| FAQ - Practice Safety/Patient Safety - 2015
I was recently asked to provide Infection Control Training for a large group dental practice. I was given the attached information regarding their eyewash station policy. Can you comment of give me a resource that verifies this information is correct?
When Are Eyewashes Required?
The primary regulation establishing requirements for emergency eyewash and shower equipment is the Federal Occupational Safety and Health Administration (OSHA) First Aid Standard. This standard 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” (29 CFR 1910.151(c)).
What Types of Materials Require Eyewashes?
Materials that are corrosive or hazardous to the eyes or skin are used in various work areas throughout the organization. (Please Note: BBF Exposure does not fall into this category) In these areas, emergency eyewash and shower equipment must be installed and maintained to achieve compliance and ensure the health and safety of employees and physicians. Examples of some corrosives and materials that are hazardous to the eyes or skin used include:
• Chlorine and Bromine
• Detergents and Cleansers
• Ethylene Oxide
• Formaldehyde and Formalin
• Fuels, Solvents and Adhesives
• Hydrochloric Acid
• Ortho-phthalaldehyde (Cidex® OPA)
• Peracetic Acid
It would appear that this is an OSHA related matter. Perhaps, you should consider consulting with your area OSHA office. Please note that there may be varying requirements in those states with State OSHA Programs. Further information about State OSHA Programs can be accessed at: http://www.osha.gov/dcsp/osp/faq.html 1
Ask OSAP can provide you with some general information.
Generally, the product’s Safety Data Sheet (formerly known as the Material Safety Data Sheet) would include a section on First Aid and specify if an eyewash unit is required.
Additionally, OSHA does generally recognize ANSI standards and can utilize them under the General Duty Clause. ANSI/ISEA Z358.1-2014 is the American National Standard for Emergency Eyewash and Shower Equipment.
This standard establishes minimum performance and use requirements for eyewash and shower equipment for the emergency treatment of the eyes or body of a person who has been exposed to hazardous materials. It covers the following types of equipment: emergency showers, eyewashes, eye/face washes, and combination units.
This standard also includes performance and use requirements for personal wash units and drench hoses, which are considered supplemental to emergency eyewash and shower equipment. 2
Regarding eye and face protection, OSHA does state the following on its website:
- If an eye injury occurs, quick action can prevent a permanent disability. For this reason:
- Emergency eyewashes should be placed in all hazardous areas
- First-aid instructions should be posted close to potential danger spots
- Employees must know where the closest eyewash station is and how to get there with restricted vision 3
OSHA also has a publication entitled Best Practices Guide: Fundamentals of a Workplace First-Aid Program (PDF*). OSHA Publication 3317-06N, (2006). This publication Identifies four essential elements for first-aid programs to be effective and successful; management leadership and employee involvement, worksite analysis, hazard prevention and control, and safety and health training. It also includes best practices for planning and conducting safe and effective first-aid training. 4
There are also several relevant letters of interpretation on the OSHA website that you may find of interest and can be accessed here:
OSHA defines a bloodborne pathogens exposure incident as follows:
Exposure Incident means a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee's duties. 6
Have you tried asking the employer to explain their emergency procedures for an accidental splash to the eye involving blood or OPIM? Of course, splashes and foreign objects can be prevented from reaching the eye with the proper use of eye protection (PPE).
1) US Department of Labor – Occupational Safety & Health Administration. Frequently Asked Questions about State Occupational Safety and Health Plans. http://www.osha.gov/dcsp/osp/faq.html Accessed on February 10, 2015.
2) ANSI. American National Standard for Emergency Eyewash and Shower Equipment. http://webstore.ansi.org/RecordDetail.aspx?sku=ANSI%2FISEA+Z358.1-2014&sourcekeyword=_inurl:webstore.ansi.org%23inurl:sku%3Dansi&source=google&adgroup=ANSI-Standards&gclid=CJzN_9bp18MCFTQF7AodqHYA1A Accessed on February 10, 2015.
3) US Department of Labor – Occupational Safety & Health Administration. Eye and Face Protection
E-Tool. https://www.osha.gov/SLTC/etools/eyeandface/employer/requirements.html Accessed on February 10, 2015.
4) US Department of Labor – Occupational Safety & Health Administration. Medical and First Aid. https://www.osha.gov/SLTC/medicalfirstaid/index.html Accessed on February 10, 2015.
5) US Department of Labor – Occupational Safety & Health Administration. Search using the terms “corrosive, eyewash”. http://search.usa.gov/search?affiliate=usdoloshapublicwebsite&query=corrosive%2C+eyewash&x=25&y=8 Accessed on February 10, 2015.
6) US Department of Labor – Occupational Safety & Health Administration. 1910.1030 Bloodborne Pathogens. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10051 Accessed on February 10, 2015,