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ANSI Z358.1 Compliance: Check Yourself Out!

• Mar 01, 2007

BACK in the days when it was acceptable to factor loss of life into the planning for major public works projects such as dams and bridges, compliance to safety standards was an afterthought. As personal safety became more of a focus, those unsafe conditions gave way to increasingly stringent current regulations and deviation penalties. Today, there are very clearly defined operational safety protocols and preparation requirements to deal with inevitable accidents due to neglect or other circumstances.

undefined Compliance is not a once-a-year or once-a-month thing. It is an all-day, every-day requirement.

Availability of adequate first aid assets is a critical element ofthe plan for all significant businesses. And those assets are most often regulated by OSHA, using ANSI's and other standards and guidelines. The ANSI standard for emergency showers and eyewashes is ANSI Z358.1, which was last revised in 2004. In its current permutation, it is the clearest and most useful tool for preparing to meet most workplace incidents.

While this discussion does not attempt to interpret Z358.1, it will provide a checklist of sorts aimed at assisting readers in understanding some of the significant requirements included in the standard. We will provide a basic outline of some of the major elements that must be met.

It should be understood that compliance is not a once-a-year or once-a-month thing. Compliance is an all-day, every-day requirement. Accordingly, emergency showers and eyewashes are required to be activated weekly, with a more thorough evaluation on an annual basis. This requirement is established in Sections 4.6.2, 4.6.5, and others. Many companies today opt to have an outside, third-party inspection performed for them annually, which provides an added measure of credibility to the review process.

Beyond that, the following areas should be reviewed:

• Emergency showers, eyewashes, and combination showers/eyewashes must be accessible within 10 seconds, must be on the same level as the hazard, and the path of travel shall be free of obstructions (Sections 4.5.2, 5.4.2, 6.4.2, 7.4.2).
• Emergency shower, eyewash, and combination shower/eyewash stations should be designated by highly visible signage (Sections 4.2, 5.2, 6.2, 7.4.3) positioned so that the sign shall be visible in all areas served by that specific equipment.
• Control valves on emergency showers, eyewashes, and combination shower/eyewash equipment should be designed to enable them to be moved from "off" to "on" in one second or less and to remain open until intentionally closed (Sections 4.2, 5.2, 6.2, 7.2).
• Spray nozzle outlets on eyewashes and eye/face washes should be protected from airborne contaminants when idle. Whatever means is used to protect them should not require a separate motion (from equipment activation) to remove the protection for equipment use (Sections 5.1.3, 6.1.3).
• Plumbed and self-contained eyewash equipment must be capable of delivering flushing fluid to the eyes at a flow of not less than 1.5 liters per minute (.4 gpm) for the full, required, 15-minute irrigation cycle (Sections 5.1.6, 6.1.6).
• For eyewashes, a means must be provided to ensure a controlled flow of flushing fluid to both eyes simultaneously. (Section 5.1.1) With respect to eye/face washes, the standard includes both eyes and face (Section 6.1.6).
• There should be a minimum distance of 6 inches between the eyewash outlet nozzles and any adjacent obstruction, such as walls, etc. (Section 5.4.4).
• The proper height for eyewash or eye/face wash heads is between 33 inches and 45 inches above the floor (Section 5.4.4).
• Drench showers must deliver a minimum of 20 gpm flow (Section 4.1.4).
• The proper height for drench shower or combination drench shower and eyewash shower heads is between 82 inches and 96 inches above the floor (Section 4.1.2).
• Drench shower flow patterns should be a minimum of 20 inches wide at 60 inches above the floor (Section 4.1.5).
• There should be no barrier closer than 16 inches from the center point of the installed emergency drench shower or combination shower and eyewash (Section 4.1.5).
• Combination shower and eyewash equipment is subject to the same individual component requirements, even when those components are used simultaneously. That means, among other things, that flow and pattern requirements for the shower and eyewash remain in effect during simultaneous use. Sufficient pressure and volume of fluid to "drive" both features is necessary (Section 7.4.4).
• Combination shower and eyewash equipment must be capable of simultaneous use of the shower and eye or face wash by the same user (Section 7.4.4).
• Flushing fluid must be tepid, which by the standard, established guideline is between 60 degrees F and below 100 degrees F for the full 15-minute use cycle (Section 7.4.4).

Large Fines Are Common
There are obviously other requirements established by ANSI Z358.1, but these are the most commonly overlooked or not followed. Every month, there are published recaps of the OSHA violations processed and the fines levied against companies that neglect to live by the requirements. Fines are usually in the six-figure area! But aside from the potentially punitive regulatory assessments that are possible, there is the potential for negligence claims and litigation. The company that was fined $213,000 last October for, among other things, a "blocked eyewash" might have gotten off easy compared to having an employee become permanently blinded due to that negligence.

Then there is the whole issue of tepid water, our final checklist item above. The tepid water requirement has been in Z358.1 for some time now. Prior to 2004, it was left to interpretation as to what was the acceptable temperature range. In the 2004 revision, the standard was clarified to provide the specifics outlined above. Tepid water is essential to ensuring that an injured worker remains under the shower or submersed into an eyewash for the full 15-minute use cycle. Cutting short on the required time risks a less-than-complete removal of the hazardous material, as well as failure to adequately cool the area affected by, let's say, a chemical burn. Likewise, remaining in contact with the water supplied by most municipal authorities for that time can easily lead to hypothermia.

So the tepid water requirement is a solid one. However, it is estimated that the vast majority of multiple shower and/or eyewash installations in the United States still do not provide tepid water. Forget about OSHA violations for a minute; think about it from the standpoint of litigation by an employee after an accident. There is a frightening amount of risk still out there in which the ANSI standard could potentially be used as the proof for a negligence claim.

Today, providing emergency showers and eyewashes isn't enough. We need to monitor their condition and the areas around them. Access and useability are the keys. Is your equipment up to date? Are you providing tepid water? Check yourself out or ask for an impartial, third-party assessment.

This article appeared in the March 2007 issue of Occupational Health & Safety.

This article originally appeared in the March 2007 issue of Occupational Health & Safety.