Ready for Action

OSHA's language in some of the older standards seems quaint, but there should be nothing antiquated about your emergency eyewash and shower equipment.

• By Judie Smithers
• May 01, 2003

SOME safety equipment blends into the background until it is urgently needed. The only people who probably pay close attention to emergency eyewash and shower equipment are those who inspect it. Even these inspectors may not have done any recent re-evaluations to determine whether the equipment is adequate for your current needs.

Take some time for a closer look at the equipment you hope is never used.

Many OSHA Requirements
OSHA only has that one little rule about providing "suitable facilities for quick drenching or flushing" the eyes and body when workers may be exposed to "injurious corrosive materials," right? Not exactly.

OSHA's medical services and first aid rule, at 29 CFR 1910.151(c), is a general rule with wide application, but other standards have additional requirements. Consider how the following standards may apply in your workplace.

The dipping and coating operations rule sets emergency eyewash and shower requirements when "employees work with liquids that may burn, irritate, or otherwise harm their skin," at 1910.124(g).

The powered industrial trucks rule requires employers to provide facilities for flushing spilled electrolyte, at 1910.178(g)(2). OSHA's compliance directive, STD 1-8.2 Instruction on Eye Wash and Body Flushing Facilities in Storage Battery Charging and Maintenance Areas, notes that the degree of potential exposure to electrolytes is a factor in determining the need for emergency eyewash and shower equipment.

Under the standard for pulp, paper, and paperboard mills, employers must provide a "deluge shower and eye fountain" to "flush the skin and eyes to counteract lime or acid burns" as part of the requirements for chemical processes of making pulp, at 1910.261(g)(5). Again, at 1910.261(g)(18), "quick operating showers, bubblers, etc., shall be available for emergency use in case of caustic soda burns."

The textile standard's first aid requirements, at 1910.262(pp), require employers to provide "a copious and flowing supply of fresh, clean water" whenever acids or caustics are used.

Employees who have known contact with a carcinogen covered by OSHA's 13 carcinogens standard are "required to shower as soon as possible" under 1910.1003(d)(2)(iv); however, under 1910.1003(d)(2)(vi): "Emergency deluge showers and eyewash fountains supplied with running potable water shall be located near, within sight of, and on the same level with locations where a direct exposure to Ethyleneimine or beta-Propiolactone only would be most likely as a result of equipment failure or improper work practice."

Employers covered by OSHA's formaldehyde rule must provide, under 1910.1048(i)(3), "acceptable eyewash facilities within the immediate work area" if there is any possibility that an employee's eyes may be splashed with solutions containing 0.1 percent or greater formaldehyde.

Employers who use methylene chloride need to provide eyewash facilities within the immediate work area under the standard's hygiene facilities provisions at 1910.1052(i).

In addition, many of OSHA's chemical-related standards have non-mandatory substance data sheets that recommend flushing the eyes and skin as a first aid procedure, as do most commercially prepared Material Safety Data Sheets.

OSHA's language in some of these older standards seems quaint, but there should be nothing antiquated about your emergency eyewash and shower equipment. To get the cold, hard facts on installing, maintaining, and using emergency eyewash and shower equipment, turn to the American National Standard Institute's ANSI Z358.1 Emergency Eyewash and Shower Equipment standard for guidance.

The ANSI Standard
Although not adopted by OSHA, ANSI Z358.1 essentially sets the benchmark for good industrial practice. An OSHA letter of interpretation dated April 18, 2002, states: "ANSI Z358.1 provides detailed information regarding the installation and operation of emergency eyewash and shower equipment. OSHA, therefore, has often referred employers to ANSI Z358.1 as a source of guidance for protecting employees who may be exposed to injurious corrosive materials."

ANSI Z358.1 outlines minimum performance and use requirements for emergency showers, eyewash equipment, eye/face wash equipment, hand-held drench hoses, and combination shower and eyewash or eye/face wash equipment. The standard provides equipment manufacturers with detailed design parameters and performance testing procedures. Reputable equipment manufacturers ensure their products comply with the standard's specifications.

Just having equipment manufactured to ANSI Z358.1 does not mean you are protecting your employees, however. The on-site installation, maintenance, and use of the equipment are key to its effectiveness.

Installation Considerations
Under ANSI Z358.1, employees must be able to reach emergency showers and eyewash units in no more than 10 seconds. Where the hazard is from strong acids or caustics, eyewash equipment needs to be immediately adjacent to the hazard. When installing the equipment, keep in mind that an injured employee, especially someone with impaired vision, may not move at the same pace as a healthy individual.

The equipment must be located in well-lighted areas on the same level as the hazards, and the path to the equipment must kept clear of obstructions. The ANSI standard also requires each unit to be identified with a highly visible sign.

Per the ANSI standard, emergency showers must be able to provide at least 20 gallons (75.7 liters) per minute for 15 minutes. Eyewash equipment must provide at least 0.4 gallons (1.5 liters) per minute for 15 minutes. Take steps to ensure the equipment's water supply cannot be tampered with or accidentally shut off.

ANSI Z358.1 notes that equipment needs to be protected from freezing temperatures, and the temperature of the flushing fluid must be "tepid" (moderately warm or lukewarm). OSHA's instruction STD 1-8.2 states: "Eye wash equipment should provide copious low velocity flow of potable water at a suitable temperature, generally between 60 degrees F and 105 degrees F."

Specifications for drainage and waste disposal are not included in ANSI Z358.1. The equipment is to be installed according to the manufacturer's instructions, but also consider the hazards created by wastewater. Wet floors create a slipping hazard. Provide non-slip floor coatings or mats in areas that could become wet. Employers should consult with local wastewater authorities if there is a possibility that contaminated flushing fluid is hazardous.

All electrical outlets in wet areas should have ground-fault circuit-interrupters (GFCIs).

Personal eyewash units (hand-held bottles) can be used to support, but not in place of, plumbed or self-contained eyewash equipment that meets ANSI Z358.1. These units are meant to deliver immediate flushing until the person can get to a standard unit.

Consider the personal needs of the employees who use the equipment. It is a good practice to provide towels, privacy curtains, and a change of clothing.

Inspection and Maintenance
Regular inspections ensure the equipment is working properly. ANSI Z358.1 states that inspection and maintenance is to be done according to the manufacturer's instructions.

The ANSI standard notes that employers are to activate plumbed equipment weekly to verify it functions properly. The standard requires a more thorough annual inspection. Clean the equipment frequently instead of using any type of cover that would interfere with the unit's immediate use. You may want to keep records of inspections and maintenance work as evidence of your diligence in keeping the equipment ready for use.

Employee Involvement
Employers should not assume that employees know how to use the equipment.

While OSHA does not specifically require employers to train employees in how to use emergency showers and eyewash equipment, OSHA could interpret the general first aid training requirements at 1910.151(b) to apply to its use. OSHA CPL 2-2.53, Guidelines for First Aid Programs, says first aid training should cover chemical burns and the importance of flushing out the eyes.

Under the hazard communication standard's training requirements, at 1910.1200(h)(3)(iii), employers must train employees on the "specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used." Training in the use of emergency eyewash and shower equipment could be considered training in "emergency procedures" under the rule.

ANSI Z358.1 notes that equipment manufacturers are to provide operating instructions and that employees must be instructed in the equipment's location and proper use. This includes instructions to hold the eyelids open and roll the eyes to completely flush all surfaces of the eye and under the eyelids when using eyewash equipment. A flushing time of 15 minutes is often recommended. Use exercises or drills to show your employees how long they need to flush their eyes or skin in an emergency.

In addition to covering the manufacturer's instructions, remind employees of how they are to report injuries and hazards. Train employees on how to escort an injured co-worker to the emergency equipment and assist in its use. Discuss the potential severity of possible injuries and how prompt flushing can minimize the damage. People can hesitate to use emergency showers and eyewash equipment because they do not want to cause a scene or make a mess--training can address this reluctance.

Ongoing Strategies
OSHA and ANSI standards outline the minimum requirements, but employers can take additional steps to protect their employees:

• Evaluate changes in the workplace and move, upgrade, or add equipment as needed.
• Implement engineering controls to eliminate or minimize exposures.
• Use less-hazardous chemical substitutes whenever possible.
• Assess the need for employees to wear personal protective equipment and strictly enforce PPE policies.

The difficulties and expense of managing an effective emergency eyewash and shower equipment program are worth it if even one serious injury is prevented.

This article originally appeared in the May 2003 issue of Occupational Health & Safety.