Wash it out

July 31, 2002
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When working with chemicals, is there a more basic - and urgent - concern than protecting the eyes? OSHA frequently issues citations relating to the lack of emergency eye fountains (or their equivalent). Much less frequently, the lack of a deluge shower (or equivalent) is cited.

The referenced standard in these cases is most often 29 CFR 1910.151(c), which states: "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."

There is no exact criteria describing what specific chemical properties or amounts can "kick you in" to the standard. If the chemical has a very high or very low pH factor (strong acid or base), and there is a reasonable chance of eye contact, I suggest that you provide the fountain. Personal protective equipment use may lessen injury likelihood but is not considered a substitute for a fountain.

Eye fountains

Although there may well be value in having eye cup solutions and flushing bottles, if you are cited you can expect to be held to a greater burden. OSHA has generally interpreted the standard, in the case of eye concerns, to call for an eye fountain. Such a device is to have two streams, meeting at nearly a vertex, for a constant flow of at least 15 minutes. The temperature and pressure should be automatically controlled to be adequate for the cleansing job intended.

There is to be "no hands required" operation after simple activation. Caps, which are displaced by the initial flow of water, or similar devices are to be used to help avoid the first stream portion from transporting accumulated dust or similar irritants towards the eyes. The fountain must be conspicuous, preferably made known by a green and white sign, and access to it must be totally unimpeded.

Sounding the alarm

It's a good idea to equip plumbed fountains with an audio and visual alarm on a spring-loaded bypass. The purpose of the alarm is simply to alert others to the emergency. The bypass allows employees to test the "eye-full tower" units without setting off the alarm. The employee performing the test cannot fail to reset the alarm; the reset will be automatic.

If the bypass is not there, employees might be reluctant to conduct the test, feeling that it takes too much effort to inform all of the relevant persons. As a result, the inadequacy of the flushing system could go undetected. If you use a non-plumbed system, realize that testing will deplete the reservoir and that a biocide-type solution may be necessary.

The eye fountain must be in the immediate area of the hazard. OSHA standards do not specify maximum distances from hazard to fountain, although compliance officers frequently use 25 feet as a guide. Not only should the potential victim NOT have to travel too far to reach the unit, but there should be no doors, ramps or steps in the path, and turns should be minimized. Considering these factors, along with the degree of hazard presented by skin contact with the specific chemical(s), it is often prudent to assure that the eye fountain is within just a few feet of the hazard. Further, OSHA may interpret that in particular situations, even 15 feet, for instance, is unreasonable and therefore "citable."

Deluge showers

The need for deluge showers is often cited where there is a significant hazard associated with a reasonably anticipated large splash. The general interpretation calls for an overhead unit, which will continue to dump a high volume of well-dispersed water, after a large ring is pulled. A locker-room type of shower will not suffice, as there is a need to adjust pressure, direction, temperature and sometimes even pattern. The shower should not take the place of the eye fountain.

When there are hazards associated with open surface tanks (most often plating), 29 CFR 1910.94(d)(9) (vii) should be cited. This standard more liberally details the criteria for alternative flushing means by way of a hose. However, it does not limit the hazard to corrosives. 1910.94 requires that, "Near each tank containing a liquid which may burn, irritate or otherwise be harmful to the skin if splashed upon the worker's body, there shall be a supply of clean cold water."

Worth the effort

When I was an OSHA compliance officer, I conducted an inspection where corrosive boiler treatment chemicals were used. The deluge shower was not nearly close enough to the area of chemical handling. As a result of my inspection, a citation was issued and the company complied with it, installing another deluge shower in the immediate area of the danger. (Keep in mind, however, that chemicals may well be handled in areas not limited to a few square feet.)

I subsequently revisited the company on a follow-up to assure compliance. When I arrived the safety director shook my hand and thanked me. Asked why I was being thanked, the director did not provide a direct response, but rather introduced me to an employee who often worked in that boiler treatment area. He, too, shook my hand and thanked me. Then he explained that just the day before my follow-up visit he had spilled a bucket of chemical on his head, but fortunately the new shower was within ten feet of him and it essentially saved him from serious injury.

I recommended that such chemicals never be stored overhead, and then I left with a smile on my face.

SIDEBAR: Time-critical

The current ANSI standard ANSI Z358.1, the American National Standard for Emergency Eyewash and Shower Equipment, provides details on eyewash and shower equipment and system specifications.

When the ANSI standard was updated in 1998, it featured a significant change to the original version that relates to the location of emergency flushing facilities. In response to end-user concerns, the newer standard emphasizes the time it takes a worker to reach an eyewash or shower, rather than the distance between units. Therefore, the flushing facility should be located such that it is not just close at hand but also easy to access. So even if your unit is in close proximity to a chemical handling area, make sure there's a clear, unimpeded path to it.

Copies of ANSI Z358.1-1998 are available from the International Safety Equipment Association (ISEA). Visit www.safetyequipment.org.

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