BACK in the days when it was acceptable to factor loss of life into
the planning for major public works projects such as dams and bridges,
compliance to safety standards was an afterthought. As personal safety
became more of a focus, those unsafe conditions gave way to
increasingly stringent current regulations and deviation penalties.
Today, there are very clearly defined operational safety protocols and
preparation requirements to deal with inevitable accidents due to
neglect or other circumstances.
undefined Compliance is not a once-a-year or once-a-month thing. It is an all-day, every-day requirement.
Availability of adequate first aid assets is a critical element ofthe plan for all significant businesses. And those assets are most often regulated by OSHA, using ANSI's and other standards and guidelines. The ANSI standard for emergency showers and eyewashes is ANSI Z358.1, which was last revised in 2004. In its current permutation, it is the clearest and most useful tool for preparing to meet most workplace incidents.
While this discussion does not attempt to interpret Z358.1, it will provide a checklist of sorts aimed at assisting readers in understanding some of the significant requirements included in the standard. We will provide a basic outline of some of the major elements that must be met.
It should be understood that compliance is not a once-a-year or once-a-month thing. Compliance is an all-day, every-day requirement. Accordingly, emergency showers and eyewashes are required to be activated weekly, with a more thorough evaluation on an annual basis. This requirement is established in Sections 4.6.2, 4.6.5, and others. Many companies today opt to have an outside, third-party inspection performed for them annually, which provides an added measure of credibility to the review process.
Beyond that, the following areas should be reviewed:
Large Fines Are Common
There are obviously other requirements established by ANSI Z358.1,
but these are the most commonly overlooked or not followed. Every
month, there are published recaps of the OSHA violations processed and
the fines levied against companies that neglect to live by the
requirements. Fines are usually in the six-figure area! But aside from
the potentially punitive regulatory assessments that are possible,
there is the potential for negligence claims and litigation. The
company that was fined $213,000 last October for, among other things, a
"blocked eyewash" might have gotten off easy compared to having an
employee become permanently blinded due to that negligence.
Then there is the whole issue of tepid water, our final checklist item above. The tepid water requirement has been in Z358.1 for some time now. Prior to 2004, it was left to interpretation as to what was the acceptable temperature range. In the 2004 revision, the standard was clarified to provide the specifics outlined above. Tepid water is essential to ensuring that an injured worker remains under the shower or submersed into an eyewash for the full 15-minute use cycle. Cutting short on the required time risks a less-than-complete removal of the hazardous material, as well as failure to adequately cool the area affected by, let's say, a chemical burn. Likewise, remaining in contact with the water supplied by most municipal authorities for that time can easily lead to hypothermia.
So the tepid water requirement is a solid one. However, it is estimated that the vast majority of multiple shower and/or eyewash installations in the United States still do not provide tepid water. Forget about OSHA violations for a minute; think about it from the standpoint of litigation by an employee after an accident. There is a frightening amount of risk still out there in which the ANSI standard could potentially be used as the proof for a negligence claim.
Today, providing emergency showers and eyewashes isn't enough. We need to monitor their condition and the areas around them. Access and useability are the keys. Is your equipment up to date? Are you providing tepid water? Check yourself out or ask for an impartial, third-party assessment.
This article appeared in the March 2007 issue of Occupational Health & Safety.
About the author
Casey Hayes
Casey Hayes is the Director of Engineering at Haws Corporation, located in Sparks, Nev. He can be reached at 775-353-8320. Haws Corporation designs, manufactures, and distributes drinking fountains and emergency equipment. For information on the full range of ANSI-compliant emergency shower and eyewash products. To arrange a free inspection at your facility, call 888-640-4297.
You can visit the company Web site at www.hawsco.com/ep .