Prime Drivers for Emergency Showers & Eyewashes

While showers and eyewashes can't prevent exposure to hazardous materials, they can certainly minimize the effects when exposure to injurious corrosive materials happens.

In the plumbing world, emergency showers & eyewashes hold a unique position among the fittings and fixtures that you use daily. While many plumbing products are purchased for personal pleasure, a great shower, a functional toilet, or a sharp-looking faucet, emergency showers & eyewashes are used by employers to save eyes and lives. Furthermore, they are required by law! Failure by an end user to use these emergency products in certain situations can result not only in warnings and fines, but also in eye damage and chemical burns.

The primary driver for employers to provide showers & eyewashes is the Occupational Safety and Health Administration, or OSHA. OSHA’s overall mission is to "assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance."

Among the many areas of safety that OSHA covers, there is a section that specifically references the need for emergency shower & eyewash products: OSHA 29 CFR 1910.151 (c). In this section, OSHA requires the following of employers: "Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use."

This brief paragraph, which is buried inside the OSHA First Aid section, is the primary driver for employers to provide emergency showers and eyewashes in their facilities. It is not industry specific and covers all employees working with injurious corrosive materials. This includes employees as diverse as those working in food service with oven cleaners or disinfectants, to mechanics maintaining automotive batteries, to industrial workers using sulfuric and nitric acid.

While showers and eyewashes are not specifically referenced in the OSHA law, the intent is clear, and OSHA inspectors are constantly on the lookout to make sure that where hazardous materials are being used, there are proper drenching (drench showers) or flushing devices (eyewashes) available for employees to use. This is evidenced by the fact that in the past several years, inadequate "Eye and Body Flushing Facilities" has landed on the OSHA "Most Frequently Cited Serious Violations in General Industry" list.

If OSHA's focus on this area is not incentive enough to comply with this important safety requirement, then perhaps a few statistics will encourage compliance. OSHA has indicated that on average, more than 1,000 eye injuries occur in American workplaces every day and the financial burden of these injuries is costly—more than $300,000 per injury in lost production time, medical expenses, and workers' compensation. While not all are due to chemical burns, the National Institute for Occupational Safety and Health (NIOSH) and the Bureau of Labor Statistics indicate that roughly 10-15 percent are.

While OSHA provides the legal requirement for showers & eyewashes, the ISEA/ANSI Z358.1 Standard provides performance, safety, placement, and testing details for this equipment. The first thing to note is the name of the standard and inclusion of "ISEA," which refers to the International Safety Equipment Association. ISEA is an organization of manufacturers that are responsible for developing and maintaining this and other safety standards, hence the dual ISEA/ANSI name.

ISEA/ANSI Z358.1 is not a law, but rather a consensus standard, which means that it is developed by a group of interested parties. Once written or revised, it needs to be reviewed and approved by a consensus vote of interested industry parties. When I describe the standard in the industry, I refer to it as "Best practices by industry for industry."

While not a law, the ISEA/ANSI Z358.1 standard has significant credibility because it is often referenced and used by OSHA inspectors to ensure compliance to shower and eyewash requirements. Additionally the Z358.1 standard is recognized as the leading global standard for shower and eyewash implementation. If an end user chooses not to follow its recommendations, then they would be on their own in ensuring the safety of their employees.

A unique feature of the ANSI/ISEA Z358.1 Standard is that it has two components, one that provides guidelines to the manufacturer on the construction, operation, and certification of showers and eyewashes, and the other that provides guidance to end users on the proper installation and testing of equipment. These end user requirements include items such as distance from a hazard to the eyewash/shower, water temperature, and frequency of testing.

In contrast, most equipment standards simply specify the performance requirements of the item in question, not how it is used in the field. For instance, safety glasses need to meet the Z87.1 performance standard. However, once the glasses are sold, there is little guidance in the standard on how or where they should be used.

Requirements in the Z358.1 Standard
Manufacturers of emergency showers and eyewashes are required to design and build equipment to meet certain performance standards. This performance then needs to be verified by a third-party certification company that inspects and tests our equipment and reports publicly that the equipment meets the requirements of Z358.1. Typical certification companies include IAPMO, CSA, and SEI. When specifying shower and eyewash equipment, make sure that it has been certified by a third-party organization.

While there are numerous details on how to construct this equipment, here are some of the more important requirements:

All equipment needs to:

  • Be activated in 1 second or less and then allow hands-free operation.
  • Be constructed of materials that will not corrode.
  • The water flows need to be non-injurious to the eyes or body.
  • Operate continuously for 15 minutes.

Showers need to:

  • Provide 20 GPM of continuous flow.
  • Provide a water dispersion that will cover a person’s body fairly evenly.

Eye & eye/face washes need to:

  • Eyewashes flow at least .4 GPM.
  • Eye/Face washes flow at least 3.0 GPM.
  • Provide flushing fluid to both eyes simultaneously.
  • Nozzles and flushing fluid are protected from airborne contaminants.

Combination Stations need to:

  • Be capable of operating individually or simultaneously.

Measuring Travel Time to the Eyewash/Shower
The ANSI/ISEA Z358.1 Standard is unique in that it also provides guidance to end users on the proper installation and testing of equipment. As explained earlier, these requirements include distance from a hazard to the eyewash/shower, water temperature, and testing frequency.

The Z358.1 standard requires that showers and eyewashes are located within 10 seconds travel distance from a hazard. This distance is often judged by using a stopwatch, and it needs to take into consideration the potential victim’s emotional/physical state, the nature of the chemicals being used, and any potential obstacles between the hazard and the emergency shower or eyewash. Particularly corrosive chemicals or the presence of physical obstacles and obstructions may require multiple pieces of equipment or that their installation be immediately adjacent to the area(s) where the chemical is being used.

While in existing facilities it is fairly easy to measure 10 seconds with a stopwatch, engineers and architects who are designing facilities do not have this luxury; all that they have to work with are blueprints. To help these design professionals, the Z358.1 Standard suggests that 55 feet is a distance that most persons can travel in 10 seconds or less. The victim’s physical condition and potential obstacles must still be taken into consideration.

The Z358.1 standard further requires that the water temperature that is delivered to showers and eyewashes is tepid, which is defined as 60-100 degrees F. This temperature range provides a safe flushing fluid temperature that will allow a victim to use a shower or eyewash for the required 15 minutes without being so cold that he or she will leave the equipment prematurely or so hot that it will scald the eyes or body, causing additional harm. There is no mention in the standard on how to achieve tepid, and there is a wide variety of solutions available.

Several additional conditions need to be considered when positioning emergency equipment. The shower or eyewash should be on the same level as the hazard to eliminate trips and the need to climb up or down. Furthermore, doors are considered obstructions, and the equipment should be located on the same side as the hazard with which the employee is working. In limited cases where the hazard is not corrosive, one door is permitted, provided that it cannot be locked and opens in the same direction that a potential victim would travel in order to reach the shower or eyewash.

The final requirement for location is that the area is well lit and identified with a highly visible sign indicating the presence of a shower and/or eyewash.

While showers and eyewashes can't prevent exposure to hazardous materials, they can certainly minimize the effects when exposure to injurious corrosive materials happens. So perform a facility audit, identify where harmful chemicals are being used, and install the proper shower and eyewash equipment to help protect your employees and comply with the OSHA 1910.151 (c) law and the ANSI/ISEA Z358.1 Standard.

This article originally appeared in the July 2018 issue of Occupational Health & Safety.

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