Using ANSI Z358.1 as guidance to comply with 1910.151(c) | Occupational Safety and Health Administration

Standard Number:

1910.151(c)

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.

March 28, 2002

Mr. Scott King
Manager-Technical Services
NorFalco LLC - US Operations
Independence, Ohio 44131

Dear Mr. King:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA). You requested 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." Your question has been restated below for clarity. Please accept our apology for the delay in this response.

Background: Your company, a large manufacturer and distributor of sulfuric acid, requires the services of many third party terminals and distributors to assist with the handling of your product. You have specific criteria when acquiring a new terminal that it must meet before a contract is signed. One of these requirements is the need for safety showers that meet or exceed OSHA requirements; OSHA has quoted ANSI Z358.1-1990 in several letters of interpretation. However, there is a new ANSI Z358.1-1998 standard that goes into much more detail and would require some facilities to make a significant capital expenditure to comply.

Question: Which ANSI standard does OSHA enforce?

Answer: ANSI standards become mandatory OSHA standards only when, and if, they are adopted by OSHA; ANSI Z358.1 was not adopted by OSHA. In comparison with the OSHA standard at 29 CFR 1910.151(c), however, ANSI Z358.1 provides detailed information regarding the installation and operation of emergency eyewash and shower equipment. OSHA, therefore, has often referred employers to ANSI Z358.1 as a recognized source of guidance for protecting employees who are exposed to injurious corrosive materials.

OSHA would also take the ANSI standard into consideration when evaluating the adequacy of the protection provided by an employer. OSHA recognizes that there are differences between the 1990 and 1998 versions of ANSI Z358.1, and is planning to develop a compliance directive addressing this issue to ensure uniform and consistent enforcement of 29 CFR 1910.151(c). In the meantime, employers should assess the specific conditions in the workplace and determine whether compliance with the 1998 version of the ANSI Z358.1 will provide protection for employees that compliance with the 1990 version would not.

Thank you for your interest in occupational safety and health. If you have further questions, please feel free to contact the [Office of General Industry Enforcement] at (202) 693-1850.

Sincerely,

John L. Henshaw
Assistant Secretary

[Corrected 6/2/2005]