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Why are we here? Because we’re here!

One item came up on the radar this past week or so and it appears (I poked around in the archival blogosphere and could find no mention) that I’ve not discussed this before—mea maxima culpa! This has the potential for generating some findings, perhaps at a higher risk level than would seem reasonable in the moment, but I guess that will sort itself out one way or the other.

I can’t quite remember how it all came to be, but at some point in the misty past, I was “schooled” that decontamination showers (like the ones that you typically find in areas near emergency room ambulance entrances) are not required to undergo weekly testing as they are not, as defined, “emergency eyewash or shower equipment” and, thus, not subject to the requirements of ANSI Z358.1 Standard for Emergency Eyewash and Shower Equipment. I was skeptical at the time, but I can say that the latter part of that concept is, indeed, correct in that decontamination shower equipment is not subject to ANSI Z358.1. But it is not correct relative to the weekly testing sequence because there is an ANSI standard—ANSI 113 Standard for Fixed and Portable Decontamination Shower Units—that covers decontamination showers and, lo and behold, it covers exactly what is required for those pesky fixed and portable decon shower units. So we have:

7.2 Fixed shower units shall be activated weekly for a period long enough to verify operation and ensure that flushing fluid is available.

That should sound familiar as a general concept, so you may need to add the decon shower(s) to the weekly to-do list, but things get even more interesting for the portables:

7.3 Portable shower units shall be deployed every 3 months to ensure proper operation.

I’m going to guess that we have some room for improvement on the weekly testing side of things, but I’m going to guess that we may even more of an opportunity on the portable side of things (those of you who possess portable decon showers). I daresay it’s almost enough to make someone not want to have anything elaborate or portable when it comes to decon shower equipment. I’ll let you gnaw on that for a bit…

Crying my eyes out: The never-ending story of emergency eyewash equipment!

October seems to be shaping up into a “greatest hits” kind of month as we once again dig back into the closet of perennial findings—this week finds us in the realm of managing occupational exposure to chemicals.

With the information contained in the September issue of Perspectives, it looked like findings relating to hazardous materials and wastes (which were mostly related to eyewash stations) had dropped off the Top 10 list (it was the #9 most-frequently cited standard for 2018), which I saw as a good thing. Generally speaking, I’ve found that the knowledge-base of the surveyor corps relative to the management of occupational exposures to hazardous materials leaves a little bit to desire, and rather prone to over-interpretation of what does and what does not constitute an inappropriately managed risk. You could, of course, (and I certainly have) give voice to the thought that over-interpretation is something of a standard practice amongst the surveyors of the world and you’d get very little in the way of argument from me. But there are a couple of recent findings that kind of crystallized (at least for me), the intersection of over-interpretation and a limited knowledge of the practical/operational aspects of appropriate management of occupational exposure to hazardous chemicals.

So, we have the following:

  • A single container of bleach in a storage room becomes a finding of moderate risk because the pH level of bleach requires the installation of an eyewash station

Now, purely from a reasonable risk assessment standpoint (and in recognition of the very remote likelihood that the container of bleach is going to somehow vomit its contents), the mere presence/storage of a corrosive does not (in my mind) constitute a risk of occupational exposure. If someone is pouring the bleach into another container (which is not the case here—again, only storage), then the risk of occupational exposure comes into play. The image that I conjured up relative to this is the local grocery store—gallons upon gallons of bleach—and nary an eyewash in sight (and yes, while OSHA doesn’t really jump ugly relative to customer exposure, the risks to customer and in-house staff is probably about equal). I suppose the best course for a corrective action would be to remove the bleach and be done with it. That said, this seems a bit of a reach…

  • Two eyewash stations (one in a soiled utility room and one in a scope decontamination room) that were located at dirty sinks in these areas, increasing the risk of staff exposure to contamination

Now, my philosophy regarding the location of emergency eyewash equipment is that you want to install them in locations as close to the point of likely exposure as is possible/reasonable, which sometimes (maybe even often) means that you install them on the only sink in a soiled utility room, etc. And you do that because?!? You do that because, the emergency eyewash station is equipped with protective covers to ensure that the emergency eyewash does not get contaminated, so you can install them in the locations in which they would be of the greatest benefit in an emergency, which might very well be in a soiled location.

It seems that the mystery of eyewash stations will never be completely solved…