Lessons from the case files
Eyewash/shower questions answered by OSHA
Location, location, location
When a worker in California fell into a process tank of nickel acetate heated to 180 degrees1, the closest emergency deluge shower was on the opposite side of the process tanks. His co-workers pulled him from the tank and immediately hosed him down with de-ionized water but they did not use an emergency shower because it was too far from where the accident occurred. Getting the injured man to it would have required guiding him to the end of the catwalk, down some stairs, then around the processing tanks to reach it. The man ultimately died from extensive thermo chemical burns.
“Had an emergency deluge shower been located on the same side of the process tanks as the catwalk, the employees performing the rescue would have been more prone to use it over the rinse hose, possibly saving the decedent’s life,” concluded state investigators.1
ANSI Standard Z358.1-20092 specifies that the shower, eyewash or combination unit should be no more than ten seconds away (generally no farther than 55 feet), with no obstructions between the unit and the hazard location.
What about water?
Employers may think that it is sufficient to have emergency eyewash and shower units that are supplied with water, but there are some additional considerations that should be taken into account.
A NIOSH health hazard evaluation (HHE) of a Maine workplace found that the mill water supply used in eyewashes and showers was not tested for adherence to the federal drinking water standards.3
OSHA subsequently noted the potential for chemical contamination of the mill water system when paper coating contaminated it, resulting in the discharge of a white, milky substance that consisted of clays, starch and biocide. The company was cited for failing to provide emergency eyewash and shower facilities with water meeting the requirements of potable water.
On another water-related subject: do OSHA inspectors cite facilities for not supplying tempered water to an emergency eyewash and shower? An agency letter of interpretation in response to that question4 noted that its 29 CFR 1910.151(c) standard makes the employer responsible for assessing “the particular conditions related to the eyewash/shower unit, such as water temperature, to ensure that the eyewash/shower unit provides suitable protection against caustic chemicals/materials to which employees may be exposed.”4
ANSI Standard Z358.1-2009 specifies that emergency showers must provide a continuous flow of 20 gallons-per-minute of 60 to 100 degree (Fahrenheit) water for 15 minutes in order to properly irrigate the affected tissue.
However, subjecting an injured person to a 60 degree shower for 15 minutes could significantly increase his or her discomfort. Additionally, the average temperature of the outer surface of the human eyeball is about 87 degrees. For these reasons, some manufacturers of tempered water systems consider 85 degrees the optimum temperature for eyewash and emergency showers.
If your existing water supply is unable to deliver water at the necessary temperature and flow level for the required length of time, a tempered water system might be the right choice for your workplace. These systems may be self-contained with gravity or air driven properties. Tempered water systems can also be used with an existing potable water source, then be heated using steam or electrical power.
When’s the last time you checked?
Eyewash stations and emergency showers located in industrial environments may be exposed to elements that could interfere with their ability to function effectively. That was the case in a drum refurbishing plant in Indiana, where NIOSH inspectors found that eyewash stations in the regrind department had no protective covers over the nozzles, which could lead to debris blocking the flow of water.
“We observed unbalanced water spray from the nozzles at the eyewash station in the poly wash department by the hydraulic pump and at other eyewash stations in the plant,” noted the inspectors.6
The company was advised to add protective covers to the nozzles of eyewash stations and ensure an evenly distributed flow of water between nozzles for all eyewash stations. NIOSH also recommended that eyewash stations be inspected and tested monthly and that the testing be documented — measures which should be followed in many workplaces. It should also be noted that the use of covers for the eyewash heads not only protects from debris that could cause the water to flow improperly, it can also prevent contamination of the water itself.
Play it safe
Does your workplace need eyewash stations and emergency showers if the hazardous chemicals your employees deal with are in sealed containers?
A Wisconsin company’s query to OSHA on that subject highlights the need for those most familiar with the workplace and its processes to determine whether or not employees may be exposed to corrosives.
The company in question produces concentrated products that are corrosive to the eyes and skin but which are packaged in sealed dispensing containers connected to a water source, allowing the user to automatically generate the recommended use dilution. Although some of the concentrated products are corrosive to the eyes and skin, the dilutions that are generated are no more than irritants.
OSHA’s answer: if exposure isn’t possible (if the caustic materials are in sealed containers that will not be opened, or in building piping, for example), then an eyewash or emergency shower is not necessary. However, if the building piping containing caustic materials has a spigot or tap from which the contents are to be sampled or withdrawn by employees, an eyewash must be located near where this task will be performed.7
A compliance checklist
ANSI 358.1-1990 provides details with respect to the location, installation, nature and maintenance of eyewash and shower equipment.8
Beyond that, the severity of potential injuries, time of exposure, and number of employees who may be exposed must all be taken into account.
1 California FACE Report #00CA002 www.cdc.gov/niosh/face/stateface/ca/00ca002.html
3 HETA 90-375-2334 7/1993 www.cdc.gov/niosh/hhe/reports/pdfs/1990-0375-2334.pdf
4 OSHA letter of interpretation 4/18/2002 www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24119
5 HETA 94-0376-2576 www.cdc.gov/niosh/hhe/reports/pdfs/1994-0376-2576.pdf
6 Evaluation of Chemical Hazards and Noise Exposures at a Drum Refurbishing Plant www.cdc.gov/niosh/hhe/reports/pdfs/2010-0031-3130.pdf
7 OSHA letter of interpretation 6/1/2009 www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27089
8 OSHA letter of interpretation 9/30/1994 www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=21607&p_table=INTERPRETATIONS