BY MICHAEL F. McKENNA
The national fire protection association (NFPA) reported 3,830 cases of eye injuries in 1997. The human eye is very susceptible to damage and can be a quick route to permanent injury and medical disability. This is unfortunate, because the eye is also one of the easiest parts of the body to protect. However, many fire departments still ignore eye safety. The best plan is to protect your department with a comprehensive eye/face policy that protects the firefighter from injury and the department from liability. If you are an administrator and one of your firefighters suffers an unnecessary eye injury, you may have to explain why you failed to comply with the Occupational Safety and Health Administration (OSHA) and the NFPA.
There is a great deal of misunderstanding surrounding primary eye protection for firefighters, including the use of self-contained breathing apparatus (SCBA) face pieces, face shields, goggles, and BourkeT-style eye shields. There are many eyewear options, and even more requirements. Each fire department should have a proactive, balanced, aggressive, and direct approach in providing line personnel with primary eye and face protection. Eye protection is required by the NFPA standards and OSHA and is recognized by the International Fire Service Training Association (IFSTA).
Preparing such a policy may seem an easy task at first. However, doing so means sorting through conflicting requirements and recommendations. The following overview is provided as a guide.
The main challenge is that the face shield has been attached to the helmet and has been relied on for both face and eye protection. However, when relied on as primary eye/face protection, the face shield has proved to be inadequate, but its ubiquity has provided a false sense of security. In addition, suppression personnel routinely rely on opaque face shields and ill-fitting and opaque goggles for eye protection during nonmedical responses. Many personnel still use no eye protection during medical-aid responses.
A properly deployed face shield provides only a minimal amount of face protection and even less eye protection. OSHA 29 CFR 1910.133(a)(1) requires that primary eye protection, applicable to the potential danger, be used. Section (b) (1) requires that the protective equipment must meet American National Standards Institute (ANSI) Z87.1. Face shields alone do not meet ANSI Z87.1 requirements for primary eye protection. The face shields on structural firefighting helmets provide only secondary eye/face protection as defined by ANSI. NFPA 1971, Standard for Protective Ensemble for Structural Fire Fighting, requires goggles or face shields; the wearer is to choose from two different levels of protection.
One of the initial uses for the face shield was radiant heat protection. The face shield was added when helmet manufacturers shortened the rear bill of the helmet and moved toward the Euro-styled structural helmet. This occurred in conjunction with impact cap and suspension changes to helmets that prevented the helmets 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. These design revisions and the more common use of SCBA changed the function of the face shield from basic radiant heat protection to face protection, and the fire service has continued to rely on the face shield for eye protection.
It is evident that when eye protection equipment, such as face shields or goggles, are exposed to ultraviolet degradation, abrasives, or products of combustion, they become scratched, cloudy, and opaque and may be rendered unserviceable in a short period of time. Suppression personnel routinely rely on opaque face shields or ill-fitting and opaque goggles for eye protection during responses. In many instances, the face shield is lifted so that the wearer can see what he is doing, leaving the eyes unprotected and exposed to the dangers of flying debris.
Another problem is that a properly deployed four-inch face shield is about three inches from the face, which leaves the face vulnerable to flying debris. NFPA 1500, Fire Department Occupational Safety and Health Program, requires that partial face/eye protection be deployed on an emergency scene to protect personnel from “unexpected exposures” to injurious materials. However, the face shield is not a universal protector.
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 scratch very easily. The lenses often look like they were scrubbed with sandpaper, and the view is completely obscured. The responders often remove the glasses, leaving their eyes vulnerable to injury or blood-borne pathogens.
The fire service is bombarded by many eye protection requirements and recommendations, many of which are mutually exclusive. As an example, OSHA requires primary face and eye protection appropriate for the specific hazard be provided and that the protection meet ANSI Z87.1, but NFPA 1971 (2000 edition) requires a face shield or permanently attached “partial eye/face protective interface component” (goggle). NFPA 1971 requires primary (attached goggle) or secondary eye protection (face shield). Many firefighters still use the face shield as primary eye protection when the label clearly states that it is not. The NFPA requires a warning label that states: “WARNING: This face shield does not provide primary eye protection. Additional protection may be required. See ANSI Z87.1.” The face shield cannot be substituted for goggles. The level of protection is not interchangeable.
NFPA 1500 requires eye protection in accordance with ANSI Z87.1 or the use of the SCBA face piece. The SCBA face piece must not have a large unprotected opening. To meet this requirement, some brands must have the second-stage regulator in place. The NFPA 1500 Handbook states: “When specific danger to the eyes is present, such as while operating saws or other tools or pulling ceilings, primary eye protection is required.” That would indicate that either 29 CFR 1910.133 goggles or an SCBA face piece would need to be used. The NFPA 1500 Handbook states further: “The face shield 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.” NFPA 1500 requires that “goggles or other appropriate primary eye protection be worn while participating in operations where protection from flying particles or chemical splashes is necessary.”
IFSTA makes many recommendations on eye protection. For example, IFSTA Essentials, Fourth Edition, page 81, states: “Face shields provide secondary protection and may not provide the eye protection required against flying particles or splashes.”
It is a clear mandate that the eyes have to be protected. For the eyes to be protected, the protection needs to be near the eyes. The problem is that face shields or anything permanently attached to a helmet (and, therefore, close to the eyes) is quickly damaged beyond functional use. Following are several problems associated with the deployment of goggles or face shields on top of the helmet:
- Face shields and goggles are damaged from ultraviolet degradation, dirt, heat, and other products of combustion.
- Inexpensive goggles change from their original design shape to conform to the shape of the helmet-not the shape of the face. Many times, elastic cords or bands hold the goggles against the helmet shell. This pressure can deform the goggles to the extent that they become useless.
- Inexpensive goggle-mounting hardware becomes stretched out, and the goggles cannot be placed in the proper location. Replacing the elastic alone is an unrealistic solution, since low-grade elastic becomes useless in a matter of weeks. The strap-retention systems are often made with inexpensive and brittle materials, causing failure after short exposures to fire or even from rough storage.
- Inexpensive goggles can also melt on top of the helmet and can create the potential for injury under high-heat exposures. The NFPA 1971 requirement that the goggles be permanently mounted and tested is an attempt to keep inexpensive goggles off the helmet, to help lessen the possibility of injury from melting.
- Placing the goggles or face shield on the top of the helmet increases weight and decreases the helmet’s balance by raising the center of gravity. Helmet manufacturers build this into the system but would probably rather not.
The NFPA 1971 requirement that the goggles will now be part of the protective ensemble and be tested as such forced the development of more durable goggles with better retention systems. The NFPA 1971 Committee also recognized that ease of access would determine the amount of use eye protection devices will receive. For firefighters to use eye protection, it must be readily accessible, and goggles must fit properly every time they are donned.
A PRIMARY EYE PROTECTION PLAN
- Issue to personnel one each pair of quality safety glasses meeting ANSI Z87.1.
- Develop a Primary Eye and Face Protection Policy that includes provisions so that eyes are appropriately protected 100 percent by one of the following means when the potential for eye injury exists:
Safety glasses should meet the following criteria:
- ANSI Z87.1 labeling,
- complete eye coverage,
- side guards,
- brightly colored frames to ensure compliance,
- proper fit, and
- retention cords.
Safety goggles should meet the following criteria:
- ANSI Z87.1 labeling;
- high-quality and heavy-duty construction;
- proper fit, rapid adjustment;
- NFPA 1971 compliance (if on structural firefighting helmet); and
- goggle spectacle kit.
- SCBA face piece, making sure there are no unprotected openings.
The Primary Eye Policy should be initiated with a department mission statement that states the goal is to protect the eyes. This mission statement should be part of a comprehensive safety program that addresses all aspects of firefighter safety. Implementation should include departmentwide company training to explain the policy and demonstrate support. During the department training, the policy should be explained clearly: The underlying theme is that the eyes are required to be protected at the appropriate level 100 percent of the time. These points need to be clearly spelled out in a policy and procedures manual.
- The eyes shall be protected appropriately for the hazard 100 percent of the time by one of the approved methods.
- The policy should depict three levels of primary eye protection: safety glasses, goggles, and SCBA face piece.
- The policy should require the use of an SCBA face piece for all structure fires, vehicle fires, and dumpster fires and anytime there is visible smoke or haze.
- Goggles should be required to be used with a shroud for wildland operations. In addition, goggles should be required during vehicle extrication, saw operations, helicopter landings, and any other time firefighters are exposed to flying debris. Although the safety glasses provide adequate protection, the goggles will not be dislodged from the face as easily.
- Safety glasses should be 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 to the ANSI Z87.1 level of protection during all incidents. Safety glasses should be part of the universal precautions for protection against bloodborne and airborne pathogens.
- Safety glasses are not necessarily suitable replacements for goggles. Each component provides a different level of protection appropriate for 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 of protection is appropriate for a given hazard.
- Serious consideration should be given to providing two sets of goggles-one set for wildland use and one for use with structural firefighting gear.
- BourkeT-style eyeshields are “cosmetic” in nature and are not to be used as eye protection. They are not NFPA 1971-compliant and are not considered primary eye protection.
Model Policy Elements
The goal is to implement a comprehensive policy that is as unobtrusive as possible while meeting the legal requirements for primary eye protection and exceeding NFPA requirements. Avoid listing circumstantial exceptions that may dilute the policy’s purpose. For the policy to be effective, there must be an organizational commitment to eye protection, the policy must be enforced, eye protection devices must be comfortable and of a quality that will encourage use, and the devices must be easily accessible or they will not be used.
MICHAEL F. McKENNA, a 22-plus-year veteran of the fire service, is a captain in the Sacramento County (CA) Fire Protection District, where he serves as protective clothing manager, responsible for protective clothing needs and respiratory compliance. He is a risk consultant at Gregory Bragg & Associates, Inc., in Roseville, California. He is an instructor in fire chemistry and combustion, hydraulics, and risk management at American River College in Sacramento and serves as a technical resource for NFPA 1971, Standard on Protective Ensemble for Structural Fire Fighting. He has a bachelor’s degree in economics from the California State University Sacramento, an associate’s degree in fire technology from American River Junior College, and is working toward a master’s degree in fire and emergency management.