A checklist for compliance
June 8, 2009
Workplace safety has seen great improvements over the past several decades, due at least in part to regulatory pressures that define acceptable limits for risks and establish safeguards and emergency measures in the event of an incident. Integral to these advancements is the current state-of-the-art in emergency showers and eyewashes. Manufacturers have come a long way in designing better and better ways of minimizing the collateral damage associated with in-plant injuries.
The ANSI standard that guides functional, placement and maintenance requirements for emergency showers and eyewashes is ANSI Z358.1, which was last revised in 2004. In its current form, it is the clearest and most useful tool for preparing to meet most workplace spill, splash and blown particulate incidents.
While this discussion will not attempt to interpret Z358.1, it will provide a checklist aimed at assisting readers in understanding some of the significant requirements included in the standard.
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 ten 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" between the eyewash outlet nozzles and any adjacent obstruction, such as walls, etc. (Section 5.4.4)
- The proper heights for eyewash or eye/ face wash heads is between 33" and 45" above the floor. (Section 5.4.4)
- Drench showers must deliver a minimum of 20gpm flow. (Section 4.1.4)
- The proper height for drench shower or combination drench shower and eyewash shower heads is between 82" and 96" above the floor. (Section 4.1.2)
- Drench shower flow patterns should be a minimum of 20" wide at 60" above the floor. (Section 4.1.5)
- There should be no barrier closer than 16" 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 60ºF and below 100ºF for the full 15-minute use cycle. (Section 7.4.4)
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 who neglect to live by the requirements. Fines are usually in the six-figure area! But, aside from the potential punitive regulatory assessments that are possible, there is the potential for negligence claims and litigation. For example, the company that was fined $213,000 a while back for, among other things, a “blocked eyewash” might have gotten off easy compared to having an employee become permanently blinded due to that negligence.
Tepid water is essential
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 assuring that an injured worker remain under the shower or submersed into an eyewash for the required 15-minute use cycle. Cutting short on the required time risks 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 U.S. still do not provide tepid water.
Today, simply providing emergency showers and eyewashes isn’t enough. We need to monitor their condition and the areas surrounding each shower and/or eyewash installation. And, importantly, we need to stay current with the state-ofthe- art in product features and designs. Access, useability and quality of care 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.