies to all types of contact lenses, OSHA staff wisnes to furtner investigate the issue of non gas permeable hard. contact lenses before com-pletely suspending tne prohibition, since the original prohibi-tion in ANSI Z87.1 was adopted when tne use of this type of nard lens was prevalent.
In consideration of tne results of our investigation, and in accordance with the Agency's intent to modify tne rule, an interim enforcement policy is appropriate.
Accordingly, tais memorandum modifies current enforcement procedures as follows:
1.
Violations of tne respirator standard involving the use of gas permeable and sof t contact lenses snall continue to be documented in the case file and recorded as de j
minimis; citations shall not be issued.
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Evidence indicating any negative effect associated with 2.
the use of contact lenses with respirators should be Benefits associated witn the provided to this office.use of contact lenses with respirators would als useful to this office.*
Tne issue witn non gas permeable hard contact lenses will be which is now resolved in the revision effort for S1910.134 underway.
Attachments O
n, H
O e
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1.
Giroux, Arthur R., " Time to Reconsider Contact Lens Policies?"
Occupational Hazards, November 1985.
2.
Nilsson, Sven Erik G., et al, (a) "The Use of Contact Lens in Environments with Organic Solvents, Acids or Alkalis," ACTA Opnthalmologica, Vol. 60, 1982.,
(b) "Tne Use of Contact Lensas in Het or Damp Environments,"
ACTA Ophtnalmologica, Vol. 58, 1980;
" Contact. Lenses and Meenanical Trauma to the Eye," ACTA (c) Ophtnalmologica, Vol. 59, 1981;
" Contact Lens Wear in an Environmental Contaminated with (d) Metal Particles," ACTA Opntnalmologica, Vol. 61, 1983.
3.
Da Roza, Robert A.,
Is it Safe to Wear Contact Lenses?"
Lawrence Livermore National Laboratory, UCRL-53653, August 16, 1985.
Gutnrie, Jonn W., et al, "An Investigation of the Cnemical 4.
Contact Lens Problem," Journal of Occupational Medicine, Maren 1975.
" Protection of the Police Aalphen, C. C. Kok-van, et al, 5.
Against Tear Gas. witn Sof t Lenses," Military Medicine, Vol.
150, August 1985.
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6.
Kartenner, Mark N.,
Fight Fires with Contacts?"
Contact Lens Forum, Maren 1985.
7.
Hirsenfelder, Dennis, " Contact Lenses in tne Workplace:
Tne Dilemma," Signtsaving, Vol. 52, No. 1, 1983, National Society to Prevent Blindness.
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