I appear to have hit a high interest subject with my eyewash question.
There were 28 responses in 2 hours, with a variety of them appended
below. I included those some that included information from OSHA and
other public domain sources or other key insights into the questions
raised.
Fortunately, not everyone agreed on the exact answer, which indicated
it wasn't as simple a question as I thought it might be. ;)
Thanks to all that responded.
- Ralph
From: Beth Shepard
Date: January 27, 2009 1:37:18 PM EST (CA)
Subject: Re: [DCHAS-L] Eyewash / shower flushing frequency
You could discuss the issue with your Microbiology Dept. or Limnology
(if you have one). =46rom what I remember, they have students running
cultures & identifications as their labs. They might be happy to have
a real world example for their students. These wouldn't be certified
results, but you could use the results generated to evaluate whether
or not it is worth the $400/fixture price.
Beth
Beth Shepard / Technical Compliance Specialist
Regulatory Compliance
6000 N. Teutonia Ave. / Milwaukee, WI 53209 / USA
P: (414) 438-3850, x5471
sigma-aldrich.com
===
From: "Erik A. Talley"
Date: January 27, 2009 1:39:25 PM EST (CA)
Subject: Re: [DCHAS-L] Eyewash / shower flushing frequency
That research has already been completed. See the article "Isolation
of amoebae and Pseudomonas and Legionella spp. from eyewash stations"
in Applied and Environmental Microbiology (attached). It's useful in
showing the need to regularly flush eyewash stations.
Regards,
Erik
===
From: "Harry J. Elston"
Date: January 27, 2009 1:39:53 PM EST (CA)
To: Ralph Stuart
Subject: Re: [DCHAS-L] Eyewash / shower flushing frequency
Ralph,
There was a paper about 10-14 years ago in one of the IH journals
(before the combining of the two) that talks about this. I don't have
it handy though.
The best I can do is pull up an abstract:
Quantitation of Free-Living Amoebae and Bacterial Populations in
Eyewash Stations Relative to Flushing Frequency
Authors: Elicia K. Bowman a; Arpad A. Vass b; Robert Mackowski c;
Bruce A. Owen b; Richard L. Tyndall b
Affiliations: a Midwest Technical Inc., Oak Ridge, TN 37830.
b Oak Ridge National Laboratory, Oak Ridge, TN 37831.
c University of Tennessee, Knoxville, TN 37921.
DOI: 10.1080/15428119691014684
Published in: journal American Industrial Hygiene Association Journal,
Volume 57, Issue 7 July 1996 , pages 626 - 633
Formats available: PDF (English)
Now published as: AIHA Journal
The circumstances under which this title is published have changed:
Reason for change: renamed
New ISSN: 1542-8117
Abstract
This study investigated the concentration of amoebic and bacterial
populations in eyewash station water relative to various flushing
regimens. Amoebae concentrations averaged approximately 200 amoebae/
100 mL in 13 of 15 stations positive for amoebae and consisted of
Hartmannella and Acanthamoeba. Bacterial concentrations ranged from
100 to more than 105 colony forming units per mL. Amoebic
concentrations differed notably between stations located in Buildings
X and Y (p<0.0001). Further study indicated that removal of diffusing
screens did not substantially change (p>0.05) the concentration of
amoeba. Amoebic and bacterial concentrations temporarily decreased
with the various flushing regiments tested. Lower amoebic
concentrations were not sustained by a weekly 3-minute or a monthly 1-
minute flushing regimen. However, weekly 3-minute flushes appeared to
be more effective in maintaining lowered bacterial concentrations
(p<0.0001).
Harry J. Elston, Ph.D., CIH
Principal
Midwest Chemical Safety, LLC
www.midwestchemsafety.com
===
rom: Lou Horton
Date: January 27, 2009 1:36:01 PM EST (CA)
Subject: Re: [SAFETY] Eyewash / shower flushing frequency
During my safety days in the precision glass and pharmaceutical
manufacturing industries, my experience was that flushing eyewashes on
a weekly basis was a necessity to prevent the initial shot of "rusty"
water. On the other hand, I think you could safely cut back to
monthly for safety showers. As for sampling for the presence of
various critters, I can't ever remember anyone requesting that as
"proof" of the proper flushing schedule.
Louis E. Horton
Project Engineer
Wyeth Pharmaceuticals, Inc.
Rouses Point, NY
===
From: "Diane Amell"
Date: January 27, 2009 1:56:37 PM EST (CA)
Subject: Re: [DCHAS-L] Eyewash / shower flushing frequency
We're still telling people that they should flush them weekly (as
opposed to "must" or "shall"). ANSI Z358.1 does say "shall" to "ensure
that there is a flushing supply at the head of the device and to clear
the supply line of any sediment build-up that could prevent fluid from
being delivered to the head of of the device and minimize microbial
contamination due to sitting water". I recall a conversation I had
with one of our IH group leaders some years back, where she had talked
about reading where Acanthamoeba can set up housekeeping in the
eyewash even if it is flushed weekly.
Oddly enough, this has been in debate in our office over the last month.
- Diane Amell, MNOSHA
===
===
From: Patrick A Ceas
Date: January 27, 2009 2:01:38 PM EST (CA)
Subject: Re: [DCHAS-L] Eyewash / shower flushing frequency
Ralph,
Before you go to the expense of such testing, why not just cite ANSI
Z358.1-2004 to your facilities & risk management folks. For all
plumbed eyewash and/or shower units, the following is stated:
"Plumbed equipment shall be activated weekly for a period long enough
to verify operation and ensure that flushing fluid is available."
You risk management folks should read this, and then I can't imagine
why they would not want to have you continue with your current
flushing schedule.
Pat
===
===
From: "Threlfall, Mike"
Date: January 27, 2009 2:08:38 PM EST (CA)
Subject: Re: [SAFETY] Eyewash / shower flushing frequency
In Washington, our WAC requires eyewashes be tested weekly.
WAC 296-800-15035
You must:
Make sure plumbed emergency eyewashes and hand-held drench hoses are
activated weekly to check the proper functioning of the valves, hardware
and availability of water.
So, from a requlatory standpoint, it is required weekly.
Mike
=0CFrom: John DeLaHunt
Date: January 27, 2009 2:10:45 PM EST (CA)
Subject: Re: [SAFETY] Eyewash / shower flushing frequency
Is ANSI 358.1 a standard of reasonable care? If so, and an eyewash
doesn't work during an emergency, is it a premises defect about which
the institution should have had material or constructive knowledge
("known or should have known")?
My impression of the weekly flushing is that it not only removes
whatever lightly adhered crusties might be on the eyewash head, but
also confirms operation.
In a different life, our practice for the chemistry labs was weekly
operation of eyewashes, and monthly operation of showers. In my lab,
itself, we performed eyewash flow tests every day that we handled
containers. This wasn't unreasonable, from my perspective - they were
my eyes, after all.
John
John DeLaHunt, MBA
Risk and Life Safety Manager
Environmental Health, Safety, and Risk Management Department
The University of Texas at San Antonio
One UTSA Circle
San Antonio, TX 78249
(210)458-4420 office
(210)458-7450 fax
john.delahunt**At_Symbol_Here**utsa.edu
http://www.utsa.edu/safety/
===
From: "Rominski, Hank"
Date: January 27, 2009 2:16:21 PM EST (CA)
Subject: Re: [SAFETY] Eyewash / shower flushing frequency
Ralph,
The requirement for weekly testing comes directly from the ANSI standard
on eyewashes and emergency showers, or at least an older version that I
possess.
In addition to the flushing of the pipes on a regular basis, you are
ensuring that this emergency equipment is operable.
Early in my career, I found an inoperable emergency eye wash in a chrome
plating shop. It had been disabled 6 months prior during some routine
plumbing work. Other times I have found missing diffusers, or clogged
lines. So it isn't just about the growth of microbes.
I'm wondering if you do set up biological testing, what criteria will be
used to determine clean vs. contaminated. And how will you prove it is
effective.
Regards
Hank
===
From: Carl Southwell
Date: January 27, 2009 2:31:13 PM EST (CA)
To: SAFETY**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [SAFETY] Eyewash / shower flushing frequency
The regulation, 29 CFR 1910.151, is actually vague. However, ANSI
Z358.1-2004 (Section 7.5.2), states, "Plumbed equipment shall be
activated weekly for a period long enough to verify operation and
ensure that flushing fluid is available." A note further states, "The
intent is to ensure that there is a flushing fluid supply at the head
of the device and to clear the supply line of any sediment build-up
that could prevent fluid from being delivered to the head of the
device and minimize microbial contamination due to sitting
water." [Of course, this is a guideline and not a requirement.]
Carl Southwell
Risk Management Consultant
City of Long Beach
333 West Ocean Boulevard, 10th floor
Risk Management Bureau
Long Beach, CA 90802
(562) 570-6714 ; (562) 570-5375 (fax)
E-mail: Carl_Southwell**At_Symbol_Here**longbeach.gov
Service First
Safety Always
From: Jeremy Yogerst
Date: January 27, 2009 2:31:50 PM EST (CA)
To: SAFETY**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [SAFETY] Eyewash / shower flushing frequency
The requirement for flushing eyewash / shower comes from the ANSI
standard - ANSI Z358.1-2004. This standard has not been adopted by
OSHA, but you all know how that can go when it comes to the general
duty clause.
There is a great free summary of the standard and checklist available
from Guardian Equipment at:
http://gesafety.com/downloads/ANSIGuide.pdf
Jeremy Yogerst
Safety Specialist
Bretford Manufacturing, Inc.
P - 847.678.2545 x 227
Fax - 847.678.5107
Safety is not an expense, it's the quickest way to a profit!
===
From: Ray Campbell
Date: January 27, 2009 2:46:44 PM EST (CA)
Subject: [SAFETY] Eyewashes
Ralph: This was cut from the OSHA website and may provide additional
direction for your original question.
OSHA Hazard Information Bulletins
December 23, 1986
MEMORANDUM FOR REGIONAL ADMINISTRATORS
THRU: JOHN MILES
Director
Directorate of Field Operations
FROM: EDWARD BAIER
Director
Directorate of Technical Support
SUBJECT: Health Hazard Information Bulletin: Potentially
Hazardous Amoebae Found in Eyewash Stations
Region VI has brought to our attention a Department of Energy (DOE)
bulletin indicating that Acanthamoebae, small amoebae capable of
causing serious eye infections, have been found in numerous portable
and stationary eyewash stations at several DOE facilities.
The infections caused by Acanthamoebae are difficult to recognize and
treat and may result in loss of the infected eye. Acanthamoebae are
able to survive conventional water plant treatment regimens, and
clinical treatments with most antibiotics are ineffective against this
amoeba.
Control by chlorination of the water (with a free residual of 25 ppm)
has been tested and found to be effective in destroying Acanthamoebae.
However, corrosion of the equipment occurred in some of the stainless
steel eyewash stations. One-minute and three-minute flushings of the
units were also tested. One-minute flushing was not effective in
reducing the number of Acanthamoebae; three-minute flushings
drastically reduced the number of positive samples.
Acanthamoebae are ubiquitous in tap water. The water can be tested
using the method outlined at the end of this bulletin. In most
instances the number of amoebae present will not be significant, but
they proliferate in stagnant, residual water and then become
dangerous. Until other control methods are investigated, such as the
optimal level of chlorination, we recommend that the following DOE
guidelines be used:
1. Plumbed eyewash units should be flushed for at least three
minutes weekly to reduce Acanthamoebae and to verify proper operation.
2. Self-contained eyewash stations should not be used in areas where
a continuous source of potable water is available. They should be used
only in remote areas where installation of a portable water system is
not economically feasible. The water in self-contained eyewash
stations should be changed weekly.
3. In general, squeeze bottles should not be used except where the
hazard severity or distance from plumbed eyewash equipment requires
personal equipment at work stations for immediate flushing prior to
prolonged flushing at a plumbed or self-contained unit.
Compliance and consultation personnel should be aware of the
possibility that eyewash stations filled with or connected to portable
water supplies may be contaminated with the Acanthamoebae. Please
disseminate this information to Area Offices, State Plan States, and
Consultation Project Officers.
Method for testing water for Acanthamoebae:
i. Filter water samples through 1.2 micrometer cellulose membranes
ii. Invert filters and place on non-nutrient agar plates coated with
iii. Incubate at 37 deg. C for 2-3 days which is the time necessary
for amoebae outgrowths
iv. Observe trophozoites and cysts for morphology indicative of
Acanthamoebae.
===
From: "Harkin, Steve"
Date: January 27, 2009 2:44:52 PM EST (CA)
Subject: Re: [SAFETY] Eyewash / shower flushing frequency
Don't forget to check with the manufacturers Recommendations/
Requirements. They may exceed ANSI and or OSHA
Steve
Steven E. Harkin Certified Utility Safety Administrator
Lead/Senior Health & Safety Compliance Consultant
PacifiCorp
825 NE Multnomah, Suite 1700
Portland, OR 97232
Office 503-813-5084
Cell 503-780-0533
steven.harkin**At_Symbol_Here**pacificorp.com
Safety Professionals work hard so you can enjoy life!
"If you hold a cat by the tail you learn things you cannot learn any
other way." Mark Twain
===
From: John DeLaHunt
Date: January 27, 2009 2:54:07 PM EST (CA)
To: SAFETY**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [SAFETY] Eyewash / shower flushing frequency
Jeremy Yogerst writes:
The requirement for flushing eyewash / shower comes from the ANSI
standard - ANSI Z358.1-2004. This standard has not been adopted by
OSHA, but you all know how that can go when it comes to the general
duty clause.
According to their interp letters regarding ANSI Z358 and 1910.151(c),
OSHA may cite against 1910.151(c) for eyewashes and showers that don't
meet ANSI Z358.
"http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRET
ATIONS&p_id=24288"
| Question 2: Is OSHA informing its compliance staff to not
| issue a citation when an employer's eyewash and shower are
| no longer "suitable," i.e., in conformance with ANSI
| Z358.1-1998? If so, what is the rationale, since the eyewash
| or shower would no longer be "suitable" according to industry
| standards?
|
| Reply: OSHA is not telling its compliance staff to refrain from
| issuing a citation when an employer's eyewash and shower are
| unsuitable. If OSHA inspects a workplace and finds unsuitable
| facilities for quick drenching or flushing of the eyes and body,
| a citation under 29 CFR 1910.151(c) would be issued. When
| determining whether the eyewash or shower facilities are suitable
| given the circumstances of a particular worksite, OSHA may refer
| to the most recent consensus standard regarding eyewash or shower
| equipment, which would be the 1998 version of ANSI Z358.1, as
| well as other recognized medical, technical and industrial
| hygiene sources.
"http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRET
ATIONS&p_id=24119"
| Question 2: Would the citation (in the situation described above)
| be written under 29 CFR 1910.151 or under the General Duty Clause,
| Section 5(a)(1)?
|
| Reply: Since OSHA has a standard related to drenching/flushing
| facilities, any citation for the failure to provide suitable
| drenching/flushing facilities must be issued pursuant to 29 CFR
| 1910.151(c).
*shrug*
John
John DeLaHunt, MBA
Risk and Life Safety Manager
Environmental Health, Safety, and Risk Management Department
The University of Texas at San Antonio
One UTSA Circle
San Antonio, TX 78249
(210)458-4420 office
(210)458-7450 fax
john.delahunt**At_Symbol_Here**utsa.edu
http://www.utsa.edu/safety/
Previous post | Top of Page | Next post
