January 20, 2010 | | Comments 6
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Eyewash stations hinge on chemical use as opposed to a wholesale requirement

Eyewash stations are only required by OSHA in specific instances, and those instances are discerned through a review of the material safety data sheets (MSDS) for the chemicals being used.

If an MSDS indicates that first aid response to an eye exposure requires flushing for 15 or more minutes, then you are looking at an eyewash station. Anything less than 15 minutes, no eyewash is required.

If you remove the chemicals in question (generally caustics or corrosives), then you have eliminated the risk, so the eyewash station becomes little more than a nicety. If you don’t need eyewash stations, your resources are better used elsewhere.

If you cannot remove the chemicals, then you have to be able to demonstrate how you manage the chemicals, which includes emergency response capability, such as eyewash stations.

In such cases, arguing against eyewash use to an inspector or surveyor can become a slippery slope in terms of best practices.

Many people are familiar with ANSI’s Z358.1 eyewash standard, which OSHA references but doesn’t mandate compliance with. However, ANSI’s standard is recognized industry guidance. So the question then becomes: If one could consider using the ANSI standard as a best practice for maintaining eyewash stations, what compelling evidence or data do you use to determine an approach different than ANSI’s?

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Filed Under: Environment of careOSHA

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Steve MacArthur About the Author: Steve MacArthur is a safety consultant with The Greeley Company in Danvers, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Briefings on Hospital Safety. Contact Steve at stevemacsafetyspace@gmail.com.

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  1. I am concerned that chemicals may not be the only requirement for having an eye wash available.

    OSHA’S Bloodborn pathogen standard under 1910.1030(d)(2)(vi) states “Employers shall ensure that employees wash hands and any other skin with soap and water, or flush mucous membranes with water immediately or as soon as feasible following contact of such body areas with blood or other potentially infectious materials.”

    While the term “flush” is not defined, it is usually used to indicate the addition of water to flow across the eye or into the nose/mouth to assist in removing blood. An eye wash would be the logical device to flush eyes.

  2. Steve MacArthur

    Hi Bruce,

    There are certainly benefits to having eyewash stations in certain instances, but when looking at when they are specifically required, from a regulatory perspective, the instances of mandates is very low. In fact, the Bloodborne Pathogens standard would be an excellent example of where the regulatory standard pulls up short of mandating eyewashes, but certainly gives you enough of a description to identify it as a possible strategy. That said, particularly when it comes to blood and body fluid exposures, the real “mandate”, if you will, is to focus on prevention because, let’s face it, if we need an eyewash station because of an exposure, that means the rest of the process – PPE, engineering controls, etc. have failed. I’d encourage you to look at exposures as one of two things – preventable and non-preventable. I think you’ll find that when push comes to shove (I’m just full of cliches today, aren’t I) that there are very few exposures that legitimately can be described as non-preventable, at least in the healthcare setting. They call them Universal Precautions for a reason.
    Have an extraordinarily safe rest of the week!

  3. Sir,
    In 1910.1030, Clinical Laboratory means a workplace where diagnostic or other screening procedures are performed on blood or other potentially infectious materials.

    1910.1030(d)(2)(vi)
    Employers shall ensure that employees wash hands and any other skin with soap and water, or flush mucous membranes with water immediately or as soon as feasible following contact of such body areas with blood or other potentially infectious materials.

    1910.1030(e)(3)(i)
    Each laboratory shall contain a facility for hand washing and an eye wash facility which is readily available within the work area.

    When considering the information above from 1910.1030, any area utilized for these purposes may be considered a clinical laboratory. All facilities shall ensure the ability to flush the eyes following an exposure. And, any area considered a laboratory shall contain an eye wash facility.

    When considering that ANSI is a private organization setting standard, NIOSH is a federal organization researching and developing standards, and OSHA is a federal regulatory agency that sets and enforces compliance of their standards, I would set my priority to first fulfill the OSHA regulation as it is the most stringent, and it is regulation.

  4. Steve Brash- in response to your statement re: 1910.1030(e)(3)(i)-

    …section (e) of 1030 refers specifically to HIV/HBV research laboratories and production facilities if i’m not mistaken. This would be clearly different than a “clinical lab”.

    I understand your broadness of scope, but again OSHA leaves the interpretation up to the person/organization performing the hazard assessment. This is why it’s important to identify which personnel (and subsequently their area of work) that would be required to utilize/maintain a proper emergency eye wash.

  5. In fact, the Bloodborne Pathogens standard would be an excellent example of where the regulatory standard pulls up short of mandating eyewashes, but certainly gives you enough of a description to identify it as a possible strategy.

  6. I recall reading something from OSHA soon after the posting of the bloodboren pathogen standard in the Federal Register relating to whether an eye wash station was necessary. It was many years ago and I could not find it when looking today. My recollection was that they did not consider resorting to an eye wash vs. taking all needed precautions such as using eye protection that would not allow a splash to directly or indirectly enter the eye, such as running down one’s forehead into the eye. As I recall, the correspondence stated that in the blink of an eye, the pathogen could be swept into an inaccessible area of the eye and the reason for the regulation subverted. A further concern was expressed that people could incorrectly depend on the eye wash and be somewhat more careless about taking the effective precautions for preventing fluid from contacting the eyes. This is an old, inactive blog, but I thought I would write anyway. We have a mandatory education slide that lists eye wash stations as acceptable engineering controls under the standard but I debate that based on the logical discussion above and personal experience.

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