Answer Library / PPE & First Aid OSHA letter · 2019-12-30

Does sunlight count as injurious light radiation requiring eye protection under OSHA?

Quick answer

No. OSHA clarified that "potentially injurious light radiation" in the shipyard eye protection standard means intense radiant energy such as that produced by electric arc welding and gas torch cutting, not ordinary sunlight (29 CFR 1915.153(a)(1)). Ordinary sunglasses also do not provide the shaded-lens protection welding requires.

A shipyard-related inquiry asked OSHA whether sunlight constitutes "potentially injurious light radiation" that would require eye protection under 29 CFR 1915.153(a)(1). OSHA answered in the negative: the term refers specifically to intense radiant energy or radiation, such as the radiation produced by electric arc welding and gas torch cutting operations.

For actual welding and cutting work, employees must receive appropriate protection through devices like welder's hoods, helmets, goggles, and safety spectacles fitted with shaded lenses that filter injurious radiant energy, in accordance with Table I-1 and 29 CFR 1915.153(a)(4). The consensus standards incorporated by 29 CFR 1915.153(b) require this protective eyewear to shield against UV radiation.

OSHA noted a practical nuance: while welding eyewear may incidentally protect against sunlight, those devices serve work-specific purposes rather than general sun protection. Conversely, ordinary sunglasses lack the radiation protection level required for welding operations, though sunglasses used for sun exposure on job sites should block appropriate UV percentages.

29 CFR 1915.152(f)(2)29 CFR 1915.152(f)(4)(ii)29 CFR 1915.15329 CFR 1915.153(a)(1)29 CFR 1915.153(a)(4)29 CFR 1915.153(b)
Source: OSHA Standard Interpretation letter, 2019-12-30 — read the official letter on osha.gov →
Interpretation letters explain how OSHA applies its rules to specific situations. Always verify current requirements — regulations and enforcement policies change.

Get answers like this in seconds — with the receipts

Canary AI answers safety & compliance questions from the actual standards and interpretation letters, cites the exact section, and drafts JHAs as clean PDFs. Free during the pilot.

Join the pilot →

Related answers

Is a small bottle of eyewash solution enough for bloodborne pathogen eye exposures?PPE & First Aid · OSHA letter 2020-11-06Do crane operators have to wear hard hats?PPE & First Aid · OSHA letter 2024-06-06Do dissolvable laundry bags count as impermeable containers for beryllium-contaminated clothing?PPE & First Aid · OSHA letter 2018-11-29