Foundations of Eyewash/Safety Shower Protection
Do whatever is needed to ensure a clear pathway to the eyewash/shower unit. No stacks of junk, excess storage, or trash bins should interfere.
Eyewash and safety shower emergency assistance is at hand. Your safety program may have it all -- the latest in PPE, new and improved chemicals, storage and removal inside in a beautiful facility. What about all of the emergency assistance and comprehensive eye and face protection?
More than just first aid kits or calling the rescue squad, safety showers, eyewashes, and drench hoses and among the most important items, yet they stay quietly in the background. These emergency equipment items are truly the unseen heroes of exposure and are not given the value they deserve.
I think of screams, disfiguring facial burns, blindness, ulcers, scarring, and blisters and know that this is more than a regular first aid kit can handle! Do your employees know what to do in such a crisis? What about your management? Are processes in place to take care of the injured employee immediately, transport the individual to the hospital, and back up his or her lost work time by way of a trained replacement? Can you explain to upper management why everything you thought was in place failed?
Consider the costs involved. Installing a simple plumbed eyewash or combination eyewash/shower can save countless dollars in lost work time, physical injuries, OSHA citations, insurance costs, and training temporary or replacement employees. Another hidden cost not usually considered is that of your time as safety chief, investigating and resolving all of the associated problems.
More Than Just a Code
The eyewash and safety shower program is one of the most under-utilized, overlooked, and abused through misuse and mismanagement that we must maintain. This should never be a "footnote" or afterthought program, but instead be front and center and regularly upgraded, as needed. Diligent care and continuous maintenance and follow up are required for the life of the program elements.
Admittedly, most safety professionals are just a little cavalier about eyewash and safety showers. Many see them as a necessary evil and give courtesy time to the program development and training elements.
However, anyone who has ever needed emergency care from an eyewash or safety shower will be a true zealot -- every moment spent on the program and long-term care pays for the safety of area employees and reduces liability tremendously for the company. I remember well the day I was doused with gasoline. All embarrassment goes out the window when it is you hurting. I am a true advocate of eyewashes and safety showers. Read the codes, then do what is right for your employees.
Most industries, from heavy industry to medical technology, have need of an eyewash/safety shower program. Consider your production and your hazard assessment.
One quick look at your facility's hazard assessment and injury log will reveal many facts; the sad news is all of those "near misses" you never hear about. Buck up and realize that you have ignored the need for a consolidated effort and start trying to work through this issue, thus helping to reduce the potential for injuries and the seriousness of injuries that requiring the use of eyewash and emergency showers.
Do you know the regulations, including 29 CFR 1910.151(c)? Check out www.osha.gov for targeted information and some great training guides. Other sources include those companies involved in eyewash and shower development and distributors, many of which have outstanding resource pages for public use. You also can call technical experts at most of the big companies.
As a seasoned safety professional, I am a strong believer in having appropriate eyewash/safety showers on site and knowing where they are needed and who needs to be trained on them. A substantial program can be achieved with minimal effort and some aggravation. Serious disfiguring injuries are often preventable with some planning, training, and good management oversight, along with a simply operated eyewash/shower station that employees actually know how to use.
You and your managers know the hazardous locations of the company where the greatest potential for corrosive exposure injuries is present or even have occurred, and thus the most serious need for eyewash/safety shower exists. Keep in mind, when it comes to corrosives and skin, corrosives always win! Are the injuries preventable? Absolutely. But so often the employee does not wear the PPE, mistakes or stupid decisions are made, someone trips or slips, there's horseplay . . . and the injury occurs. How do you make a real change in the program? Following are a few items to include next time your facility reviews programs related to eyewash/safety showers. (By the way, many of these exist, including first aid, HazCom, PPE, protective apparel, fire, and more -- think of anything that results in burning, scalding, or corrosive injury that is destructive, possibly including your compounding/administration of some medical drugs, such as chemo items.)
- Emergency eyewashes should be placed in all hazardous areas. First aid instructions and supplies should be posted close by. Everyone must know where the closest eyewash station is and how to get there with restricted vision. Don’t forget employees must know how to get help, because time matters in an emergency.
- Advise all department managers of the eyewash/safety shower relationship and tie their bonus or pay to the upkeep and maintenance of the equipment. You will be amazed at how suddenly the equipment is no longer blocked and is tested weekly and kept clean. It’s simply amazing how that works!
- Educate all employees on the specifics of the eyewash/safety shower equipment, locations within the facility, why it is there, how to use it, and that it is OK to use it. Often employees are afraid to touch the eyewash station or to report any injury related to it. Cover this in all needed languages.
- Implement real policies for selection, implementation, testing, annual testing, training, and replacement of the equipment. Devise a budget and selection process and then actually use it. Even more important is guidelines through human resources or other management in the event an employee does not use these protective devices or does something to disable it by turning off the water supply, blocking it, gluing the caps on, etc. We all have clever employees who are angry, vengeful, or think such things are humorous. Deal harshly with them. Failure to comply with policy or other such protective measures will cause injuries to be worse and recovery to be delayed. Make sure you follow up with such mischief and document toward termination! For some offenses where someone else will be injured (such as turning off the water supply), immediate termination will be necessary. Harsh, you say? I disagree; it's necessary to protect the other employees. I personally have no patience or sympathy for disabling a workable eyewash station, yet it happens more often than you may realize because no bell or alarm sounds, no lights flash. An eyewash/shower station that works properly is silent and waiting for the emergency to come to it. Disabling one is exactly like chaining a fire exit, in my opinion. It is life threatening in an emergency situation.
- Make sure there is a fully integrated weekly testing and documentation system in place. If you have clever employees who tear down the signs/tags, keep a log, too. Ensure weekly testing is done as required and that the tests are real -- not just activation, but a real flow of water. Too often, I see eyewashes tested by "slapping" on and off the water supply. One second is not enough. Teach your employees how to test it correctly and why it is important.
- Blocking. You may have lines on the floor. Do whatever is needed to ensure a clear pathway to the eyewash/shower unit. No stacks of junk, excess storage, or trash bins should interfere. Have the sign in place.
- Water temperature. I see eyewashes that have water hot enough to "pick chickens," it is so scalding. Before installing the units, test your water temperature and reduce it to the allowed temperature. Install eyewash equipment that tempers the water if necessary.
- I also have seen eyewash stations used for weird purposes. Thawing frozen bags of shrimp under a steady stream of water comes to mind, as does using the bowl as a planter. Do you know the condition of your stations?
- For all of those "little faucet style" eyewash stations that supervisors love to purchase without telling anyone: Train the employees how to use them, what the limitations are, and why this piece of equipment is there. Make sure the department did not buy/install themselves and make darn sure it is on the schedule for testing and follow it closely. These items serve a valuable purpose at a very reasonable price for limited exposures. However they are not a true substitute for a full-sized, stand-alone unit. Evaluate carefully, call for professional assistance, and you will have an answer within minutes. Save your documentation and post the needed reminder training item for correct activation. It matters.
- Have first aid that works within reach. Design your first aid kits with a need for large-scale injury/burns/chemical exposure. You already have to check the eyewash weekly, so it is ideal to have first aid close by and to keep a watch on it as well. You want high visibility for this program. Use it for the purpose intended to assist in an injury. The money you save is worker's comp benefits, and possibly your salary.
- Are those emergency call numbers posted? Are they current? Does the phone work? (Yes, it does bear repeating, safety means redundancy. Emergency preparedness means planning for the worst.)
Do your employees really know what the hazards are? Explain, train, document, and reassess. Set up the work area correctly, clearly label all eyewash/shower units, and show employees how to use the system. Tell everyone the way to test them and when to call for maintenance. Regularly educate all employees on their work environment and the hazards through whatever means it takes to get the message to them: Posters, handouts, group inspections, and committee meetings all work well. You know your workplace, use what will work and keep it going. The need to boost awareness never ends because you have employee turnover.
Avoiding OSHA's Fines
This is by far the hardest thing to keep going. Update your program as hazards change and increase or decrease. Evaluate your chemicals and change out to safer ones where possible. Label or number every eyewash/shower station so you can keep up with them.
After all, a dusty, untested, blocked eyewash station observed during an OSHA inspection can mean pretty hefty fines. This is a huge preventable liability that can be controlled with a little planning right now.
In the greater scheme of safety programs, eyewash units and safety showers are often merged and overlooked for more flashy, more interesting programs. But for safety professionals, there are few static pieces of safety equipment more important if they are located in an area where they’re needed. Use common sense and simple planning skills. Active awareness and a good maintenance system and schedule will help advance your program and will reduce the severity of an injury if one occurs.
Not having a needed eyewash station that results in injury is just as negligent as having one that is not usable during a crisis event. And as safety, the responsibility and liability lies at your door. It is a tough program to keep moving, but there are things you can do that are low cost or will pay for themselves in the long run. It is worth every consideration, the nagging of supervisors -- and, in my case, even hauling the bucket myself to test them -- to prevent injuries at the workplace, which is part of the compassionate service of professional safety.
This article originally appeared in the May 2013 issue of Occupational Health & Safety.