Code Update: Emergency showers and eyewashes

Posted: 2/7/2008

By Ron George, CIPE, CPD

President, Ron George Design & Consulting Services

Emergency showers and eyewashes are required by federal law - the U.S. Department of Labor, Occupational Safety & Health Administration (OSHA) Code of Federal Regulations - where workers can be exposed to hazardous materials in the workplace.

Section 29 CFR 1910.151(c) of the OSHA code has the following language: "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."

Basic requirements

The purpose of an emergency fixture is to provide flushing fluid to cool the skin, dilute any hazardous chemicals and flush the hazard from the skin. Following are the basic requirements for these fixtures.

The emergency fixture valve operation should be simple to operate in one second or less.
The velocity/pressure of the fluid is important and should be low enough to be non-injurious to the eyes or skin. If the pressure is too high, water will emit from the fixture at a high velocity and will be uncomfortable on burned skin or in the eyes. Flow regulators and verification of proper shower patterns and eyewash streams is important.
Emergency fixtures should be located within 10 seconds walking distance of a hazard and on the same floor level. (The average brisk walking pace is 5.5 feet per second, which would equate to about 55 feet in 10 seconds.
The path of travel from the hazardous area to the emergency fixture should be free of obstructions.
The area around an emergency fixture should be well lit, so that the user can clearly see the fixture.
Emergency fixtures should be identified with a highly visible green or yellow safety sign.

ANSI Z358.1-2004 Standard for Emergency Eyewash and Showers

The industry standard for emergency shower and eyewash fixtures is produced by the International Safety Equipment Association (ISEA) in accordance with the standards development requirements of the American National Standards Institute (ANSI).

The standard establishes testing, installation, performance and training criteria for equipment used for emergency treatment of the eyes and body and covers the following:

ANSI Z-358.1 Standard - Performance Requirements for Plumbed Emergency Showers

Minimum flow of 20 gallons per minute at 30 psi for 15 minutes to drench the user and wash away any chemical hazard. (Research shows that residual chemicals on the body require extended flushing of at least 15 minutes to ensure chemical removal in order to prevent chemical burns.)
Even distribution of flow through the showerhead
Eyewash should not be considered an obstruction

ANSI Z-358.1 Standard - Performance Requirements for Plumbed Eyewashes

Minimum 0.4 gpm at 30 psi for 15 minutes (The proposed ASSE Standard 1071 language does not correlate with this requirement; it has a much higher minimum flow rate. This should be addressed!)
Controlled flow to simultaneously flush both eyes
Eyewash nozzles protected from airborne contaminants with dust caps

ANSI Z-358.1 Standard - Performance requirements for Plumbed Eye/Facewashes

Minimum 3.0 gpm for 15 minutes
Controlled flow to simultaneously flush both eyes
Face ring/eyewash nozzles protected from airborne contaminants with dust cover/cap

ANSI Z-358.1 Standard - Performance Requirements for Plumbed Hand-Held Drench Hoses

Minimum 3.0 gpm for 15 minutes (Hand-held devices provide support for emergency shower and eyewash units but do not replace them.)

ANSI Z-358.1 Standard - Performance Requirements for Plumbed Combination Units

Each unit must meet individual performance requirements when all components (on a unit) are operated simultaneously.

ANSI Z-358.1 Standard - Simultaneous Operation

The unit shall be ... capable of supplying adequate flushing fluid to meet the requirements ... when all components are operated simultaneously ... and shall be positioned so that components may be used simultaneously by the same user."

The flow requirements for drench hoses were removed, since drench hoses are supplemental to the required fixtures.

The appendices of the Standard are for reference only. The information in an appendix cannot be enforced by the code officials; however, the information is in the standard and it can be contested in court if an owner feels a design professional or contractor did not comply with standard design or maintenance criteria given in the appendices.

Since OSHA requires suitable facilities for quick drenching and flushing of the eyes and body for emergency use and since the ANSI standard provides details on emergency eyewash and shower equipment, this standard is often the document used by OSHA compliance personnel when assessing safety and health conditions in workplaces.

Although the standard is not specifically referenced in the OSHA 29 CFR 1910.151 document, that does not mean that it cannot be enforced. The OSHA standard is older than the ANSI Z358.1 standard, so there was no document to reference at the time the OSHA requirements were published.

If there is an incident dealing with hazardous materials exposure, the Z-358.1 standard will be what everyone points to as the acceptable industry standard. Manufacturers recognize the importance and the impact of the standard, and many owners voluntarily comply with it. Others may roll the dice and not install emergency fixtures and hope that they will not have an accident that requires emergency fixtures. If they do not comply, I would not want to be in their shoes.

OSHA workplace inspections

OSHA workplace inspections are typically scheduled on a regular basis. Inspections may occur randomly without prior notice, or they may occur due to a complaint; they almost always occur due to a workplace injury accident.

OSHA penalties may be as little as a warning if the inspector happens to notice an unsafe condition during a routine inspection. If the violation is a repeat violation, or if someone is injured, and the facility is deemed unsafe, the penalty can include a monetary fine or even a facility shutdown. Employers, design professionals, contractors and owners may share in the liability, and they may be affected by fines and possible litigation for not complying with the OSHA requirements.

Water supply temperature concerns

The delivered flushing fluid temperature shall be tepid, not tempered. Tempered water was defined in the plumbing codes as follows: "Tempered Water - water having a temperature range between 85 and 110 degrees Fahrenheit." Because this temperature range is too hot for use in emergency fixtures, the term tepid, defined as follows, was substituted: "Tepid - moderately or slightly warm; lukewarm."

Tepid water prevents hypothermia, cools chemical burns, prevents chemical absorption, encourages safety equipment use, encourages the full 15-minute drench time and encourages the removal of contaminated clothing.

Tepid water system components include the following:

A heat source (water heater)
A blending unit (tempering valve with safety features)
A distribution system (piping, heat traced lines, recirculating lines)
Emergency fixtures (shower, eyewash)
Chiller units, if required for hot environments.

ASSE 1071

The American Society of Sanitary Engineering (ASSE) is in the process of developing Standard 1071- Temperature Actuated Mixing Valves For Plumbed Emergency Equipment that should include the following redundant safety features.

a stay-open cold water supply upon hot water failure
accurate control of the hot water (when only the eyewash is in use)
full flow cold water by-pass in the event of blocked flows

When emergency fixture water lines are exposed to extreme temperatures outdoors or high temperature systems or equipment indoors, water supplies can get very hot or very cold. The water flowing from the emergency fixture could be too hot or too cold to encourage proper use of the fixture. Heat sources can cause high temperatures in the cold water pipes and may include direct sunlight, boilers, space heaters, steam mains and heating hot water mains, to name a few. Cold weather or pipes routed through cold spaces or near outside air inlets can cause extremely low temperatures and lead to hypothermia if an adequate supply of hot water is not available to mix with cold water.

Owners should have their design engineers work with facility personnel to review each application and to select the proper emergency shower and eyewash equipment, including location, size of water heating equipment and type of emergency fixture thermostatic mixing valve with a cold water by-pass. The outlet temperature of the mixing valve should, ideally, be set at about 80 degrees Fahrenheit. The adjustment on the mixing valve allows the facility owner's safety personnel to adjust the outlet temperature to the desired temperature based on the requirements of the site safety or medical personnel.

Flushing emergency fixtures

Emergency fixture water is often in a dedicated piping system and may sit in the piping for long periods of time. It is recommended to perform weekly tests to verify proper operation of plumbed emergency equipment and to flush lines of rust and stagnant water. These weekly tests should be recorded on a testing and flushing tag located on each emergency fixture. Most manufacturers offer emergency fixture models that include stainless steel piping or copper distribution piping, which can eliminate or significantly reduce the amount of rust and bacteria that is common in galvanized pipes. The appendix in the Z-358.1 standard recommends annual flow tests to test for full flow and tepid temperature for the full 15-minute duration.

Americans with Disabilities Act (ADA)

ANSI Z358.1 does not specifically address ADA and ADA does not specifically address emergency fixtures. However, ADA/ABNSI A117.1 is a federal law, and an employer that has handicapped employees who work in an area subject to a chemical hazard should provide emergency fixtures that are suitable for employees in a wheelchair. Barrier- free emergency fixtures should include the following ANSI A117.1 requirements:

Minimum knee clearance
Extension from the wall
Maximum forward and side reach limit
Less than five pounds of force for activation
Maximum height of the eyewash

Designers should review the provisions of ADAAG and local accessibility regulations. There are several manufacturers that make units with under-fixture clearance and emergency shower pull rods designed to meet ADAAG and ANSI A117.1 height and opening force requirements.

Design and maintenance considerations

The following design and maintenance issues should be addressed:

Waste directing (necessary when there is no floor drain present)
Waste containing (curbs to contain contaminants when hazardous chemicals cannot drain to sanitary or leave the area)
Waste disposal according to local codes.
Alarm devices, including local or remote alarming (these are a good idea when emergency fixtures are in a remote area; an exterior light may flash or an audible alarm sound.)
Flow switch or proximity switch activation.
Remote annunciation wired
Remote annunciation radio signal
Stand-alone tempering systems (There are remote areas where instantaneous heaters can provide enough water for emergency fixtures to operate.)
Alarms (status indicators for pumps, valves, temperatures)
Cold or hot water rust plugs (limited dead legs, recirculation)
Pressure drops (booster pumps, pipe sizes)
Full compliance testing performed annually
Valves locked open to prevent inadvertent or intentional closing
Full flow cold water bypass loops

Training

Manufacturers should provide operation, inspection, and maintenance instructions with shower and eye wash equipment.

Instructions should be readily accessible to maintenance and training personnel.
Weekly test and flush should be performed on all plumbed units.
Inspection tags are recommended to document compliance with weekly testing and flushing.

Visit the Haws Corporation website for more info about emergency showers and eyewashes and to see the wide variety of available products. www.hawsco.com