Rounding Out Your Safety Program with Emergency Eyewashes and Safety Showers

By: Cindy Pauley, Contributor

Emergency planning is one of the most vital parts of a comprehensive safety program. Employers and employees understand the importance of evacuation, emergency exits and fire extinguishers. However, there’s another emergency planning component that’s often overlooked — emergency eyewashes and safety showers.

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.” This requirement is in place so workers can help themselves as much as possible until additional assistance arrives. Without proper eyewash and safety shower implementation, a serious gap exists in emergency response.

Start with a hazardous materials exposure assessment

Employers must perform a hazard assessment to identify chemical exposures. OSHA expects employers to determine the level of the potential risk to employees and provide protection accordingly. Because eyewashes or safety showers aren’t required simply because chemicals are in the workplace, a hazard assessment is necessary. The standard is clear that these units are required if workers are exposed to harmful corrosive materials.

Hazard assessments should include:

• Referencing safety data sheets (SDSs);
• Focusing on each chemical’s properties and hazards;
• Identifying effective protective measures; and
• Evaluating precautions for safely handling and storing chemicals.

The SDS may not clearly state an eyewash or safety shower is required, so the employer makes the determination. For example, where an SDS indicates a material may cause eye burns or blindness, the material would be considered hazardous, and therefore an eyewash or safety shower must be provided. Employers can also reference manufacturer guidelines or the NIOSH Pocket Guide to Chemical Hazards when in doubt.

OSHA’s definition of “corrosive”

Eyewashes and showers should be activated weekly to verify that they are operating correctly. © settapong – stock.adobe.com

An April 14, 2008, OSHA letter of interpretation clarifies a “corrosive” as:

“… A chemical that causes visible destruction of, or irreversible alterations in, living tissue by chemical action at the site of contact. For example, a chemical is considered corrosive if, when tested on the intact skin of albino rabbits by the method described by the U.S. Department of Transportation in appendix A to 49 CFR part 173, it destroys or changes irreversibly the structure of the tissue at the site of contact following an exposure period of four hours. This term shall not refer to action on inanimate surfaces.”

Although OSHA doesn’t stipulate requirements for chemicals other than corrosives, the American National Standards Institute (ANSI) standard expands the qualifier to hazardous materials. ANSI considers “hazardous materials” to include caustics and substances or compounds that could produce adverse effects for human health or safety (e.g., excessive dust).

What’s required with an eyewash or safety shower?

OSHA refers to ANSI Z358.1 for eyewash and safety shower design, use, testing and maintenance compliance. These include:

• Accessible by the average person traveling a distance of approximately 55ft in 10 seconds when walking at a normal pace.
• Able to deliver a minimum of .4 gallons of flushing fluid per minute for 15 minutes.
• Having a temperature that is “tepid,” or between 60 F to 100 F.

Equipment location is key

Once eyewash or safety shower requirements are identified, the next step is determining the location. When considering placement, the intent is that someone with vision impairment can safely navigate the work area to the eyewash or shower station. Meandering around equipment, fighting with door handles, or climbing stairs while temporarily blinded can delay essential care.

ANSI recommends eyewashes and showers be located on the same level as the hazard but states an unobstructed single step would be acceptable. Doors should only be permitted when they open toward the eyewash or safety shower and have no locking mechanisms that may prevent access to the safety equipment.

The level of hazard also must be considered when determining the placement of eyewashes and safety showers. The more hazardous the material, the closer in time and distance the unit should be. For example, for strong acids or caustics, the eyewash or shower should be immediately adjacent to the hazard.

Can I rely on saline bottles?

ANSI doesn’t consider a personal wash unit (e.g., an eyewash bottle) as an adequate primary eyewash. Always consult the chemical’s SDS and plan protective measures accordingly.

Emergency flushing duration recommendations vary depending on chemical properties and demonstrate why saline bottles aren’t adequate for most hazardous chemicals. For example, ANSI recommends:

• 5-minutes for non-irritants or mild irritants,
• 15-20 minutes for moderate to severe irritants and chemicals with acute toxicity,
• 30 minutes for most corrosives, and
• 60 minutes for strong alkalis (e.g., sodium, potassium or calcium hydroxide).

Do battery charging stations need an eyewash or shower?

Whether working with lithium-ion or forklift batteries, 1910.151(c) requires suitable drenching facilities where employees may be exposed to harmful corrosive materials. Where there’s no exposure to “corrosive materials,” eyewashes or safety showers aren’t required. This includes where batteries are only charged and where no maintenance is performed on the equipment or battery.

Inspections keep an eye on quality

Both OSHA and ANSI expect employers to perform inspections on eyewash stations and safety showers. Annual inspections ensure that units are maintained per the manufacturer’s instructions. However, to ensure safe use, more frequent inspections are also required.

Per ANSI Z358.1, activation of eyewashes and showers is required weekly to verify operation, ensure adequate fluid supply, and clear the supply line of any sediment that could prevent fluid flow. Activation duration depends on the amount of water contained in the unit plus any piping that’s not a part of a constant circulation system, or “dead leg” portions. This typically requires at least a three-minute flush for each test. Inspections of both self-contained and plumbed units provide an opportunity to ensure proper function and contaminant-free cleansing.

Anyone can be trained to perform inspections, which include:

• A top-to-bottom visual check to ensure the unit isn’t blocked or covered with material and nothing is broken or missing.
• Verifying that activated units provide a continuous, hands-free fluid flow that allows the user to hold their eyes open for flushing or removing contaminated clothing.
• Confirming that eyewash protective caps are present, and that water pressure effectively ejects the caps.
• Ensuring safe water temperature. Water that’s too hot or cold could deter the injured worker from a full 15-minute flush.

Eyewash implementation efforts are futile without training

Even the most robust emergency plan, complete with emergency equipment in the perfect locations, is void if employees aren’t trained. Workers must understand how eyewashes and safety showers fit into the comprehensive safety plan; where these units are located; and how to use, inspect, and maintain this lifesaving equipment.

A well-rounded training program will also include related topics like Hazard Communications (1910.1200), Emergency Action Plans (1910.38), Medical Services and First Aid (1910.151), and PPE (1910.132). Employers should consider specialized training as related to any unique workplace processes, such as laboratories (1910.1450).

And what about recordkeeping?

OSHA doesn’t detail recordkeeping requirements for eyewash and shower inspections. It’s always a best practice to keep a record of inspections, however, should the employer ever be asked to demonstrate inspection compliance.

Many companies use tags as quick, visual confirmation that equipment has been inspected; others may use a spreadsheet to track inspections. How employers document inspections is up to their discretion. WMHS

Cindy Pauley joined J. J. Keller & Associates, Inc. in June 2022 as an Editor on the Environmental, Health & Safety (EHS) Publishing Team. She uses her 13 years of safety program development and management experience in oil and gas, chemical, manufacturing, construction, and agricultural industries to develop a wide variety of easily understandable content and to provide regulatory insight for J. J. Keller’s customers and partners. Pauley is both a Certified Occupational Safety Specialist (COSS) and a Certified Occupational Hearing Conservationist (COHC) with a Master of Arts (MA) and Bachelor of Applied Arts (BAA) from Central Michigan University.