MIOSHA Publishes Revised Requirements for Emergency Eyewashes and Showers

I. Purpose: This instruction establishes policies and provides clarifications to ensure uniform enforcement and interpretation of MIOSHA standards requiring emergency eyewash/shower equipment.

II. Scope: This instruction applies agency-wide.

III. References:

A. American National Standards Institute (ANSI) Z358.1 - 2004 American National Standard for Emergency Eyewash and Shower Equipment.

B. Department of Labor and Economic Growth (DLEG), Michigan Occupational Safety and Health Administration (MIOSHA) Chemical Information Manual (CIM) as amended.

C. Department of Labor and Economic Growth (DLEG), Michigan Occupational Safety and Health Administration (MIOSHA) Field Operations Manual (FOM) as amended.

D. General Industry Safety Standard Part 21. / R408.12101 et seq., Powered Industrial Trucks.

E. General Industry Safety Standard Part 78. / R408.17801 et seq., Storage and Handling of Anhydrous Ammonia (1910.111).

F. Occupational Health Standard Part 306. / R325.51451 et seq., Formaldehyde.

G. Occupational Health Standard Part 313. / R325.51651 et seq., Methylene Chloride.

H. Occupational Health Standard Part 472. / R325.47201 et seq., Medical Services and First Aid.

I. Occupational Health Standard Part 526. / R325.52601 et seq., Dipping and Coating Operations.

J. Occupational Health Standard Part 554. / R325.70001 et seq., Bloodborne Infectious Diseases (BID).

K. Occupational Health Standard Part 621. / Rule 6310 et seq., Health Hazard Control for Specific Equipment and Operations for Construction.

L. P.A. 154 of 1974, as amended, Michigan Occupational Safety and Health Act, R408.1001 et seq.

M. Toxicology of the Eye, Volumes 1 and 2, 4th Edition (1993), W. Morton Grant and Joel S. Schuman.

IV. Distribution: General; Internet Accessible.

V. Cancellations: This instruction cancels Michigan Occupational Health Program Directive No. 93-4, Violations of Occupational Health Rule 4401(3), Rule 3220(9)(d), and 6310(6)(f); Facilities for Quick Drenching or Flushing of Eyes and Body.

VI. Contact: Martha B. Yoder, Deputy Director

VII. Originator: Douglas J. Kalinowski, Director
Michigan Occupational Safety and Health Administration

I. Purpose. This instruction establishes policies and provides clarifications to ensure uniform enforcement and interpretation of MIOSHA standards requiring emergency eyewash/shower equipment.

II. Scope. This instruction applies agency wide.

III. References.

A. American National Standards Institute (ANSI) Z358.1 - 2004 American National Standard for Emergency Eyewash and Shower Equipment.

B. Department of Labor and Economic Growth (DLEG), Michigan Occupational Safety and Health Administration (MIOSHA) Chemical Information Manual (CIM) as amended.

C. Department of Labor and Economic Growth (DLEG), Michigan Occupational Safety and Health Administration (MIOSHA) Field Operations Manual (FOM) as amended.

D. General Industry Safety Standard Part 21. / R408.12101 et. seq., Powered Industrial Trucks.

E. General Industry Safety Standard Part 78. / R408.17801 et seq., Storage and Handling of Anhydrous Ammonia (1910.111).

F. Occupational Health Standard Part 306. / R325.51451 et. seq., Formaldehyde.

G. Occupational Health Standard Part 313. / R325.51651 et. seq., Methylene Chloride.

H. Occupational Health Standard Part 472. / R325.47201 et. seq., Medical Services and First Aid.

I. Occupational Health Standard Part 526. / R325.52601 et. seq., Dipping and Coating Operations.

J. Occupational Health Standard Part 554. / R325.70001 et. seq., Bloodborne Infectious Diseases (BID).

K. Occupational Health Standard Part 621. / Rule 6310 et. seq., Health Hazard Control for Specific Equipment and Operations for Construction.

L. P.A. 154 of 1974, as amended, Michigan Occupational Safety and Health Act, R408.1001 et. seq.

M. Toxicology of the Eye, Volumes 1 and 2, 4th Edition (1993), W. Morton Grant and Joel S. Schuman.

IV. Distribution. General; Internet Accessible.

V. Cancellations. This instruction cancels Michigan Occupational Health Program Directive No. 93-4, Violations of Occupational Health Rule 4401(3), Rule 3220(9)(d), and 6310(6)(f); Facilities for Quick Drenching or Flushing of Eyes and Body.

VI. Contact. Martha B. Yoder, Deputy Director.

VII. Originator. This document was developed by the MIOSHA Consistency Committee for approval by Douglas J. Kalinowski, Director, MIOSHA.

VIII. Background. This instruction addresses the fundamental need for suitable facilities to quickly remove or dilute injurious or corrosive materials and in the case of human immunodeficiency virus (HIV) and Hepatitis B virus (HBV) research facilities, potentially infectious materials, from the eyes or body in the event of contact. The intent of these standards/rules is to prevent burns to the skin, damage to or loss of eye sight, and to minimize exposure to potentially infectious materials. Many acids and caustic materials in liquid, granular or powder form, and some organic materials are capable of causing damage to the body or eyes. Exposure to some biological materials can cause infection and disease. If employees may reasonably be expected to be exposed to these materials in their workplace, without regard to the use of personal protective equipment (PPE), facilities for quick drenching shall be provided for immediate emergency use.

IX. MIOSHA Standards Overview.

A. General Industry.
1. General Industry Safety Standard Part 21. / R408.12101 et seq., Powered Industrial Trucks.
2. General Industry Safety Standard Part 78. / R408.17801 et seq., Storage and Handling of Anhydrous Ammonia (1910.111).
3. Occupational Health Standard Part 306. / R325.51451 et seq., Formaldehyde.
4. Occupational Health Standard Part 313. / R325.51651 et seq., Methylene Chloride.
5. Occupational Health Standard Part 472. / R325.47201 et seq., Medical Services and First Aid.
6. Occupational Health Standard Part 526. / Rule R325.52601 et seq., Dipping and Coating Operations.
7. Occupational Health Standard Part 554. / R325.70001 et seq., Bloodborne Infectious Diseases.
B. Construction.
1. Occupational Health Standard Part 621. / Rule 6310 et seq., Health Hazard Control for Specific Equipment and Operations for Construction.
2. General Duty Clause, P.A. 154 of 1974, as amended, Michigan Occupational Safety and Health Act, R 408.1001 et seq.

X. Application of Standards.

A. In interpreting these standards/rules, injurious or corrosive materials will normally be considered to be caustic compounds if they have a pH of 9.0 or greater or acidic compounds if they have a pH of 4.0 or less in solution. Solid or liquid compounds in solution which would fall in the pH range outlined above will generally be considered as injurious or corrosive materials. Some materials may be technically classified as acids or caustic compounds but the level of corrosive action may be very low and contact with the eye or body would not be considered likely to cause injuries. For example, the washing of hands or face with soap or the use of a weak acetic acid in food preparation would not require emergency facilities of this type.
Some organic materials are also capable of causing damage to the body or eyes and are injurious.

Because HIV and HBV research laboratories deal with solutions containing higher viral titers than normally found in patient's blood, an emergency eyewash must be readily available in the work area.

B. The terms suitable facilities, quickdrench showers, acceptable facilities, appropriate eyewash facilities, emergency shower and eye-wash station, eye wash station, and facilities, as utilized in any of the specified standards/rules, shall be defined as a plumbed or self-contained emergency shower and/or eyewash equipment, or eye/face wash equipment, meeting the engineering design specifications of the American National Standard for Emergency Eyewash and Shower Equipment (i.e., ANSI Z358.1 - 2004).

C. Self-contained eyewash equipment (i.e., portable units) must be capable of delivering to the eyes not less than 1.5 liters per minute (0.4 gallons per minute) for 15 minutes. Self-contained emergency showers shall be capable of delivering a minimum of 20 gallons per minute for 15 minutes.

D. Although not considered a suitable eyewash/shower facility by the ANSI Standard, the industrial hygienist/safety officer (IH/SO) shall not issue a citation to an employer that has installed a cold water pipe carrying potable water at a pressure not exceeding 25 PSI, equipped with a quick opening valve and a hand-held drench hose or a standard hose at least 48 inches in length not smaller than three-fourths of an inch, as their emergency eyewash/shower unit.

The rationale for allowing this exception is based upon Occupational Health Part 526, Dipping and Coating Operations Standard [i.e., 1910.124(g)(2)]. When encountering this type of equipment, the IH/SO shall advise the employer of the inherent design deficiencies (e.g., requires two handed activation; difficult to flush both eyes simultaneously; and doesn't allow for two free hands to hold eyelids open) and recommend that plumbed or self-contained eyewash and/or shower facilities meeting ANSI Z358.1 - 2004 criteria should be installed. This recommendation should be placed on a safety and health recommendation form.

E. Personal wash units (e.g., 12 to 16 ounce bottles) do not meet the criteria of plumbed or self-contained eyewash equipment. These units are supplemental devices that support plumbed and/or self-contained units by delivering immediate flushing fluid to the eyes or body. Personal wash units shall have the capacity to deliver immediate flushing fluid without being injurious to the user. See paragraph J of this section for circumstances where personal wash units may be utilized.

F. The proximity of the emergency shower and/or eyewash facility shall be determined by the injurious or corrosive nature of the chemical(s) and/or its ability to cause tissue damage. ANSI Z358.1 - 2004 recommends the placement of emergency eye wash/shower equipment based upon a time response criteria. However, because this criteria can create the potential for confusion and debate (i.e., varying travel speeds), MIOSHA's policy is as follows:

1. 100 feet or less from the hazardous operation - For chemicals that are injurious or corrosive (pH > 2 and = 4 or pH = 9 and < 11.5).

2. 25 feet or less from the hazardous operation - For chemicals that are considered highly corrosive or capable of causing severe tissue damage.
a) pH = 2.0 or = 11.5.
b) Certain organic materials at concentrations known to cause severe tissue damage.

3. Readily available in the work area for HIV and HBV research laboratories (i.e., 100 feet or less).

4. The location of the shower and/or eyewash facility shall be easily accessible (i.e., no obstacles, closeable doorways, or turns) and should be clearly marked and well lighted.

G. Employers should inspect and maintain all equipment in accordance with the manufacturer's instructions. During MIOSHA inspections, IH/SOs shall determine whether equipment is functioning properly (e.g. adequate flow of clean water). If not functioning properly (e.g. rusty water, only one side working, etc.), the IH/SO shall recommend a citation for inadequate equipment.

H. If a SO desires assistance in assessing the need or adequacy of emergency eyewash/shower equipment, they may request the assistance of an IH.

I. Where exposure to ammonia occurs at a facility outside the scope of General Industry Safety Standard Part 78, Storage and Handling of Anhydrous Ammonia (1910.111), Occupational Health Standard Part 472, Medical Services and First Aid, applies.

J. Exceptions.

1. Battery Maintenance/Handling.
a) Emergency eyewash/shower facilities are not required in battery charging area(s) where the battery(s) is charged without removing the battery(s) from the equipment. If employees service the battery(s) (i.e., checking fluid levels and/or making additions) or remove the battery(s) for charging, this exemption does not apply.
b) In a retail establishment where employees transport batteries through the establishment, there must be an emergency eyewash/shower facility. In lieu of an emergency eyewash/shower facility meeting the distance criteria in this instruction, a personal wash unit may be kept to supplement their potential needs. However, the employees must be properly trained in accordance with the Hazard Communication Standard and wearing appropriate PPE. The main purpose of these units is to supply immediate flushing to the injured individual until they are able to proceed to an acceptable plumbed or self-contained emergency eyewash and/or shower facility.

2. Custodial/Housekeeping Activities. Custodial and housekeeping staff typically handle and may be exposed to chemical products that are injurious or corrosive. In lieu of an emergency eyewash/shower facility meeting the distance criteria in this instruction, a personal wash unit may be kept to supplement their potential needs. However, the employees must be properly trained in accordance with the Hazard Communication Standard and wearing appropriate PPE. The main purpose of these units is to supply immediate flushing to the injured individual until they are able to proceed to an acceptable plumbed or self-contained emergency eyewash and/or shower facility.

XI. Violation Documentation. When documenting violations for the lack of satisfactory emergency eyewash/shower facilities, the IH/SO shall, where appropriate, document the following information in the case file:

A. Type of hazard that exists (e.g., pH measurements when appropriate or other evidence),
B. Employee exposure route(s),
C. Employer knowledge of hazard (e.g., MSDS, etc.),
D. Frequency and duration of exposure,
E. Photographs of area, chemicals, PPE, evidence of exposure, etc.,
F. PPE being utilized by employees,
G. Alternative water source(s) in hazard area,
H. Verification of hazard communication training,
I. Interview statements, and/or
J. Relevant injury and illness history.

XII. Citation Guidelines.

A. Serious.
1. Highly corrosive materials (pH is 2.0 or less, or 11.5 or greater)
2. Highly injurious materials (methyl ethyl ketone peroxide [MEKP], etc.)
3. BID hazards in a HIV and HBV research lab.
4. General duty violations in construction utilizing the above criteria.
Exception: Where the IH/SO documents that proper PPE is being utilized, an alternate water source is present, the employee is properly trained in accordance with the hazard communication standard, and in the professional judgment of the IH/SO, serious physical harm to an employee is highly unlikely to occur, the violation shall be classified as other than serious.

B. Other than Serious. Corrosive materials (pH is >2 and =4, or pH is = 9 and < 11.5)

C. Grouping. Where there are violations of the emergency eyewash/shower requirements, PPE requirements, and/or hazard communication training requirements, involving the same hazard, the violations shall normally be grouped in accordance with the FOM.

Source: MIOSHA MIOSHA-STD-07-1R1 (1/04/08)

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