IMHO, the wording in the Z133.1 3.4.1 is often overlooked.
You could very well argue the fact that many facets of our work poses risk of injury to the face; therefore, a face shield, if designed to reduce that risk, SHALL be worn or at least be on the helmet to be implemented at a moment's notice.
The ANSI Zs say "face protection" rather than the more limiting term of "face shield". I would think this is due to different aspects of work requiring different configurations of the protection. The fact that they don't say "shield" specifically, I would not take as an out for not having it listed as a PPE. My vote, therefore, is a face shield is a PPE.
I confess to not having read the Z87.1 so am not sure if they simply control the design and construction, labeling products that meet said criteria or also define the situations where they are supposed to be implemented. (My belief has been the former.)
http://www.visionrx.com/library/enc/enc_ansi.asp
"The ANSI Z87.1 standard sets forth requirements for the design, construction, testing, and use of eye protection devices, including standards for impact and penetration resistance. All safety glasses, goggles, and face shields used by employees under OSHA jurisdiction must meet the ANSI Z87.1 standard. The eyewear standard includes the following minimum requirements:
Provide adequate protection against the hazards for which they are designed
Be reasonably comfortable
Fit securely, without interfering with movement or vision
Be capable of being disinfected if necessary, and be easy to clean
Be durable
Fit over, or incorporate, prescription eyewear"
OSHA states "when necessary". There are circumstances or jobs that simply may not need or require a face shield; the eyes, being so very delicate can be injured by such a wide variety of situations and circumstances everyone has simply said "SHALL" on the eye protection.
The above quote also refers to "under OSHA jurisdiction"...well, there is another cop out for you. Many tree care companies fly under the radar of OSHA due to few employees. Personally, we do not take the stance that since we do not have to answer to OSHA, this allows us to take foolish risks. Many of these are common sense precautions.
So, STR, I believe your co-workers could each present a very strong debate for either side. FWIW, with the wording of 3.4.1, I would be hard to argue against the mandate to have face shields on every helmet in our industry. And if I had employees, helmets would all be equipped with face shields, as ours are. The convenience factor of being able to flip them up and out of the way, or immediately down again, there really isn't any excuse NOT to have them.
Sylvia