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It appears that everything isn’t meant to be OK…

You may recall a few weeks back we were discussing some recent survey findings relative to the placement of eyewash stations once one has determined that one needs an eyewash station (or stations). At the time, my dream was to clarify those findings and have them vanish into the ether (which is pretty much where they belong). But alas, that dream crashed upon the rocks of an overreach—can’t say for sure if this signals a sea change or is based on a reluctance to overturn a judgement call in the field. The ruling from the home office read thusly (but not justly): “The organization must do a risk assessment to determine if substances that may be in the sink would not splash onto the person using the eyewash station and inadvertently be contaminated.”

And so, I guess we add an additional imponderable to the equation: How do we install the eyewash station close enough to the area of greatest risk without placing the eyewash in a location that could be adjudged to be too close to the risk area? I suppose the ultimate goal would be to try to remove the hazard entirely, but with all the focus on disinfection and the likelihood that whatever disinfectant in use is going to be firmly in the high-risk zone, that seems unlikely to win favor during survey. Is it possible to “sell” engineering controls to a surveyor that is looking to find things to cite? I think we can all agree that the use of PPE and other forms of engineering controls are probably never going to be the interventions we would hope for them to be, but it is often so difficult to protect folks from themselves.

That said, I suppose it wouldn’t be the worst idea to do a little global evaluation of your eyewash station locations (much like a conjunction function) and add yet another risk assessment to the mix. If you’ve got a survey coming up in the near future, it may save you some aggravation.

 

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…

Time to bust a cap in your…eyewash station?!?

Howdy folks! A couple of quick items to warm the cockles of your heart as winter starts to make its arrival a little more obvious/foreboding (at least up here in the land of the New English) as we celebrate that most autumnal of days, All Hallows Eve (I’m writing this on All Hallows Eve Eve)…

The first item relates to some general safety considerations, mostly as a function of ensuring that the folks who rely on emergency equipment to work when there is an emergency are sufficiently prepared to ensure that happens. It seems that lately (though this is probably no more true than it usually is, but perhaps more noticeable of late) I’ve been running into a lot of emergency eyewash stations for which the protective caps are not in place. Now I know this is partially the result of too many eyewash stations in too many locations that don’t really need to have them (the reasoning behind the desire for eyewash stations seems to lean towards blood and body fluid splashes, for which we all know there is no specific requirement). At any rate, my concern is that, without the protective caps, the eyewash stations are capable of making the situation worse if someone flushes some sort of contaminant into their eyes because stuff got spilled/splashed/etc. on the “nekkid” eyewash stations. The same thing applies to making sure the caps are in place for the nozzles of the kitchen fire suppression system (nekkid nozzles—could be a band name!—can very quickly get gunked up with grease). We only need these things in the event of an emergency, but we need them to work correctly right away, not after someone wipes them off, etc. So, please remind the folks at point of care/point of service/point of culinary marvels to make sure those caps are in place at all times.

The other item relates to the recent changes in the fire safety management performance element that deals with your fire response plan. Please take a moment to review the response plan education process to ensure that you are capturing cooperation with firefighting authorities when (periodically) instructing staff and licensed independent practitioners. One of the ages-old survey techniques is to focus not so much on the time-honored compliance elements, but rather to poke around at what is new to the party, like cooperation with firefighting authorities (or 1135 waiver processes or continuity of operations plans or, I daresay, ligature risk assessments). It would seem that one of the primary directives of the survey process is to generate findings, so what better way to do that than to “pick” on the latest and (maybe not so) greatest.

Have a safe reorientation of the clocks!

Education < / = / > Achievement: Don’t Let Survey Prep Get in the Way of Good Sense

I’d like to start off this week with an interesting (and hopefully instructive) tale from the field:

I was doing some work recently at an organization that is facing down the final six months of its survey window. This was my first visit to the facility and I was working on getting a sense of the place as well as identifying the usual list of survey vulnerabilities. As we’ve discussed before, one of the things that’s always in the mix, particularly with the gang from Chicago, is the care and feeding of emergency eyewash stations. This particular organization has adopted the strategy of having folks at the department level perform the weekly testing (a sensible approach from my standpoint—I think the most important piece of the weekly testing is helping to ensure that folks who might actually need the eyewash in an emergency actually know how the darn thing works), but the documentation form had two columns: one for the date and one for the signature of the person doing the test. The sheet did not, however, have any instructions on it, which prompted me to inquire as to how folks would know what (and why) they are checking, since the purpose is not just to run the water. The response to my inquiry was rather noncommittal, which is not that unusual, so I continued to collect data relative to the process. So, over the course of the facility tour, we found a couple of eyewashes with missing caps and no clear indication on the testing form that this had been identified as an issue. OK, not crazily unusual, but pointing towards a process that could use some tweaking. A couple of eyewashes with obstructed access provided a little more data.

Then we made our way to the kitchen. No real compliance issues with the eyewash itself, but I noted that they were checking the eyewash station on a daily basis and recording the temperature at that same frequency. Now, the ANSI standard does not require daily verification of eyewash flushing fluid temperature, so I asked about this particular practice (BTW: Nowhere else had we seen this practice—at least not yet …) and was informed another hospital in the region had been cited for not doing the daily temp checks (I have not been able to verify that this was an actual survey finding, but sometimes believing is enough … to cause trouble). And then we headed over to the lab and ran into a similar practice (they were just verifying the temps during the weekly test) and the feedback there was that a College of American Pathologists (CAP) surveyor had told them a story about an individual that had suffered eye damage because the (low temperature) water from the eyewash interacted with a chemical. This was not written up as a finding, but was relayed as an anecdotal recommendation.

The “funny” thing about all this (actually, there are a couple of process gaps) is that each of the eyewash stations in question are equipped with mixing valves, which pretty much mitigates the need for daily or weekly temperature checks (you want to check the temp when you’re doing the annual preventive maintenance activity). But the more telling/unfortunate aspect of this is that (independent of each other) these folks had unilaterally adopted a process modification that was not in keeping with the rest of the organization (it has been said, and this is generally true, that you get more credit for being consistently wrong than inconsistently right). Now, one of the big truisms of the survey process is that is almost impossible to push back when you are not compliant with your own policy/practice. And while I absolutely appreciate (particularly when the survey window is closing) wanting to “do the right thing,” it is of critical importance to discuss any changes (never mind changes in the late innings) with the folks responsible for the EOC program. While I pride myself on not telling folks that they have to do something that is not specifically required by code or regulation, some of the regulatory survey folks don’t share that reticence. The other potential dynamic for these “mythical” requirements is when a surveyor tells an organization something that doesn’t show up in the actual report. I run into this all the time—they may “look” at the finding in the report, but what they sometimes react to is what the surveyor “said.” Compliance has way more than 50 shades of whatever color you care to designate and what works/worked somewhere else doesn’t always work everywhere, so folks make these changes without knowing what is actually required and end up increasing the potential for a survey finding.

And healthcare isn’t the only pursuit in which incomplete communications (or making sure that communications are as complete as they can be) can have an impact. At the moment, I am reading An Astronaut’s Guide to Life on Earth by Col. Chris Hadfield (this, apparently, is going to be the summer for reading astronaut memoirs, be that as it may) and I came across a passage in which Hadfield describes a debriefing following a practice spacewalk in which one of the instructors noted that while Hadfield has a “very clear and authoritative manner,” he encouraged the folks participating in the debrief to not be “lulled into a feeling of complete confidence that he’s right.” As soon as I saw that, I was able to tie it back to the management of surveyors who speak in a “very clear and authoritative manner” and sometimes turn out not to be worthy of complete confidence that the surveyor is correct. If you are doing something that, in good faith and the extent of your knowledge, is the “right thing” and somebody (even me!) comes along and says you’re not doing that right, never be afraid to ask to see where it says that in the code/regulation, etc. (BTW: I’m not giving you permission to be obnoxious about it!) Surveyors (same for consultants) see a lot of stuff and sometimes compliance becomes a fixed idea, or process, in their head, but that doesn’t mean it’s the only way. And if you hear something that makes you think you have a vulnerability (something you’ve heard through that pesky grapevine), talk it out before you make any changes. That gives everyone in your organization a fighting chance at compliance.

As a final note, if you’ve forgotten about Col. Hadfield’s most notable performance (beyond the astronaut thing), check it out:

What it is ain’t exactly clear: Hazardous materials management and the SAFER matrix

I was recently asked to ponder the (relative—all things are relative) preponderance of findings under the Hazardous Materials and Wastes Management standard (EC.02.02.01 for those of you keeping track). For me, the most interesting part of the question was the information that (as was apparently revealed at the Joint Commission Executive Briefings sessions last fall) findings under EC.02.02.01 frequently found their way to the part of the SAFER matrix indicating a greater likelihood of causing harm (the metric being low, moderate, and high likelihood of harm) than some of the other RFIs being generated (EC.02.06.01, particularly as a function of survey issues with ligature risks, also generates those upper harm-level likelihood survey results). Once upon a time, eyewash station questions were among the most frequently asked (and responded to in this space), so it’s almost like replaying a classic

Generally speaking, the findings that they’ve earmarked as being more likely to cause harm are the ones relating to eyewash stations (the most common being the surveyors over-interpreting where one “has” to have an eyewash station the remainder pretty much fall under the maintenance of eyewashes—either there’s a missing inspection, access to the eyewash station is obstructed during the survey, or there is clearly something wrong with the eyewash—usually the protective caps are missing or the water flow is rather anemic in its trajectory). All of those scenarios have the “potential” for being serious; if someone needs an eyewash and the thing doesn’t work properly or it’s been contaminated, etc., someone could definitely be harmed. But (and it is an extraordinarily big “but”) it’s only when you have an exposure to a caustic or corrosive chemical, which loops us back to the over-interpretation. OSHA only requires emergency eyewash equipment when there is a risk of occupational exposure to a corrosive chemical (the ANSI standard goes a bit further by indicating eyewash equipment should be available for caustic chemicals as well as corrosives). A lot of the findings I’ve seen have been generated by the clinical surveyors, who are frequently in the company of hospital staff that aren’t really clear on what the requirements are (you could make the case that they should, if only from a Hazard Communications standard standpoint, but we’ll set that aside for the moment), so when the clinical surveyor says “you need an eyewash station here” and writes it up, the safety folks frequently don’t find out until the closeout (and sometimes don’t find out until the survey report is received). The “problem” that can come to the fore is that the clinical folks don’t perceive the eyewash finding as “theirs” because it’s not a clinical finding, so they really don’t get too stressed about it. So, the surveyor may ask to see the SDS for a product in use and if the SDS indicates that the first aid for eye exposure is a 15- or 20-minute flush with water, then they equate that with an eyewash station, which in a number of instances, is not (again, strictly speaking from a regulatory standpoint) “required.” Sometimes you can make a case for a post-survey clarification, but successful clarifications are becoming increasingly rare, so you need to have a process in place to make your case/defense during the survey.

The other “batch” of findings for this standard tend relate to the labeling of secondary containers (usually the containers that are used to transport soiled instruments); again, in terms of actual risk, these conditions are not particularly “scary,” but you can’t completely negate the potential, so (again) the harm level can be up-sold (so to speak).

In terms of survey prep, you have to have a complete working knowledge of what corrosive chemicals are in use in the organization and where those chemicals are being used (I would be inclined to include caustic chemicals as well); the subset of that is to evaluate those products to see if there are safer (i.e., not corrosive or caustic) alternatives to be used. The classic finding revolves around the use of chemical sprays to “soak” instruments awaiting disinfection and sterilization—if you don’t soak them, then the bioburden dries and it’s a pain to be sure it’s all removed, etc.; generally, some sort of enzymatic spray product is used—but not all of them are corrosive and require an eyewash station. Then once you know where you have corrosives/caustics, you need to make sure you have properly accessible eyewash equipment (generally within 10 seconds of unimpeded travel time from the area of exposure risk to the eyewash) and then you need to make sure that staff understand what products they have and why an eyewash is not required (strictly speaking, there really aren’t that many places in a hospital for which an eyewash station would be required) if that is the case—or at least make sure that they will reach out to the safety folks if a question should come up during survey. Every once in a while there’s a truly legit finding (usually because some product found its way someplace where it didn’t belong), but more often than not, it’s not necessary.

You also have to be absolutely relentless when it comes to the labeling of secondary containers; if there’s something of a biohazard nature and you put it in a container, then that container must be properly identified as a biohazard; if you put a chemical in a spray bottle, bucket, or other container, then there needs to be a label (there are exceptions, but for the purposes of this discussion, it is best managed as an absolute). Anything that is not in its original container has to be labeled, regardless of what the container is, the reason for doing it, etc. The hazard nature of the contents must be clear to anyone and everyone that might encounter the container.

At the end of the day (as cliché an expression as that might be), it is the responsibility of each organization to know what’s going on and to make sure that the folks at the point of care/point of service have a clear understanding of what risks they are likely to encounter and how the organization provides for their safety in encountering those risks. We are not in the habit of putting people in harm’s way, but if folks don’t understand the risks and (perhaps most importantly) understand the protective measures in place, the risk of survey finding is really the least of your worries.

I’m happy, hope you’re happy too…

A couple of weeks ago, HCPro’s Accreditation Insider featured an article that addressed a study published by the American Journal of Infection Control on compliance by nurses with the many and varied requirements of the Bloodborne Pathogens standard.

I guess I’m of two minds about the study; it is a somewhat smallish sample size (116 nurses were studied), though presumably statistically valid (not being wicked up on the whole statistical analysis thang, I wouldn’t even presume to presume, but I’m thinking that it would hardly have been worth publishing if it were not of some note). I think in my heart of hearts that (at this point) I would have hoped for better compliance numbers but again I’m not certain that I was particularly surprised that gloves aren’t worn all the time, hands are not washed as often as is necessary (e.g., after taking care of patients, after taking off gloves), and face shields are not worn as often as would be advisable given the risks (no big surprise on the face shields—it is a struggle, struggle, struggle—not just for the potential of an exposure to blood or other potentially infectious materials (OPIM to those among you that are acronymically inclined), but also for potential chemical exposures. (Everybody wants a freaking eyewash station “in case”, but nobody wants to use appropriate PPE to ensure that “case” doesn’t occur—jeepers!)

I haven’t had a chance to actually read the study (yes, I know—shame!), but the article in Accreditation Insider doesn’t really get into what the compliance barriers might have been (I honestly don’t know if the study gets into some of the causative factors), which I think would have been instructive. Apparently, the study concludes with a recommendation for stricter enforcement of compliance policies and to address problem areas with better monitoring and staff education. Now, those are fine things indeed, but kind of begs the question as to what constitutes better monitoring and staff education. I will go on the record here (I don’t think I have previously, but if I have, mea maxima culpa) as no particular fan of computer-based learning. I “get” that it is more convenient for folks to do and thus, generally results in better “compliance” when it comes down to numbers of folks completing the required “modules,” etc. And I also “get” that it is compliant from a regulatory standpoint (BTW, just because I “get” something doesn’t necessarily mean that I am convinced that such claims are valid). What I don’t find as I travel the highways and byways of healthcare facilities is evidence that this process results in an enhancement of staff competence and knowledge. I don’t necessarily think of myself as a Luddite (in fact, I’m pretty okay with a lot of technology), but I don’t know that convenience is the yardstick by which we should be measuring the effectiveness of education. Rant over…

Before I hop along, I do have one favor to ask (and it sort of relates to the above). I understand that, from a sterile processing perspective, it is important to do some sort of enzymatic pre-treatment of soiled instruments so the OPIM doesn’t get all caked and hardened on the surface of said instruments. The favor (or question) is this: Has anyone identified a product that will appropriately pre-treat instruments but not require emergency eyewash equipment? If you have a risk assessment of that determination, that would be very cool. I’m running into another uptick in the proliferation of eyewash stations—I’m a great believer in having them when they are appropriate, but I’m no fan of eyewash stations “in case” (that sounds somewhat familiar…where have I seen that before?). Any feedback would be most appreciated.

Happy Mardi Gras for those of you disposed towards that kind of celebratory activity…

What’s the frequency, Kenneth?

In our continuing coverage of stories from the survey beat, I have an interesting one to share with you regarding my most favorite of subjects: risk assessments. During a recent FSA survey (what’s that, you ask? Why, that’s the nifty replacement for the “old” PPR process—yet another kicky acronym, in this case standing for Focus Standards Assessment), a hospital was informed by the surveyor that it was required to conduct an annual risk assessment regarding emergency eyewash stations. Now I will admit that I got this information secondhand, so you may invoke the traditional grain of salt. But it does raise an interesting question in regards to the risk assessment process: Is it a one-and-done or is there an obligation to revisit things from time to time?

Now, purely from a contrarian standpoint, I would argue against a “scheduled” risk assessment on some specific recurring basis, unless, of course, there is a concern that the management of the risk (in question) as an operational consideration is not as easily assured as might otherwise serve the purpose of safety. If we take the eyewash equipment as an example, as it deals primarily with response to a chemical exposure, I would consider this topic as being a function of the Hazardous Communications standard, which is, by definition, a performance standard. So as long as we are appropriately managing the involved risks, we should be okay. And I know that we are monitoring the management of those risks as a function of safety rounds and the review of occupational injury reports, etc. If you look at a lot of the requirements relating to monitoring, a theme emerges—that we need to adjust to changes in the process if we are to properly manage the risks. If someone introduces a new chemical product into the workplace, then yes, we need to assess how that change is going to impact occupational safety. But again, if we are monitoring the EC program effectively, this is a process that “lives” in the program and really doesn’t benefit from a specific recurrence schedule. We do the risk assessment to identify strategies to manage risks and then we monitor to ensure that the risks are appropriately managed. And if they aren’t being appropriately managed…then it’s time to get out the risk assessment again.

Temper Temper(ature)

In the continuing pursuit of every possible question that could ever be asked about eyewash stations, there’s been some chatter recently (as well as some field encounters) relative to what is involved with the weekly operational testing of emergency eyewash equipment, particularly whether or not you have to verify the temperature of the flushing fluid. The “good” news is that while there is a requirement to periodically verify the temperature of the flushing liquid, that period is one that is some 52 weeks in length, so we can put that down for an annual visitation. Having said that, I’m thinking this might be a fine opportunity to cover the basic goals of the weekly test (I find there is frequently a bit of a gap in terms of front-line staff’s understanding of the reasons behind the testing).

Let’s start with the ANSI standard. The intent of the weekly activation from the ANSI perspective is to ensure that there is a flushing fluid supply at the head of the device and to clear the supply line of any sediment buildup that could interfere with flow (that’s why you do the test with the caps on – if the pressure isn’t sufficient to “pop” the caps, then there may be some blockage). Running the water also helps to minimize any contamination due to stagnant water.

Another common question is, “How long should I run the water?” The answer is “It depends.” I think we’ve discussed this before, but once more unto the breach: You have to consider the amount of water contained in the eyewash itself, and the water which is in all the sections of piping that do not form part of a constant circulation (a “dead leg” in the plumbing, as it were). Since water tends to be stagnant in these sections until a flow is activated, you need to run the device long enough to flush out all the stagnant water. This may take a little bit of figuring, but once you’ve figured out the time period, you should be good to go.

You also want to make sure that the eyewash equipment is completely accessible, the protective caps are in place, and someone hasn’t installed a cabinet over the device close enough to result in a head injury if someone tries to use the eyewash (don’t laugh – I’ve whacked my head more than once trying to fit my noggin into a confined eyewash. Yes, I realize that head trauma probably explains a lot, but that is an entirely different topic of conversation). Ultimately, it’s about making sure that if someone gets some bad stuff in their eyes, they have an appropriate means of responding to that exposure. Hopefully, it’s not something we need to use very often, but if we have the eyewash stations, we have to properly maintain them.

Shoo beedoobee – splattered, splattered!

In the never ending discourse on the subject of emergency eyewash stations, I’d like to take a moment to remind folks that it appears that the TJC surveyors have access to the ANSI Emergency Eyewash and Shower Equipment Standards and they have become very diligent in ferreting out (apologies to the ferrets in the audience – I don’t mean to offend) practices that are not consistent with the “recommendations” contained therein. And so, let me say this:

If your organization has chosen to maintain your emergency eyewash stations on a lesser frequency than weekly, then you had best conducted a risk assessment to demonstrate that you are ensuring the same level of safety that you would if your were maintaining them on a weekly basis. Water temperature, water pressures, “cleanness” of the flushing liquid, whether access to the equipment is obstructed – these all need to be considered in the mix, because, and I can tell you this with a great deal of certainty, if you are doing these inspections less than weekly, you will be cited during survey. If you have not conducted the risk assessment to demonstrate that the lesser frequency is appropriate, then you will have to move to the weekly program. (Sort of a “you can pay me now or you can pay me later” kind of deal.) But rest assured that eyewash stations are definitely in the mix, so make like a Boy Scout (do I really need to finish that thought? I didn’t think so…)

By the way, I’ve also caught wind of the invocation of AAMI standards when it comes to the placement of emergency eyewash equipment in the contaminated section of central sterile. (Also, don’t forget to keep those pressure relationships in check. Clean central sterile should never be negative to dirty central sterile). Now I will freely admit that I am not as conversant with the AAMI standards as I am with, say, OSHA standards, and perhaps even the ANSI standards dealing with this stuff. Again, the rhetorical question becomes: How many rocks do we need to turn over before we can safely determine that there isn’t some funky consensus standard lurking in the weeds that is not in strict concurrence with accepted practice? Why can’t these guys just get along…jeez!

In your eyes – the light, the heat … the chemicals?

A couple of weeks ago, a client was asking me about who should be performing the weekly checks of eyewash stations. A clinical surveyor consultant had given them the impression that this should be the responsibility of maintenance staff. Now, I’m not sure if this direction was framed as a “must” or a “would be a good idea,” but what I can tell you is that there is no specific regulatory guidance in any direction on this topic. I do, however, have a fairly succinct opinion on the topic—yeah, I know you’re surprised to hear that!—which I will now share with you.

Certainly we want to establish a process to ensure the checks will be done when they need to be done. I agree that maintenance folks are typically more diligent when it comes to such routine activities than clinical folks often are. However, from an end-user education standpoint, I think it is way more valuable for the folks who may have to use the device in the area to actually practice its operation. If they do have a splash exposure, they would have a moderately increased familiarity with the location, proper operation, etc., of the device. Ideally, the eyewash will never have to be used because all our engineering controls and PPE will prevent that splash (strictly speaking, the eyewash is a last resort for when all our other safeguards have failed or otherwise broken down.

I’m also a believer (not quite like Neil Diamond, maybe more like Smashmouth) that providing for the safety of an organization is a shared responsibility. Sure, we have folks who call ourselves safety professionals help guide the way. But real safety lives at the point of care/point of service, where everyone works. So it’s only appropriate that each one of us take a piece of the action.