United States Nuclear Regulatory Commission - Protecting People and the Environment

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: " 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

Page Last Reviewed/Updated Thursday, March 29, 2012