Mr. Eric Smith, P.E.
International Institute of Ammonia Refrigeration
Vice President and Technical Director
1001 North Fairfax Street, Suite 503
Alexandria, Virginia 22314-1797

Dear Mr. Smith:

Thank you for your letter on behalf of the International Institute of Ammonia Refrigeration (IIAR) to the Occupational Safety and Health Administration (OSHA) for a clarification of OSHA’s standard at 29 CFR 1910.151(c), Medical services and first aid.  This constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.  We apologize for the delay in our response. 

Your questions are paraphrased and our responses follow.

Scenario/Background:  29 CFR 1910.151(c) 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.

The IIAR believes that identified risks of exposure to ammonia, an injurious corrosive material, exist only when maintenance occurs that involves the deliberate opening or the potential uncontrolled opening of a system.  This is because there is a very low probability that equipment, valve stations and piping will have ammonia leaks.  Examples of the types of maintenance functions where there is virtually no risk of exposure are: service of control systems, cleaning of coils, lubrication of bearings, fan replacement, where there is no intention of opening or repairing the pressure-containing envelope of the system.

However, the IIAR contends that even where employees are exposed to ammonia used in refrigeration, the use of eyewash/safety showers in cold environments is impractical.  Refrigerated facilities are often very expansive and much of the equipment, piping and valve stations are located along roofs or within refrigerated areas.  Permanent eyewash/safety shower stations, or even tepid water loops for temporary drenching connections, can present a tremendous capital cost as well as operating and maintenance costs in such conditions because of the need for freeze protection of water piping.  While temporary portable eyewash/safety showers are often a good alternative, their use in cold weather conditions or in cold or subfreezing rooms is impractical.  Water in portable units cannot be kept at required temperatures.  Further, the use or testing of any type of eyewash/safety shower in cold conditions can present a potential for hypothermia or even create a slip/trip hazard – the last thing that is needed when evacuation is necessary.  Even the testing of permanently installed units can present potential hazards. 

Question #1:  Would OSHA accept the use of personal protective equipment in lieu of permanent or portable eyewash/safety showers in cold environments? 

Reply #1:  No.  OSHA would not accept the use of personal protective equipment in lieu of eyewash/safety showers regardless of the environment.  Further, there are emergency eye wash and safety shower products that have built-in heating elements for maintenance operations in cold environments.

Question #2:  If the ammonia refrigeration is in a sealed container where there is no intention of opening or repairing the pressure-containing envelope of the piping system, does 29 CFR 1910.151(c) require an eyewash or emergency shower?

Reply #2:  No.  However, as you recognized in your letter, for some maintenance operations, such as oil draining, equipment replacement, and valve and piping maintenance or repair, there is potential exposure to ammonia.  In those circumstances, the standard requires the employer to provide facilities for quick drenching or flushing of the eyes or body. 

Thank you for your interest in occupational safety and health.  We hope you find this information helpful.  OSHA’s requirements are set by statute, standards, and regulations.  Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances.  This letter constitutes OSHA’s interpretation of the requirements discussed.  From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation.  To assure that you are using the correct information and guidance, please consult OSHA’s website at http://www.osha.gov.  If you have further questions, please feel free to contact the Office of General Industry and Agricultural Enforcement at (202) 693-1850.

Sincerely,

Thomas Galassi, Director
Directorate of Enforcement Programs