Check your stopwatch to measure eyewash station needs

By: October 24th, 2008 Email This Post Print This Post

The topic of eyewash stations comes up a lot.

In general, the OSHA medical services and first aid standard requires eyewash stations in locations in which there is a risk of accidental exposure to corrosive or caustic materials.

There are definitely specific environments—high-level disinfection and processing areas for one—where I would be looking for eyewash stations, but only after looking at the chemicals involved.

The need to have an eyewash station in close proximity can be ascertained by looking at the chemical’s first aid instructions, either on the container or on the MSDS. If the first aid information indicates that an exposure to the eyes requires flushing for 15 or more minutes, then you need to have an eyewash station.

If the first aid instructions do not indicate a 15-minute or longer flush after exposure, then you do not “need” to have an eyewash station–though nothing’s stopping you from installing one.

By the way, those lovely little wall-mounted plastic bottles do not meet the standard for emergency eyewash as would be required for conditions noted above.

So, do you have hazardous substances requiring eyewash stations? If so what are they, and what safety measures do you have in place?

Comments

By Bruce Cunha RN MS COHN-S on October 30th, 2008 at 10:06 pm

A larger question we are dealing with is when is a drench shower needed? OSHA first aid standard says

“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”

We have showers in lab areas. What about in areas with gallons of high level disinfectants? Areas were housekeeping employees mix hazardous chemicals from a dispenser? How about in chemotherapy mixing and treatment areas?

Any advice on how to determine when a drench shower is needed would be appreciated.

By Steve MacArthur on October 31st, 2008 at 1:27 pm

Hello again Bruce

The simple/complex response to your question is a function of the classic application of the risk assessment process – what is the reasonable likelihood of a release and/or exposure for which a drench shower would be an appropriate emergency response. The important thing to remember in all of this is that drench showers and eye wash stations are for when everything else (engineering controls, PPE, etc.) have failed. The first example you gave of gallons of high-level disinfectants – how are the materials stored? Are the stored on pallets? shelves? Are the case or containers stacked in such a way as to minimize the likelihood of someone being engulfed in material? Is there some sort of spill containment involved that would result in “better” control of a release? These are all practices, etc. that would need to be considered in determining the need for drench shower and other emergency equipment (also check the MSDS for guidance). Hope this helps.

By Patricia Higazi on March 18th, 2009 at 8:06 am

Are drench showers required/advocated on all clinical laboratories? What about small off site laboratories that process minimal blood tests ?

By David LaHoda on March 18th, 2009 at 6:40 pm

Steve MacArthur, blog post author and safety consultant at The Greeley Company responds:

Ah, drench hoses! The terse answer to your question would be “no”, which is based more on your using “all” as the descriptor. Drench hoses have a very specific application when it comes to emergency response – an exposure for which you would need lots of water, and not a great deal of accuracy as far as specific body parts, etc. that you’d be drenching (and my inclination would be to look at a full-body emergency shower if you have an exposure risk that might require a lot of water to mitigate – I find that drench hoses are more useful when “applied” by someone else). Ultimately, the type of emergency equipment you want to have is specifically dictated by the exposure risks; generally speaking, the reasons we have eyewash stations, showers, and the like in clinical laboratories is not so much a function of the potential for exposure to blood or OPIM, but because of the types of chemicals that are used in that laboratories, that’s where you start to work towards eyewashes, etc. And so to the second question, if the only splash risk would be that of small amounts of blood or OPIM, then you probably wouldn’t need a plumbed eyewash station, shower, or drench hose, but you might want to provide folks in the area with some of those personal eyewash bottles (I’m not a big fan of those, but for every small exposures of blood, etc. they’d probably be OK). When it comes to what you might need because of the chemicals involved, check the MSDS for the materials being used – if the First Aid instructions for exposure response indicate flushing with water for 15, 15-20, minutes (basically anything that indicates a specific amount of time), that’s when you need to start looking at equipment with the capacity to provide that level of protection. By the way, in my practice, if you need to actually use an eyewash station, etc., then you’ve had a process breakdown somewhere – folks should be using PPE appropriate to the exposure risks – gloves, gowns, face shields, etc. This comes under the “ounce of prevention is worth a pound of cure” doctrine – you need to start this discussion by focusing on prevention.

By C. Y. Diggit on June 24th, 2010 at 2:20 pm

“The need to have an eyewash station in close proximity.”

What is the definition of “Close Proximity”?

I work in a hospital, if that helps.

By David LaHoda on June 24th, 2010 at 2:33 pm

OSHA references ANSI standards here which says eyewash stations must be within 10 seconds walking time and on the same floor level of an area where there is reasonable expectation of exposure to hazardous substances.

We have a number of eye wash units in our facilites and our research labs. Do these all need to be upgraded to meet the 1998 ANSI Standard?

By Kathy Covington on July 21st, 2010 at 9:52 am

We have an eyewash station within 10 seconds of our Chemotherapy Mixing room, but not actually in the room. Is this ok or do we have to have one in the room where we mix Antineoplastic Drugs.

By David LaHoda on July 21st, 2010 at 11:24 am

You could have a problem with door placement/use. ANSI/ISEA Z358.1-2009 identifies a door as a obstacle in the path. If the hazardous substance is not corrosive, one door that opens in direction of movement and is never locked is permissible. Click here for more information.

If the door(s) creates a non-compliant situation, an alternative to moving the eyewash station is to provide person eyewashes that could be used to supplement the emergency eyewash provision process. If you choose that option,make sure it is included in the training and document it.

Hi Dave. I think this is one of those topics that is really confusing for a lot of people.

The cost of an installing an eye washes with a tepid mixing valve really razes up the price of these units ($1500 plus installation). That is going to be somewhat expensive if you also have to go back and retrofit your existing units.

I also have some issues in that the manufacturers are selling eye wash units that state they are ANSI Z358.1 compliant, yet they do not provide tepid water. When I asked about this, one of the big manufacturers of eye washes told me. Well, the faucet does meet ANSI X358.1 standards, but you have to supply it with tepid water. I bet a lot of facilities are not understanding this and adding these in expecting that they would be meeting the ANSI standard.

I also did some research on why ANSA added in the tepid requirement. It appears there were two reasons. One; that a person who has to do a drench shower, would not stay in a cold shower long enough. The second, that some chemicals can react faster/stronger if exposed to hot water.

I see no issue in putting in tepid water systems for shower’s or for eye wash’s where the type of chemical is so corrosive that continuous flushing is needed.

But I have issues in that we have used eye wash units plumbed to cold water for 50+ years and I have not seen any good information that they were not effective. Most health care facilities I have seen, probably do need more eye wash units than they actually have. In a Clinical system like mine, we are talking about large numbers in that we have a multitude of departments that use disinfection agents that can cause eye injury.

One other point we found.

If you put a tepid valve system in; if the hot water were to fail, the unit would still operate on cold water. But if the cold water fails, the unit will shut down and not allow any water through. This is appropriate in that I would not want a person putting their eyes in hot water.

What is very unclear is what OSHA is going to look at. If we have a functional eye wash that meets all of ANZI Z358.1 but does not have tepid water, are we looking at a citation? Would it be more than deminimus?

By David LaHoda on July 21st, 2010 at 4:10 pm

Bruce: You are correct that the reason for the tepid temperature specification and I would bet that few MSDSs in healthcare settings reference temperature on the exposure/first aid settings. All this could be explained through a risk assessment.

Hey, wonderful blog you have here! Keep up the excellent work

By Marlene Zuckerman on November 23rd, 2010 at 11:01 pm

We are establishing an outpatient chemotherapy suite in close proximity to one of our nursing units. One of our major expenses is the eyewash station. We have plans for installation of the station when funding is available. Is it acceptable to begin using the suite using a portable eyewash unit until after the first of the year when funding will be available?

By David LaHoda on November 24th, 2010 at 9:55 am

Squeeze bottle emergency eyewash stations are usually not compliant because, used alone, they cannot provide the required flush time for exposures found on most MSDSs. They are mostly used as a emergency measure to get workers to a plumbed eyewash station.

Check you MSDS for how long a flush is required for exposure to eyes and mucous membranes. That flush time is what you are required to provide to be OSHA compliant.

By Debbie Miyashiro on January 25th, 2011 at 10:57 am

Can you tell me how often the drench showers need to be checked to make sure they are functioning properly?

By David LaHoda on January 25th, 2011 at 12:06 pm

The Complete Guide to Laboratory Safety has an excellent section on emergency eyewashes and showers. According to the Guide:

“The ANSI guidelines recommend that showers be inspected and flushed weekly, but the general practice is to check them monthly. To test the shower, attach a large plastic funnel to plastic tubing. Hold the funnel up to the showerhead and allow the tubing to drain into a bucket or floor drain. Turn the shower on for three minutes and then turn it off. Document the testing at the site of the shower or in a central location.”

What about Hospitals? Are they required to have eye-wash stations in areas where patients are cared for? I work at a hospital and a patient recently spit directly into my eye. It turns out the patients had MRSA of the mouth. I am now permanently partially blind in that eye due to the infection that set in. Immediately after the incident, I yelled at a nurse to direct me to an eye-wash station. The nurse responded that the hospital does not have eye wash stations. Because the hospital did not have eye wash stations, I had to find a sink, take my gloves off, wash my hand, and then splash as mush water as possible into my eye. It apparently didn’t help. Any advice would be appreciated!

By David LaHoda on March 21st, 2011 at 6:38 pm

Hospitals, similar to all businesses/employers, are required to have suitable emergency facilities for quick drenching or flushing of the eyes and body within the immediate work area where an employee may be exposed to injurious corrosive materials, according to the Medical and First Aid standard (1910.151). The interpretation of suitable facilities usually means plumbed emergency eyewash stations or showers.

The specific requirement for plumbed facilities under 1910.151 is not, however, applied by OSHA to blood or OPIM exposures. The Bloodborne Pathogen standard would apply to in those situations, and the standard does have provisions requiring employers to provide protection from and training for responding to exposures, when there is reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other OPIM that may result from the performance of an employee’s duties, but not specifically eyewash plumbed eyewash stations.

Whether it is reasonably anticipated that a MRSA-infected patient would spit in your eye is the matter up for interpretation.

My opinion is that it is not, and that the absence of an emergency eyewash station in that patient care area is not an OSHA violation.

Now, it is another matter if spitting and assaults were associated with that patient or in that patient care area. OSHA could analyze that chain of facts and determine the employer was not compliant in taking measures to protect workers.

Your employer however should have on hand personal eyewash devices, squeeze bottles for example, for such exposures and training for how to use them. After such an event, the exposure control plan should be amended to address, even such an unusual situation.

By Bruce Cunha on July 18th, 2011 at 10:11 am

Another example of the problems with the OSHA standards. The Bloodborn Pathogen Standard says

“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.”

Flush with water would indicate to me that you need an eye wash, although a flush bottle may work for this specific issue.

As you always point out Dave, a risk assessment is the first step to identifying need.

This would be one of those areas I do wish OSHA would revisit.

 

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