Eye Protection Standards for Small Healthcare Practices (29 CFR § 1910.133(a))

Eye injuries are among the most common occupational hazards in healthcare, ranging from exposure to infectious fluids to chemical splashes. OSHA’s 29 CFR § 1910.133(a) establishes strict standards for eye and face protection, requiring employers to provide appropriate personal protective equipment (PPE) when hazards are present. For small healthcare practices, compliance ensures both staff safety and legal protection against penalties. Proper implementation reduces risk, protects patients indirectly, and strengthens the reputation of the practice as a safe and compliant facility.

In small healthcare practices, daily tasks such as drawing blood, handling disinfectants, or performing minor procedures present real risks to staff. Eye protection is often overlooked, yet it is critical under OSHA’s standards to safeguard employees. Section (29 CFR §1910.133(a)(1)) specifically mandates that employers provide suitable protection where hazards could cause injury to the eyes. For practices with limited resources, compliance may seem daunting, but failure to follow the rule can result in injuries, lost work time, and costly fines. This article provides a comprehensive guide to understanding and applying the standard in small healthcare settings.

Understanding Eye Protection Standards Under 29 CFR § 1910.133(a)

OSHA’s regulation 29 CFR § 1910.133(a) requires that employers ensure employees use appropriate eye or face protection when exposed to hazards such as:

• Flying particles from medical instruments or minor procedures.

• Liquid chemicals, acids, or disinfectants.

• Bloodborne pathogens and other infectious materials.

Employers must select PPE that meets or exceeds the standards of the American National Standards Institute (ANSI Z87.1) (29 CFR §1910.133(b)(1)(i)–(iii)). This ensures that eyewear is tested for impact resistance, splash protection, and optical clarity. Importantly, practices must document hazard assessments and ensure employees are trained in proper use, limitations, and care of protective eyewear. Understanding and applying this legal framework is essential to reducing risks and avoiding OSHA penalties.

The OCR’s Authority in Eye Protection Standards

Although OSHA regulates workplace safety, the Office for Civil Rights (OCR) enforces HIPAA and has overlapping authority when inadequate safety measures compromise patient privacy or safety. Examples include:

• If an exposure incident due to lack of eye protection results in contamination of patient care records, OCR may review the event.

• OCR investigations may be triggered by patient complaints regarding infection control breaches, which can involve failure to use or document PPE.

• During audits, OCR may examine whether safety failures indirectly compromise patient confidentiality or create unsafe care environments.

For small practices, this reinforces the importance of maintaining PPE compliance not only for staff safety but also for HIPAA-related oversight.

1. Conduct a Hazard Assessment
   Document every clinical activity that could pose an eye hazard, including chemical handling, patient procedures, and lab work.

2. Select Appropriate PPE
   Choose ANSI Z87.1-compliant goggles, face shields, or safety glasses, depending on the hazard identified.

3. Provide PPE at No Cost
   OSHA requires employers to furnish required PPE without cost to employees (29 CFR §1910.132(h))

4. Train Staff
   Ensure staff know when to wear PPE, how to properly fit it, how to maintain it, and its limitations.

5. Document Training
   Keep written records of all PPE training, including staff signatures and training dates.

6. Inspect and Maintain PPE
   Replace scratched, damaged, or contaminated eyewear immediately.

7. Prepare for OSHA Audits
   Maintain a binder with hazard assessments, training certifications, and PPE purchase records to show compliance readiness.

A small dermatology practice experienced a compliance failure when a staff member suffered a serious eye injury from accidental splashing of a chemical peel solution during a cosmetic procedure. The injured employee later reported that although gloves were routinely provided, protective goggles or face shields were not available in the treatment rooms. OSHA launched an investigation after receiving a formal complaint and quickly discovered that the practice had never completed a written hazard assessment to identify the risks associated with chemical peel solutions or other dermatologic treatments involving corrosive agents. Furthermore, the clinic could not produce any documentation showing that staff had been trained on the proper selection, use, and limitations of eye protection.

Citing violations under 29 CFR 1910.133(a), OSHA imposed fines totaling $7,500. In addition to the financial penalty, the clinic was required to implement immediate corrective actions, including conducting a full hazard assessment, purchasing ANSI-approved protective eyewear, and providing retraining for all employees with signed documentation. The incident also generated reputational damage, as word spread among patients and the local community that the clinic had failed to meet basic safety standards. Staff morale declined, with several employees openly questioning whether leadership prioritized patient outcomes over workplace safety.

By contrast, another dermatology clinic in the same region had taken a proactive approach. Leadership conducted annual hazard assessments that specifically evaluated chemical and procedural risks, ensuring that each treatment type had corresponding PPE requirements. The clinic stocked ANSI-approved goggles and face shields in every treatment room, making protective equipment both visible and easily accessible. Training on PPE use was incorporated into onboarding for new employees and reinforced with annual refresher sessions, each documented with attendance records and signed verifications. When OSHA inspectors later conducted an unannounced inspection after an unrelated complaint, the clinic was able to provide complete documentation immediately. Inspectors found no deficiencies and commended the clinic for its safety program.

This proactive approach not only avoided costly penalties but also strengthened staff confidence and patient trust. Employees reported feeling safer and more prepared, while patients took reassurance from visibly enforced safety protocols, which enhanced the clinic’s reputation as a professional and responsible provider.

• Failing to perform hazard assessments: Without written assessments, PPE selection cannot be justified.

• Using non-ANSI eyewear: Ordinary glasses or cheap goggles do not meet OSHA requirements.

• Inadequate training: PPE is ineffective if staff are unaware of proper usage.

• Poor maintenance: Damaged or dirty eyewear creates new hazards instead of preventing injuries.

Avoiding these mistakes ensures compliance while protecting staff and patients.

• Standardize PPE procurement to ensure all equipment meets ANSI standards.

• Store PPE in easily accessible, clearly marked stations.

• Post signage in high-risk areas reminding staff of required eye protection.

• Implement quarterly refresher courses to reinforce compliance.

• Use checklists during inspections to verify PPE availability and staff compliance.

These best practices make compliance more consistent and affordable for small practices.

A culture of compliance goes beyond rules. Leadership must model PPE use consistently, supervisors should monitor adherence during daily operations, and staff should feel empowered to report hazards or missing equipment. Integrating compliance into meetings, new employee orientation, and performance reviews ensures eye protection becomes a natural part of clinical routines. When staff view compliance as shared responsibility, safety outcomes improve across the practice.

Eye protection compliance under 29 CFR § 1910.133(a) is a legal and ethical requirement for small healthcare practices. By identifying hazards, providing ANSI-approved eyewear, training staff, and documenting compliance, practices can prevent injuries and avoid costly penalties.

Advisers

Small practices can benefit from affordable compliance tools that manage training schedules, store documentation, and provide self-audit checklists. Free OSHA resources, HHS infection control guidelines, and OCR’s HIPAA compliance materials offer practical support without financial burden. Combining these resources ensures compliance while keeping costs low, protecting staff and patients alike.

• 29 CFR § 1910.133 Eye and Face Protection

• Personal Protective Equipment Standards

• Healthcare Wide Hazards

• Compliance Resources for Healthcare Providers