Vision Conservation and Readiness

 Local VCR Program Requirements for Site Surveys and Hazard Assessments

Last Updated: October 28, 2019
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​OSHA requires the employer "to assess the workplace to determine if hazards are present, or likely to be present, which necessitate the use of PPE."

Whenever a hazard analysis of a worksite is necessary, a site survey is required to:

• Uncover unsafe acts/processes;

• Evaluate current safety measures;

• Determine the need for specific engineering, administrative or personal protection controls;

• Develop a good working relationship with the personnel and encourage safe practices; and to

                                                                                • Benchmark efforts to comply with regulatory standards.

According to OSHA 1910 Subpart I App B, the purpose of the survey is to identify sources of hazards to workers and co-workers.  Consideration should be given to the basic hazard categories:

  1. Sources of motion such as machinery or processes where any movement of tools, machine elements or particles could exist, or movement of personnel that could result in collision with stationary objects;
  2. Sources of high temperatures that could result in burns, eye injuries or ignition of protective equipment;
  3. Types of chemical exposures;
  4.  Sources of harmful dust;
  5. Sources of light radiation such as welding, brazing, cutting, furnaces, heat treating, high intensity lights...
  6.  Sources of falling objects or potential for dropping objects;
  7.  The layout of workplace and location of co-workers; and
  8.  Any electrical hazards.

In addition, injury/accident data should be reviewed to help identify problem areas.

Even though the timeline is not specified in OSHA 1910, OSHA 1960, Basic Program for Federal Employees OSHA, Paragraph 1960.25(c) states:

"All areas and operations of each workplace, including office operations, shall be inspected at least annually. More frequent inspections shall be conducted in all workplaces where there is an increased risk of accident, injury, or illness due to the nature of the work performed. Sufficient unannounced inspections and unannounced follow-up inspections should be conducted by the agency to ensure the identification and abatement of hazardous conditions."

DoD 6055.01: Occupational Safety and Health Program confirms this requirement for annual inspections and the requirement for more frequent inspections for special emphasis programs, for changing operations or organizations, or for other events that indicate increased risk.  Also, be aware that changes of mission, new processes or processes not previously assessed, new operations and new equipment must be assessed within 3 months of being identified or for before the process has been performed more than three times, whichever is longer and identify associated risks and hazards  (including eye hazards).

The types of surveys include:

    - Those that are required as stated previously such as annual surveys or those due to changes of mission, process or equipment;

    - Problem oriented surveys due to a past history of injuries or damage or due to past failures during assessments; and

    - Familiarization surveys which enable you to understand the organization and programs, the issues and needs of the site, to develop and assist in maintaining a positive working relationship and to meet management and the workers.   If you have never done a worksite survey, it is recommended that you go your first time with someone familiar with the site such as Industrial Hygiene or Safety personnel.

Understanding all aspects of performing a site survey and a hazard assessment are beyond the scope of this page.  The rest will apply to the components relevant to vision, visual performance and eye safety.   As always, if you have any questions, feel free to CONTACT US.


​When performing a site survey, whether it is an assessment of the entire worksite or you have been requested to evaluate a particular task, piece of machinery or process, with an emphasis on vision conservation, there are two considerations:

  1.  Ocular hazard analysis:  Preventing injuries should always be the top priority in all assessments.  You want to evaluate the current safety measures in place for compliance with regulatory standards and determine if there are any unsafe acts or processes which necessitate the need for additional specific engineering, administrative or personal protection controls.  Remember that it is important that you evaluate sites while the workers are actually working and not on break or between shifts.  The steps in this analysis include:
    1.  Identify the eye safety issues
      1. Identify the characteristics of the workers
        1. Are there any job specific vision requirements in regulations?
        2. Are there any occupational vision requirements?
      2. Ask specific eye hazard/risk based questions
        1. Are the engineering controls in place where possible and are they adequate?
        2. Are the administrative controls in place and are they adequate?
        3. Is the PPE being used appropriate for the mission?  Is it in good working condition and readily available?
        4. Are the eyewash/shower stations appropriately located and maintained?  Make certain to test them just to be certain.  If necessary, bring a mop or bucket.
      3. Evaluate controls that are currently in place and determine if they are being complied with.  For example, if there is a sign that states that eye protection is required, are all personnel in that area wearing their eye protection?  Also, are the workers wearing the appropriate eye protection and PPE for that specific task?
      4. Be alert for all hazards and conditions that may require additional controls or elimination.
        1. Determine why the condition exists.
        2. Consider all options for reducing the risk for eye injuries.
      5. Consider other environmental factors such as UV, IR, microwave, lasers...
      6. Review the list of chemicals utilized and the Safety Data Sheets for them to make certain that all requirements are being met.
  2.  Visual performance analysis:  It is recommended that a task assessment for each process be undertaken at least once for each type of task.  Understanding the visual demands of performing a task and providing recommendations on how to make the worker not only safer, but more effective and efficient as well can also be of benefit.  In addition to recommending PPE and engineering controls such as machine guarding to eliminate the potential for hazards whenever feasible, an assessment should also include evaluating the visual demands of a task such as illumination, possible vision requirements, and ergonomic issues created by performance of the task repetitively over an entire work day.  Normally, vision evaluations are conducted to ensure the minimum level of functioning necessary to accomplish the task but can also be used to assist the worker in optimizing their performance.  For each task:
    1. Determine the visual tasks required in each step of the process; and
    2. Understand the visual detail involved in performing the task.  For example, does the task require a certain level of acuity such as being able to read a specific item correctly or being able to differentiate between a number of colors/
    3. Factors include:
      1. Lighting - Poor lighting can increase the need for greater levels of concentration on a step in the process which increases fatigue over a work day and can result in increased risks for injury and poor quality production.
        1. Assess the quantity and quality of the light both without and with the worker in place (The worker may cast shadows on the task at hand).
        2. Look for glare and/or shadows.
        3. Light levels should be compared to standards while remembering that personal preference is also important as long as it does not interfere with task performance.
        4. Is the lighting adequate for the tasks?
          1. Is the current light systems in place the appropriate type and have proper color rendering when necessary?  When differentiating colors is critical to the task such as wiring for example, having the proper types of lighting that does not alter the worker's color perception becomes more important.
          2. It the illumination relatively uniform across the task area?
          3. Is supplemental/task lighting necessary and, if so, available?
    4. Vision requirements - Even if it is not mentioned in a position description (PD), does the task currently being assessed create demands that necessitate the need for certain levels of visual acuity, color vision or depth perception?  And, if so, does this requirement necessitate the need for development of a new job standard for that job?
      1.  The first step in performing a vision assessment is to take an overall look at the worksite and determine if it is designed properly and if the worker has the vision skills necessary to perform the task.  Poor design of the work area can reduce performance and should consider proper lighting and proper contrast as discussed previously, working distances and the worker's visual skills necessary to perform the task including being able to adequately see and the working distance and to be able to exit a site if necessary, the ability to perceive differences in colors, and the ability to perceive differences in distances.  Each of these requirements are only necessary to meet the specific task so can be different depending on what that task is.  For example, an electrician usually will require better color vision than other workers even if both state that they require "Normal color vision" in the respective PDs.  Items to consider include:
        1. Visual acuity - Assess the ability to see to do the task.  Four factors impact the visibility of a task which can impact the performance of a task.
          1. The worker's ability to see the task at hand.
          2. The size of the items being worked on - Performance is best if the item is 20/80 or greater in size for most tasks.  If the object is smaller you may want to consider a VA standard.
          3. Contrast - The greater, the better.
          4. Viewing time - Things that are more difficult to see require a longer viewing time and are more fatiguing.
        2. Color Vision - Assess the requirement for not only having color vision but also what level of fine color perception is necessary.
          1. Higher levels of discrimination may require more sophisticated screening tools such as the Munsell 100 Hue Test or the new Computer Color Vision tests.
          2. If necessary, do a functional color vision discrimination test such as having an electrician differentiate colored wires in a test situation.
        3. Depth Perception - Assess the need for precise judgement of relative depth.  Remember that monocular cues are adequate for most tasks so determine the true need for binocular vision based upon:
          • The safety consequences of an error
          • The need for speed and/or accuracy                                                                                                                      Examples of jobs which you should consider a binocular vision standard include forklift and crane operators.
        4. Visual Field - Assess the need to be able to see the surrounding area while performing a task.  This is primarily a safety issue but could also play a factor in detail work.  Items to consider include:
          1. Do they need peripheral vision to be safe?
          2. Assess whether the worker's alternate methods of performing the task are sufficient.
    5. Ergonomic considerations -  As defined on the APHC Ergonomic webpage "Ergonomics is defined as fitting the workplace to the worker."   Take a look at the overall layout of a workplace from an ergonomic perspective.  The design of the worksite and the vision requirements over time can cause issues for the worker later in the day.  For example, a task that requires a worker who wears bifocals to look at items up close that are above their head can cause neck fatigue over time.  Simply lowering the item, raising the worker or recommending specialized glasses with an additional reading portion at the top of the lenses could make the worker a lot more comfortable.  For additional guidance, information, the APHC Ergonomics Program offers subject matter expertise in reduction and prevention of work-related musculoskeletal injuries in a variety of settings such as industrial, office, laboratory and healthcare settings and provides installation-level ergonomic services, training and consultation.  For additional information on ergonomics, go to the Ergonomics webpages.
  3. Other considerations:
    1. Review injury reports and Workman's Comp data to determine if there is a history of eye related types of injuries.
    2. Review literature to determine if the process has been evaluated elsewhere and potential solutions are already being recommended.
    3. If the process is not new, ask current experienced workers and supervisors what steps of the task give them the most difficulty.  They may offer solutions that no one else has considered.
    4. Review any pertinent Safety Data Sheets if the work involves the use of chemicals.
  4. After the site visit:
    1. Provide verbal and written feedback to the supervisors.
    2. Your report should:
      1. Evaluate the findings
      2. Identify potential eye hazards
      3. Perform a risk evaluation when evaluate new processes or processes not evaluated before
      4. Identify areas/actions that can be improved
      5. Determine and then propose a corrective course of action for remediation and set a timeline for task completion.
      6. Schedule subsequent meetings to evaluate progress.
  5. Finally, as always, if you have questions regarding eye related findings, always feel free to CONTACT US.