U.S. Nuclear Regulatory Commission
Use of Contact Lenses with Respirators
HPPOS-162 PDR-9111220148
Title: Use of Contact Lenses with Respirators
See the memorandum from F. J. Congel and R. E. Cunningham
to M. R. Knapp (and others) dated June 5, 1989. Contact
lenses may be worn will full face respirators under
specified conditions. This permission is a policy change.
a. Lawrence Livermore National Laboratory report of
August 16, 1985 (DE86001775, UCRL-53653) by R. A. da Rosa
and C. Weaver, "Is It Safe to Wear Contact Lenses with a
Full-Facepiece Respirator?"
b. U.S. Department of Energy, Memorandum from M. L.
Walker dated September 23, 1986, Subject: Amendment of the
Occupational Safety and Health Administration (OSHA)
Prohibition on Wearing Contact Lenses in Contaminated
Atmospheres with Full-Face Respirators.
c. U.S. Department of Labor, Occupational Safety and
Health Administration, Memorandum from T. Shepick dated
February 8, 1988, Subject: Contact Lenses Used with
Respirators (29 CFR 1910.34 (e) (5) (ii)).
d. Draft ANSI Z88.2-1989, American National Standard
Practices for Respiratory Protection.
References (a) and (b) accompanied the June 3, 1986
memorandum from R. L. Baer to the Regional Branch Chiefs of
the Emergency Preparedness and Radiological Protection of
the Division of Radiation Safety and Safeguards. These
references shed new light on the NRC policy on the use of
prescriptive lenses with respirators. As referenced in RG
8.15 and stated in NUREG-0041, the policy states: "Contact
lenses shall not be worn with full face respirators. These
devices present a distinct hazard to the individual 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
respirator 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 contaminated area."
On the basis of references (a) and (b), the June 3, 1986
memorandum contemplated a policy change that would permit
NRC licensees to use contact lenses with respirators.
However, at the time, OSHA prohibited the use of contact
lenses with respirators in nonradioactive environments.
The NRC staff postponed the contemplated policy change
rather than implementing different policies and regulations
for radioactive and nonradioactive environments.
Subsequently, OSHA revisited this subject.
Reference (c) modified OSHA enforcement procedures so that,
among others, violations involving 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 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
Regulatory Research has budgeted for comprehensive
revisions of 10 CFR Part 20 and RG 8.15. These revisions
will incorporate updated standards including those
developed by ANSI Committee Z88.2. Specifically, reference
(d) states: "6.5.3.3. Use of contact 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 staff
position is changed to permit the use of contact lenses
with respirators in accordance with the above citation from
ANSI Z88.2-1989.
Regulatory references: Regulatory Guide 8.15
Subject codes: 5.6, 8.10, 12.19
Applicability: All
