Testing of Showers & Eyewashes
By: David Withee, Contributor
Test showers and eyewashes how often? Short answer: weekly. Middle answer: testing annually, activating weekly. Long answer: as often as needed to meet OSHA requirements and expectations for your circumstances.
OSHA Standard 29 CFR 1910.151 (C) words it simply: “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.”
The key word there is “suitable.” This leaves OSHA with plenty of leeway to take circumstances into account. This doesn’t give you the clearest direction, though.
For instance, showers and eyewashes are typically located at plumbing deadlegs with non-moving water, unless the equipment is activated. Since the water is also normally tepid (more on that later), this is likely to create a corrosive environment for the plumbing and could even create an environment conducive to bacteria and biofilm growth.
If someone needs to use an eyewash, do you really want rust to flow into their eyes—or, if using a shower, to have black gunk land on them? Activating showers and eyewashes weekly, long enough to ensure the water is clear, helps ensure your employees will be able to use the equipment safely and completely (and you will hopefully be in the good graces of OSHA).
What if the water isn’t tempered and is just cold? You want a victim to stay in the water for at least 15 minutes to wash away corrosive materials, not jump back due to the shock of cold water. If you have tempered the water, weekly activation ensures it is still tempered as soon as someone needs to use the shower or eyewash. The ANSI standard, Z358.1, requires “tepid” water, which is defined as above 60°F (160°C) and below 100°F (38°C).
“But,” I can hear you ask, “what if we haven’t had a single need to use an emergency shower or an eyewash in 20 years?!” Well, you know how the saying goes: “It only takes once.”
Do you want to explain to OSHA why you didn’t do the weekly activation? They will likely wonder what else you haven’t done to keep your employees safe. Do you really want them to wonder about that? Even if your emergency showers and eyewashes were installed before the latest—or any—edition of ANSI Z358.1, you don’t get a pass on safety issues. Equipment which doesn’t meet standards and a lack of annual testing and/or weekly activation are two strikes, where a single strike can be costly.
Let’s get back to the question of how often to test. OSHA will often refer people to ANSI/ISEA Z358.1 for guidance as to an industry consensus of what is needed in general. OSHA, though, may or may not accept meeting that standard when taking into account particular circumstances and incidents. The key is what have you done to make “suitable facilities.” Following the requirements of ANSI Z358.1 should at least show a good faith effort. ANSI requires weekly activation, so. . .
Besides, especially if you have an educational institution or healthcare facility, commissioning bodies are increasingly requiring ANSI Z358.1 be followed. Is losing your accreditation a risk you really want to take?
Now, the issue is often a matter of being able to activate showers and eyewashes easily and quickly, without making a mess. The mess is the challenge; no one wants to end up with water all over the floor. Laboratories are often built without drains to ensure chemicals don’t mix with community water systems. Water all over the floor really puts a crimp on their lab work. Healthcare facilities can’t afford to create circumstances which may create or exacerbate potential safety hazards and definitely don’t want to encourage the growth of biofilms, bacteria, mold, etc.
Industrial facilities don’t want to create safety hazards they are trying to avoid in the first place. Fortunately, several companies have developed products to help make weekly activation less of a challenge. You can minimize, and possibly eliminate altogether, the potential mess.
How often should you activate eyewashes and showers? The answer is as often as needed to meet what OSHA would require in your circumstances. Following ANSI Z358.1 guidelines and activating weekly is a good place to start.
[David Withee is Managing Director, Green Gobbler Safety, https://greengobblersafety.com/, 920-737-8477, email@example.com]
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