HPPOS-162 PDR-9111220148

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