The production and commercialization of lenses and Sunglasses
within the European Union is governed by Directives 89/686/EEC,
93/68/EEC, 93/95/EEC, 96/58/EEC since they have been classified
amongst the Personal Protective Equipment (PPE)
All the countries that are members of the European Union have
been obliged to accept such Directives into their own
legislation.
In Italy, the European Standards have been implemented by the
following Legislative Decrees:
D.L. 475/92 of 4-12-92 with which Directive 89/686/EEC has been
enforced.
D.L. 10/97 of 2-01-97 with which also the successive Directives
93/68/EEC, 93/95/EEC and 96/58/EEC have also been enforced.
The legislative decrees also define the responsibilities
regarding control, fines and juridicial consequences in the case
of non-compliance.
In order to help manufacturers in the definition and design of
PPEs, the European Union has appointed CEN to prepare a series of
harmonised technical standards that define test methods and
technical specifications assuring conformity with the essential
safety requirements defined by the Directives. This is the
obiective of standard EN 1836:1997. The standard attempted to
interpret the Directive's philosophy and its spirit.
As a result, they have the same objective: to guarantee that the
products freely circulating in the European Community are
"safe". This concept regarding safety must be
interpreted both in terms of the capacity to adequately carry out
their primary function of protection (in this case, protection of
the eyes from solar radiation) and in terms of not being
hazardous (for example, because they are excessively fragile or
limit vision).
Moreover, it must be assured that the user be informed on the
correct product use.
Consequently, the Directive and therefore the technical standard
place great attention on the filter, as a protective element,
while they impose a limited number of specifications for frames.
According to the legislator, sunglasses must be above all a safe
product and adequately protect against solar radiation.
Consequently, the essential requirement is the sun filter
(protective element), while the frame is simply considered as a
necessary accessory that allows the correct positioning of the
protective elements in front of the eyes.
Standard-Directive Comparison
Having said this, table 1 reports a comparison between the
essential safety requirements stated in Annex II of Directive
89/686/EEC and the paragraphs of standard EN 1836:1997.
Table 1
| Annex II of Directive 89/686/EEC | Standard EN 1836:1997 | |
| 1.0 | Adequate protection against risks | 1 Scope |
| 1.1 | Design principles | |
| 1.1.1 | Ergonomics | 5.1 General construction |
| 1.1.2 | Adequate protection levels | 4.1.1 Transmittance and filter categories |
| 1.2 | Innocuousness of PPE | |
| 1.2.1 | Absence of risks | 4.5 Robustness |
| 4.7 Ignition | ||
| 5.2 Mechanical requirements | ||
| 1.2.1.3 | Maximum permissible user impediment | 4.1.2.1 Uniformity of luminous transmittance |
| 4.2 Optical power of oculars | ||
| 4.3 Scattered light | ||
| 4.4 Material and surface quality | ||
| 1.3 | Comfort and efficiency | |
| 1.3.2 | Lightness and design strenght | 4.5 Robustness |
| 1.3.3 | Compatibility of different classes or types of PPE designed for simultaneous use. | - - |
| 1.4 | Information supplied by the manufacturer | 7 Information and labelling |
| 2 | Additional requirements common several classes or types of PPE | |
| 2.2 | PPE ‘enclosing’ the parts of the body to be protected | - - |
| 2.3 | Adequate field of vision | - - |
| 2.4 | PPE subject to ageing | - - |
| 2.9 | PPE incorporating components which can be adjusted or removed by the user | - - |
| 2.12 | PPE bearing one or more identification or recognition marks directly or indirectly relating to health and safety | 7 Information and labelling |
| 2.14 | Multi-risk PPE | - - |
| 3 | Additional requirements | |
| 3.9.1 | Non-ionizing radiation | 4.1 Transmittance requirements |
Analysis of the technical specifications subject of Standard
EN 1836:1997
The following paragraphs explain the essential points governed by
Standard EN 1836:1997.
Adequate protection from solar radiation (4.1.1;4.1.3)
This standard defines the minimum protection levels from UV
radiation and classifies filters according to the degree of
transmittance of visible light.
In order to give correct information to the consumer, the
standard additionally defines the methods of evaluating the
degree of protection from Blue light and infrared radiation,
without however setting minimum requirements.
Note: In order to guarantee a sufficient degree of
precision, the measurements of transmittance (UV protection,
transmittance of visible light etc.) have to be carried out using
a scanning spectrophotometer.
Optical characteristics that do not fatigue vision (4.2)
In this respect, the standard establishes two optical classes
according to the type of use, setting the limits for spherical,
astigmatic, prismatic powers and differences of prismatic
deviation between the right and the left lens of the sunglass.
With the intention of evaluating such parameters, the standard
also specifies the optical instruments that have to be used.
Note: The front focometers normally used in the ophthalmic
field are not suitable for the evaluation of solar filters and
can give incorrect results.
Filtering suitable for not causing hazards in common
situations of use (4.1.2.2)
Regarding the above, very precise specifications are required for
use when driving, which regard the ability to recognise road
signals, visibility in conditions of artificial lighting and
minimum level of transmittance.
Characteristics guaranteeing filter safety in terms of eye
health (4.5; 4.7)
In this respect, tests are required to make sure that filters are
not hazardous for the user. Especially in:
Manufacturing (4.1.2; 4.3; 4.4)
Requirements to be met are within the following:
Filtering power maintained in time (4.6)
An ageing test is required based on UV radiation overexposure.
Sufficient information for the correct use of the sunglasses
by the user (7).
The standard requires a series of minimum information simplified
with respect to what has been established by Directive
89/686/EEC. This has been done give the consumer a better
understanding of the correct sunglass use.
Finished glasses
Information to be given upon request
Unshaped and spare filters