Section 13 - Eye and Face Protection
Primary Eye and Face Protection For Firefighters
Author: Mike McKenna
Risk Control Consultant
One Sierra Gate Plaza, Ste. 345B
Roseville, CA 95678
Voice: (916) 566-4316
Fax: (916) 783-0334
INTRODUCTION
There is a great deal of misunderstanding surrounding primary eye protection for firefighters including the use of self-contained breathing apparatus face pieces, faceshields, and Bourke-style eye shields. Each fire department should have a primary eye and face protection policy to provide a proactive, balanced, aggressive and direct approach in providing line personnel with primary eye protection, as required by NFPA and OSHA. The faceshields on the structural firefighting helmets provide only secondary eye/face protection as defined by American National Standards Institute (ANSI). The protection provided by the faceshield has long been inadequate when relied upon as primary eye/face protection and has provided a false sense of security. In addition, suppression personnel routinely rely on opaque faceshields, ill fitting and opaque goggles for eye protection during non-medical responses. Many personnel still use no eye protection during medical aid responses. A properly deployed faceshield provides only a minimal amount of face protection and even less eye protection. CAL/OSHA, for example, requires that primary eye protection be used, applicable to the potential danger and must meet ANSI Z87.1. Faceshields alone do not meet ANSI Z87.1 as primary eye protection.
Faceshields are often used incorrectly as the form of primary eye protection. It is evident that when eye protection equipment, such as faceshields and goggles, are exposed to ultraviolet degradation, abrasion, as well as products of combustion, they become scratched, cloudy, opaque, and can be rendered unserviceable in a very short period of time. In many instances, the faceshield is lifted so that the wearer can see what he is doing, leaving the eyes unprotected and exposed to the dangers of flying debris. This is also the situation with the inexpensive glasses issued for use on medical aid incidents. These glasses are usually made of soft plastic and are scratched very easily. The scratches often look like sandpaper was taken to the lenses and the view is completely obscured. The glasses are then removed, again, leaving the eyes vulnerable to injury or blood borne pathogens.
One of the initial uses for faceshields was radiant heat protection. This occurred when helmet manufacturers shortened the rear bill of the helmet and moved towards the Euro-styled structural helmet. This occurred in conjunction with impact cap and suspension changes to helmets that prevented them from being turned around. It had been a common practice to turn the traditionally shaped, long-billed, helmet around and use the rear bill to protect the wearer from radiant heat. With these design changes and the common use of SCBA the role of the faceshield changed. The faceshield was required by NFPA 1972 as a means of secondary eye protection. NFPA 1500 requires that partial face/eye protection be deployed on an emergency scene to protect personnel from "unexpected exposures" to injurious materials. CAL/OSHA requires that primary eye protection be used. It is very confusing.
Here is a short reference list of commonly used firefighting standards and applicable laws. The legal requirements may be different in your area, so when determining the minimum requirements, make sure that you check with all applicable regulations.
National Fire Protection Association standards are the legally recognized consensus standard for the industry and multiple references are made throughout publications mandating eye protection. NFPA reported that there were 3830 reported cases of eye injuries in 1997. The human eye is very susceptible to damage and can be a quick route to permanent injury and a medical disability. This is unfortunate because the eye is also one of the easiest parts of our body to protect. However, many departments still take the attitude that "it will never happen to me." It happened to firefighters over 3830 times in 1997. The best plan is to protect your department with a comprehensive eye/face protection policy. This type of policy protects the department from liability and protects the firefighters from injury. If you are an administrator and a firefighter suffers an unnecessary eye injury, you may have to explain why you failed to follow NFPA.
Below is a list of some of the eye/face protection requirements.
NFPA 1500 -- Fire Department Occupational Safety and Health Program, 1992 Edition.
5-10.1 "Primary face and eye protection appropriate for a given specific hazard shall be provided and used by members exposed to that specific hazard such primary face and eye protection shall meet the requirements of ANSI Z87.1, Practice for Occupational and Educational Eye and Face Protection."
5-10.2 "The full facepiece of SCBA shall constitute face and eye protection when worn."
5-10.3 "When operating in the hazardous area at an emergency scene without the full facepiece of SCBA worn, members shall deploy the helmet faceshield for partial face protection."
NFPA 1971 Protective Ensemble for Structural Fire Fighting (1997 Edition)
1-1.6 Nothing herein shall restrict any jurisdiction or manufacturer from exceeding these minimum requirements.
1-3 Definitions. Approved. "Acceptable to the authority having jurisdiction."
1-3 Definitions. Authority Having Jurisdiction. "The organization, office, or individual responsible for approving equipment, an installation, or a procedure."
1-3 Definitions. Faceshield. A helmet component intended to help protect a portion of the wearer?s face in addition to the eyes not intended as primary eye protection.
1-3 Definitions. "Partial Eye/ Face Protective Interface Component. An interface component intended to help shield a portion of the wearer?s face in addition to the eyes; not intended to provide primary eye protection.
5-7 The standard calls for the helmet to provide partial eye/ face protection through the use of a faceshield or to have the partial eye/ face protection component permanently attached to the helmet.
IFSTA Essentials, Third Edition, Chapter 3, Firefighter Personal Protective Equipment, page 52.
"Any time there is a danger to the eyes, safety glasses or goggles must be worn."
"For more information on requirements for eye protection reference ANSI Standard Z87.1."
NFPA 1500 Handbook, Edited by Bruce Teele, NFPA, 1993
"When specific danger to the eyes is present, such as while operating saws or other tools or pulling ceilings, primary eye protection is required. Primary eye protectors must meet federal OSHA regulation for eye protection in 29 CFR 1910.133. Primary eye protection may be provided by goggles or SCBA facepieces. "The faceshield is not intended to be used as primary eye protection, but is required by the standard because it provides partial face and eye protection when specific hazards are not present or expected, but unexpected exposures could occur given the nature of emergency scenes."
CAL/OSHA General Industry Safety Orders: Article 10.1
Personal Protective Clothing and Equipment for Firefighters
Section 3401(a) These Orders establish minimum requirements for personal protective clothing and equipment for fire fighters when exposed to the hazards of fire fighting activity, and take precedence over any other Safety Order with which they were inconsistent."
Section 3403(B) Section 3-9 "Faceshields" shall be optional when protection required by Section 3404 is provided.
Section 3404(1) Employees exposed to eye injury hazards shall be protected in accordance with the provisions of Section 3382.
Section 3382(d) Design, construction, testing and use of devices for eye and face protection shall be in accordance with ANSI Z87.1.
Section 3410(b) Wildland Firefighting Requirements. Eye Protection. Employees exposed to eye injury hazards shall be protected in accordance with the provisions of Section 3382.
American National Standards Institute, Practice for Occupational and Educational Eye and Face Protection Standard Z87.1
Definition. Faceshield - A protective device commonly intended to shield the wear?s face, or portions thereof, in addition to the eyes, from certain hazards. Faceshields are secondary protectors and shall be used only with primary protectors.
Definition. Goggle - A protective device intended to fit the face immediately surrounding the eyes in order to shield the eyes from a variety of hazards.
Section 10.1 - While they are primary protectors and may be used alone, they may also be used in conjunction with the other protectors
THE PROBLEM ? CONFLICTING REQUIREMENTS
CAL/OSHA requires primary face and eye protection appropriate for the specific hazard be provided and that that protection must meet ANSI Z87.1.
NFPA 1971 (1997 Edition) requires a faceshield or permanently attached goggles. NFPA 1971 requires primary or secondary eye protection.
Faceshields are quickly damaged beyond functional use. In addition, the NFPA 1971 requirement of permanent attachment of the goggles to the structural helmet exposes the goggles to the exact elements and conditions, which destroy the faceshields. There are several problems associated with the current deployment of the goggles on top of the helmet:
1. Goggles are damaged from ultraviolet degradation, dirt, heat and other products of combustion.
2. Goggles are deformed from their original design shape to the shape of the helmet. The goggles are held against the helmet shell by elastic cords. This pressure deforms the goggles to such a shape that renders them useless.
3. The elastic or thin rubber strap will become stretched out and the goggles cannot be placed into the proper location. Replacement of the elastic is an unrealistic solution, as the elastic is rendered useless in a matter of weeks. The strap retention systems are made with inexpensive and brittle materials causing failure after even short exposures to fire, or even from rough storage.
4. Inexpensive goggles can also melt on top of the helmet and can open the opportunity for injury under high heat exposures.
5. Many goggle styles prevent the faceshield from being deployed. The goggles are thick and obstruct the deployment of the faceshield. One particular model of goggle is designed to be used for people who wear prescription glasses and is commonly used by fire departments for general use. However, this model does not allow for any faceshield deployment. While it is not common, personnel have both goggles and faceshield to facilitate access to eye and face protection.
6. Placement of the goggles as well as the faceshield on the top of the helmet increases weight and decreases the balance of the helmet by raising the center of the gravity.
The damage to goggles is magnified by the selection of inexpensive goggles. Many goggles used by the fire service have thin plastic lenses and retention systems that will be damaged and rendered unusable very quickly. Many of these problems will be minimized by the evolution of goggles under the NFPA 1971 requirement. The placement of goggles, which must meet NFPA 1971 requirements, will force the development of a more durable and suitable goggle and retainer system.
Even with the negatives, the NFPA 1971 requirement is based on solid logic. There is always the possibility that inexpensive goggles that do not meet the heat standard can melt and could possibly cause injuries.
The NFPA 1971 Committee recognized that ease of access would determine the amount of use that eye protection devices will receive. In order for firefighters to use eye protection, it must be readily accessible and fit properly.
A SOLUTION
* Provide personnel with primary eye protection that meets the requirements of the General Industry Safety Orders that are applicable.
* Develop a primary eye protection policy that conforms to the required standards and legal requirements.
* Implement a primary eye protection policy and to provide department wide training. Some states require that personnel be trained on any new equipment or policy. Personnel should receive training on the goal of the eye protection policy and well as the plan for implementation. Records should be kept along with copies of the lesson plans. This information can will be very useful in case of a catastrophic injury.
A PLAN
1. Issue personnel with one each pair of quality safety glasses meeting ANSI Z87.1.
2. Development of a Primary Eye and Face Protection Policy. Policy should include provisions so that eyes appropriately protected 100% when the potential of eye injury exists by one of the following means:
* ANSI approved Safety Glasses
Selection of safety glasses should include:
1. ANSI Z87.1 labeling
2. Complete eye coverage
1. Side guards
2. Brightly colored frames to assure compliance
3. Proper fit
4. Retention cords
* Safety Goggles
1. ANSI Z87.1 labeling
2. Quality and heavy duty construction
3. Proper fit
4. NFPA 1971 Compliance (if on structure helmet)
* SCBA Facepiece1
3) Implementation of Policy.
IMPLEMENTATION
The implementation of the Primary Eye Policy should be initiated with department wide company training. During the department, training the policy should be explained. The underlying theme of the policy is that the eyes are required to be protected at the appropriate level 100% of the time. These will be clearly spelled out in the policy and procedures manual.
The policy depicts three levels of protection:
Policy should require the use of a SCBA facepiece for all structure fires, vehicle fires, dumpster fires, or anytime there is visible smoke or haze.
Goggles should be required to be used with shroud for wildland operations. In addition, goggles should be required during vehicle extrication and saw operations. While the eyeglasses provide adequate protection, but the goggles are not as easily dislodged from the face.
Safety glasses are considered the minimum level of protection when any type of hazard potentially exists. They are required during all other incidents. Safety glasses, as the minimum requirements, allow all personnel to be protected by ANSI Z87.1 level protection during all incidents.
The glasses are not necessarily suitable replacements for the goggles. Each component provides a different level of protection that is appropriate to the level of potential dangers the eyes may face. It is very important to note that for this type of policy to be successful the eye protection device must be accessible at all times and personnel should be aware of what level is appropriate for given hazard.
In addition, it should be noted that the Bourke-style eyeshields is "cosmetic" in nature and is not to be used as eye protection. Bourke-style eyeshields are not NFPA 1971 approved and are not considered primary eye protection.
JUSTIFICATION
This Primary Eye Protection is a more comprehensive policy that exceeds NFPA 1971 and is compliant with NFPA 1500, Section 3404 and 3382 of the California General Industry Safety Orders: Article 10.1. Policy 228.113 Primary Eye Protection requires that ANSI Z87.1 eye protection be used on all incidents to "provide partial face and eye protection when specific hazards are not present or expected."
This primary eye protection, as defined by the legal requirements, is already required because it states that a SCBA must be worn on all structure fires, vehicle fires, dumpster fires, or anytime there is visible smoke or haze. Under ANSI Z87.1, the SCBA facepiece is considered primary eye protection. The policy also requires the use of goggles during wildland operations. This is consistent with the requirement of California's General Industry Safety Orders Section 3410(6)(b), which requires the use of primary eye protection during wildland fire operations.
The issue of primary and secondary eye protection has been the topic of controversy for several years. The standards and codes are inconsistent and mutually exclusive on numerous points. CAL/OSHA General Industry Safety Orders Section 3401(a) takes precedence over any other safety order. Section 3404 requires that eye be protected from hazards in accordance with Section 3382. Section 3382 requires that eye protection meet ANSI Z87.1.
The implementation of this policy also meets or exceeds the requirements put forth for the protection of emergency medical personnel from blood and airborne pathogens.
CONCLUSION
The implementation of Primary Eye Policy is a comprehensive primary eye policy deigned to be as unobtrusive as possible while meeting the legal requirement of primary eye protection as well as exceeding the various NFPA and legal requirements. The policy is designed to ensure that personnel will be protected from eye related injuries. It is, for example, impossible to list circumstantial exceptions to the policy without diluting the policy and its effectiveness.
In order for the policy to be effective several things must occur:
1. There must be an organizational commitment to eye protection.
2. The policy must be enforced.
3. Eye protection devices must be comfortable and of a quality, that will encourage use.
4. The eye protection devices must be easily accessible. If the devices are not accessible, they will not be used.