From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
Subject: Re: [DCHAS-L] Emergency Shower and Eyewash Temperatures
Date: Fri, 6 Jul 2018 17:13:24 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: CC778533-351C-44A2-BD17-DF29D340B021**At_Symbol_Here**ilpi.com
In-Reply-To <20180706122648.4a1b7c747c75ab54f90280e9d8251945.9e3db6935c.wbe**At_Symbol_Here**email05.godaddy.com>


Just so folks are clear on the relationship between ANSI standards and OSHA:

If OSHA incorporates an ANSI, NFPA or other third party standard by reference (language using "shall" or some other mandatory term) then those standards have the same force and effect as OSHA standards.  

ANSI Z358.1 Emergency Eyewash and Shower Equipment is not incorporated by reference: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9806.  OSHA does refer people to the ANSI standard in various Interpretation letters and whatnot, but the standard itself if not enforceable.

HOWEVER, industry consensus standards that are not incorporated by reference *can* still be considered germane for issuing a citation under section 5(a)(1) of the OSH Act, also known as the General Duty Clause. That provision requires employers to "furnish to each of [its] employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to [its] employees."  I presume it might be difficult to argue tempered water might rise to that level for routine installations, however, if the employer's eyewash was a bucket of stagnant water, then a General Duty Clause citation could be assessed.

To complete the picture, an example of an ANSI standard incorporated by reference that is therefore enforceable by OSHA Is 29 CFR 1926.453, Aerial Lifts, which leads off with "Unless otherwise provided in this section, aerial lifts acquired for use on or after January 22, 1973 shall be designed and constructed in conformance with the applicable requirements of the American National Standards for "Vehicle Mounted Elevating and Rotating Work Platforms," ANSI A92.2-1969, including appendix."

Finally, it is also worth noting that any subsequent updates to an incorporated standard (the current version is A92.2-2015) are not enforceable. Only the specific version incorporated by reference is enforceable.  Yes, we are stuck in 1969 best practices because the law reads 1926.453-1969.

Rob Toreki

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On Jul 6, 2018, at 3:26 PM, mail**At_Symbol_Here**ECHELONENVIRONMENTAL.NET wrote:

Mr. Towle,

Back to the original question: "Are there any regulations surrounding eyewash and emergency shower temperatures?"

The answer is No.

OSHA (the regulatory body in our case) has a regulation at 29 CFR 1910.151(c) which requires eyewash/showers to be available where employees can be exposed to chemicals hazardous to the skin or eyes.  Nowhere in this rule is a temperature range specified for the water.

OSHA often refers to ANSI  [Z]358.1-2004 which does specify a temp range of 85 to 100F, but this is guidance only - not enforceable.

Guidance is good though, because if your employee has to use an ice cold or scalding hot eyewash/shower, your insurance company will be much displeased and their lawyer will be dancing all the way to the bank.

I hope this helps.  Good luck.


Ron Harvey
Echelon Environmental
843-599-0330

-------- Original Message --------
Subject: Re: [DCHAS-L] Emergency Shower and Eyewash Temperatures
From: Tyrell Towle <tyrelltowle**At_Symbol_Here**GMAIL.COM>
Date: Fri, July 06, 2018 11:23 am
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU

Thank you for your input, everyone!  This is a lot of great information for me to use moving forward.

Upon further inspection of our setup, there is a single mixing valve beneath each handwashing sink that feeds both the sink and the emergency eyewash.  Has anyone encountered this configuration before?  To me, it seems that there should be a separate mixing valve for the handwashing sink and the eyewash since they have different temperature requirements.

Anyway, thank you, again!

-Tyrell

On Fri, Jul 6, 2018 at 11:56 AM, Chance, Brandon <bchance**At_Symbol_Here**mail.smu.edu> wrote:
Also, remember that mixing valves fail.  I have had situations where mixing valves that served all of the units on a floor have failed on the hot side, resulting in a complete system having water above 120F.   We have asked our Facilities group to ensure the valves are part of the building preventative maintenance plan after we had to rebuild or replace a number of them. 


Regards,

Brandon S. Chance, MS, CCHO
Director of Environmental Health and Safety
Sustainability Committee Chair
Office of Risk Management
Southern Methodist University 
PO Box 750231 | Dallas, TX  75275-0231
T) 214.768.2430 | M) 469-978-8664

"=E2=80=A6 our job in safety is to make the task happen, SAFELY; not to interfere with the work-" Neal Langerman


From: ACS Division of Chemical Health and Safety on behalf of Penny Manisco
Reply-To: ACS Division of Chemical Health and Safety
Date: Thursday, July 5, 2018 at 6:14 PM
To: "DCHAS-L**At_Symbol_Here**PRINCETON.EDU"
Subject: Re: [DCHAS-L] Emergency Shower and Eyewash Temperatures

Hi All,

This is so weird because this exact thing happened in one of our newly renovated labs. A few weeks ago I was instructing students on flushing eyewash and safety shower and noticed the shower was scalding hot. The eyewash/shower had been installed last summer and has been fine all year.  I checked a second system in that lab only to find that the shower was not functioning at all. It turned out that someone (contractors remodeling a restroom perhaps?) had erroneously turned off the cold water valve that feeds the emergency equipment. That caused scalding water at one end of the room, and no pressure at the other. The eyewash and shower are fed with water from a mixing valve.

This is why we  check!

Best,

Penny Manisco
Chemical Hygiene Officer
Harvey Mudd College

On Thu, Jul 5, 2018 at 2:14 PM, Tyrell Towle <Tyrell**At_Symbol_Here**medpharmholdings.com> wrote:
Hello everyone,
 
This may seem like a basic question, but I am getting some pushback from our plumbing contractors on this.
 
We have a brand new facility and I went through to test all of the eyewash and emergency shower stations.  At first everything seemed to be working fine, but then I noticed that the emergency eyewash water was getting warmer.  I was horrified when the eyewash water became hot.  I have never encountered hot eyewash water before.  I had the contractors re-plumb the eyewash stations into cold tap water only.  Now they are pushing back, wanting to hook the eyewash stations back into the hot water.
 
I also noticed that our emergency shower is releasing hot water.
 
Are there any regulations surrounding eyewash and emergency shower temperatures?  My understanding has always been to have cold, potable tap water running into emergency showers and eyewashes so that chemical reactions are not accelerated upon exposure to heat.  Regardless, with the temperatures that our eyewash stations were reaching, there was no way that anyone could keep their eyeballs open for 10 minutes in this water.  Any information is appreciated, especially information that will put this debate to rest.
 
Thank you!
 
Tyrell R. Towle, Ph.D.
Senior Chemist
MedPharm Holdings, LLC
www.medpharmholdings..com
 
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--
Penny Manisco,
Chemical Hygiene Officer
Harvey Mudd College

(909)6074217
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