5.2 Head, Eye, Face, Hand & Foot Protection (29 CFR 1910.133-138)

5.2 Head, Eye, Face, Hand & Foot Protection (29 CFR 1910.133-138)

Introduction to Body Part Protection

To protect workers from physical, chemical, and electrical hazards, OSHA has established specific regulations for different parts of the body. These are detailed in 29 CFR 1910.133 (Eye and Face Protection), 29 CFR 1910.135 (Head Protection), 29 CFR 1910.136 (Foot Protection), and 29 CFR 1910.138 (Hand Protection). Each standard references specific consensus standards set by organisations like the American National Standards Institute (ANSI) and the American Society for Testing and Materials (ASTM). Compliance requires an understanding of these standards, equipment classes, and selection parameters.

Head Protection & ANSI Z89.1 Hard Hat Classes

Under 29 CFR 1910.135, employers must ensure that employees wear protective helmets (hard hats) when working in areas where there is a potential for injury to the head from falling objects. Additionally, employees must wear protective helmets designed to reduce electrical shock hazards when working near exposed electrical conductors.

All industrial hard hats must comply with the consensus standard ANSI/ISEA Z89.1. Hard hats are classified by their impact protection type and their electrical performance class.

Impact Protection Types

• Type I: Helmets intended to reduce the force of impact resulting only from a blow to the top of the head.
• Type II: Helmets intended to reduce the force of impact resulting from a blow to the top, sides, front, and back of the head. Type II helmets feature a thicker foam liner and are more suitable for environments with lateral swing hazards.

Electrical Performance Classes

• Class G (General): Designed to reduce the danger of contact with low-voltage conductors. They are proof-tested at 2,200 volts (phase to ground). This voltage is for testing purposes only and does not represent the safe working voltage.
• Class E (Electrical): Designed to reduce the danger of contact with higher-voltage conductors. They are proof-tested at 20,000 volts. These helmets provide the maximum level of electrical protection and are commonly used by utility workers and electricians.
• Class C (Conductive): Conductive helmets that are not intended to provide protection against contact with electrical hazards. They are often ventilated (having air holes) to keep the worker cool, but because of these vents and materials, they offer zero electrical insulation.

Hard hat shells and suspensions must be inspected daily for cracks, dents, tears, and signs of degradation from sunlight or chemical exposure. In general, suspensions should be replaced annually, and the hard hat shell should be replaced every two to five years depending on wear and exposure.

Eye and Face Protection (29 CFR 1910.133)

The standard requires that employers ensure affected employees use appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or injurious light radiation.

Eye and face protection must comply with ANSI Z87.1. Critical compliance directives include:

• Side Protection: Employees must use eye protection that incorporates side protection (side shields) when there is a hazard from flying objects. Detachable side shields (e.g., clip-on or slide-on shields) that meet ANSI Z87.1 are acceptable.
• Prescription Lenses: Employees who wear prescription (Rx) lenses must either wear eye protection that incorporates the prescription in its design, or wear eye protection that can be worn over the prescription lenses (such as over-the-glass goggles) without disturbing the proper position of the prescription lenses or the protective lenses.
• Face Shields vs. Safety Glasses: A common compliance error is using a face shield as a standalone eye protector. Under ANSI Z87.1 and OSHA regulations, face shields are considered secondary protection. They protect the face from splashes and large debris but do not protect the eyes from all angles (such as fine dust or liquid vapors). Therefore, face shields must always be worn over primary eye protection, such as safety glasses or splash goggles.
• Filter Lenses: For operations that involve welding, cutting, brazing, or soldering, employees must use equipment with filter lenses of a shade number appropriate for the work. For example, open-arc welding typically requires shade numbers from 10 to 14, while oxy-fuel gas cutting requires shades 3 to 6, to protect the eyes from optical radiation (ultraviolet and infrared light) that can cause permanent retina damage or "welder's flash" (photokeratitis).

Foot Protection & ASTM F2413

29 CFR 1910.136 requires that employees wear protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, and where employees' feet are exposed to electrical hazards, such as static-discharge or electric shock hazards.

Protective footwear must comply with the ASTM F2413 standard (which replaced the older ANSI Z41 standard). ASTM F2413 specifies performance requirements for protective toe caps, metatarsal protection, electrical hazard protection, conductive protection, static dissipative protection, and puncture resistance.

• Impact (I) and Compression (C) Resistance: Safety shoes are tested for impact (heavy objects falling on the toe) and compression (heavy objects rolling over the toe). The standard testing levels are typically rated for 50 or 75 foot-pounds of impact energy and 2,500 pounds of compression force.
• Metatarsal Protection (Mt): Protects the metatarsal bones on the top of the foot between the ankle and the toes. Metatarsal guards are either built into the shoe or strapped to the outside.
• Electrical Hazard (EH): Footwear designed to be non-conductive and prevent the user from completing an electrical circuit to the ground. These shoes are tested to withstand 18,000 volts at 60 Hz for one minute with no current leakage in excess of 1.0 milliampere under dry conditions.
• Conductive (Cd) and Static Dissipative (SD): Conductive footwear is designed to discharge static electricity from the body to the ground in environments where explosive or volatile chemicals are present. Static dissipative footwear reduces the accumulation of excess static electricity while maintaining a level of electrical resistance.

Hand Protection & Chemical Gloves (29 CFR 1910.138)

Hand protection is required when employees' hands are exposed to hazards such as skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns, and harmful temperature extremes.

Unlike head or eye protection, there is no single consensus standard covering all hand protection. Instead, employers must select gloves based on the specific tasks to be performed, the conditions present, and the performance characteristics of the glove material relative to the hazards.

For chemical protection, glove selection is a precise science. The performance of a chemical-resistant glove is measured using three key metrics:

1. Permeation: The process by which a chemical moves through a protective glove material on a molecular level. Unlike penetration, which occurs through physical holes, seams, or tears, permeation occurs through the solid material itself.
2. Breakthrough Time: The elapsed time between the initial contact of the chemical with the outside surface of the glove and its subsequent detection on the inside surface of the glove. Employers must select gloves with a breakthrough time that exceeds the expected duration of the work task.
3. Degradation: A physical change in a glove material caused by chemical contact. Signs of degradation include swelling, softening, stiffening, shrinking, cracking, color changes, or becoming brittle. A glove that degrades quickly will allow chemicals to pass through rapidly.

Employers must refer to manufacturer chemical compatibility charts and Safety Data Sheets (SDSs) to select the correct glove material. Common glove materials include:

• Nitrile: Good general resistance to oils, greases, solvents, and punctures.
• Neoprene: Offers excellent resistance to acids, bases, alcohols, and fuels.
• Butyl Rubber: Highly resistant to gases and vapors, as well as ketones (like acetone) and esters.
• Viton: Provides superior protection against aromatic and chlorinated solvents, but has poor resistance to ketones.

There is no "universal" chemical glove; using the wrong material can lead to immediate glove failure and severe chemical burns or systemic toxic exposure.