- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
September 30, 1994
Mr. Edward Krisiunas, MT(ASCP),CIC
Infection Control Coordinator
Safe Way Disposal Systems, Inc.
90 Industrial Park Road
Middletown, Connecticut 06457
Dear Mr. Krisiunas:
Thank you for your inquiry of April 14, requesting interpretation of 29 CFR 1910.151, Medical services and first aid, specifically, section (c) regarding "suitable facilities for quick drenching or flushing of the eyes and body." We apologize for the delay in responding.
You specifically request clarification of the following items:
1. What criteria does the Occupational Safety and Health Administration (OSHA) use to establish the acceptance of emergency eyewash equipment?
Response:
The OSHA standard 29 CFR 1910.151(c) requires that the employer must provide suitable facilities for quick drenching or flushing of the eyes and body when employees are exposed to injurious corrosive materials. For specific requirements, OSHA refers to consensus standard ANSI Z358.1-1990 through the General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health (OSH) Act.
2. Do compliance officers weigh the type, quality, and/or frequency of use of chemicals in a facility to determine whether the eyewash or shower stations are appropriate?
Response:
Yes, severity of injury, time of exposure, and number of employees exposed are all considered in determining the required number of eyewash stations, shower stations, or both eyewash and shower stations. The emergency eyewash and shower equipment must meet the specifications of ANSI 358.1-1990, to be acceptable to OSHA.
3. Should severity of an exposure be considered when buying eyewash equipment?
Response:
Yes, any improvement of quality and/or response time for commencing the eyewash procedure should be considered when purchasing eyewash equipment.
4. Is the presence of an eyewash station, regardless of design, sufficient to OSHA?
Response:
No, The emergency eyewash and shower equipment must meet the specifications of ANSI 358.1-1990, to be acceptable to OSHA.
We appreciate your interest in employee safety and health. If we can be of further assistance, please do contact David Garcia on 202-219-8031 x 121.
Sincerely,
John B. Miles, Jr., Director
Directorate of Compliance Programs
M/R: Previous letter of interpretation attached [07/20/92 Naim Interpretation Letter].
Enclosure
Disposal Systems, Inc.
90 Industrial Park Road
Middletown, CT 06457
April 14, 1994
Ms. Ruth McCulley
Director of Health Compliance Division
U.S. Department of Labor - OSHA
Room N-3469
200 Constitution Avenue, N.W.
Washington, DC 20210
Dear Ms. McCulley;
I am writing to request an interpretation of 29 CFR 1910.151, Medical services and first aid, specifically, section (c) regarding "suitable facilities for quick drenching or flushing of the eyes and body."
Many "Eyewash Stations" are sold under the guise they meet OSHA standards. I have the ANSI Standard Z358.1-1990 for Emergency Eyewash and Shower Equipment. I have also spoken with the Industrial Safety Equipment Association (ISEA) concerning faucet mounted eyewash units (see attached memo).
I am trying to determine what criteria OSHA compliance personnel use to establish the acceptance of eyewash safety equipment. The ISEA memo clearly describes several deficiencies why faucet mounted eyewash units do not meet the ANSI standard.
Do compliance officers weigh the type, quantity, and/or frequency of use of chemicals in a facility to determine whether the eyewash stations or showers are appropriate, i.e., a hospital chemistry laboratory versus a dental office? Should severity of an exposure be a consideration when buying an eyewash station?
I believe OSHA does not endorse safety equipment. As indicated above, I want to establish whether the presence of an eyewash station, regardless of design, is sufficient to OSHA. Please elaborate on the criteria OSHA uses, if any.
I have enclosed a sample of an eyewash station developed by a dentist in Oklahoma. I have also provided you examples depicted in safety catalogs.
Should you have any additional questions, please contact me at 1-800-231-7233. I look forward to your response.
Sincerely,
Edward Krisiunas, MT(ASCP), CIC
Infection Control Coordinator