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FAQ - Regulatory Processes - 2016
FAQ - Regulatory Processes - 2016

 

 

We have only motion sensors on our sinks for IC purposes - what do we need for an eyewash station? Can we put an eyewash station on a motion sensors sink? Can it be in Sterilization area or clinical area. It is a large office and we are not sure if we need 2 eyewash stations. Thank you.

Regarding plumbing issues, it is recommended that you consult further with ANSI/ISEA Z358.1-2014, the American National Standard for Emergency Eyewash and Shower Equipment (also noted below). This standard provides further information regarding the specific installation and operation requirements for eyewash stations. You may also wish to consult further with your state public health agency and/or area OSHA office on this matter. Requirements can vary by state. Further information about State OSHA Programs can be accessed at: https://www.osha.gov/dcsp/osp/index.html   1

Ask OSAP can provide you with some general information on this topic. 

Generally, the product’s Safety Data Sheet (formerly known as the Material Safety Data Sheet) includes a section on First Aid and should specify if an eyewash unit is required.

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:

Handling Emergencies

  • 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:
http://search.usa.gov/search?affiliate=usdoloshapublicwebsite&query=corrosive%2C+eyewash&x=25&y=8  5

As one of these letters notes:

The OSHA requirements for emergency eyewashes and showers, found at 29 CFR 1910.151(c), specify that "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. As the standard states, an eyewash and/or safety shower would be required where an employee's eyes or body could be exposed to injurious corrosive materials. If none of the materials used in this work area is an injurious corrosive [chemical] (as indicated by the Material Safety Data Sheet (MSDS) for each product), then an emergency eyewash or shower would not be required pursuant to 1910.151(c). 

While not having the force of a regulation under the OSH Act, the current ANSI standard addressing emergency eyewash and shower equipment (ANSI [Z]358.1-2004) provides for eyewash and shower equipment in appropriate situations when employees are exposed to hazardous materials. ANSI's definition of "hazardous material" would include caustics, as well as additional substances and compounds that have the capability of producing adverse effects on the health and safety of humans. ANSI's standard also provides detail with respect to the location, installation, nature, and maintenance of eyewash and shower equipment. 6

Resources

1)     US Department of Labor – Occupational Safety & Health Administration. Frequently Asked Questions about State Occupational Safety and Health Plans. https://www.osha.gov/dcsp/osp/index.html    Accessed on April 26, 2016. 

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 April 26, 2016.

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 April 26, 2016.

4)     US Department of Labor – Occupational Safety & Health Administration. Medical and First Aid. https://www.osha.gov/SLTC/medicalfirstaid/index.html   Accessed on April 26, 2016.

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 April 26, 2016.     

6)     US Department of Labor – Occupational Safety & Health Administration. Letter of Interpretation dated June 1, 2009. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27089   Accessed on April 26, 2016.

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