Years ago, it was acceptable to factor loss of life into the planning for major public works projects like dams and bridges. In those days, safety in the workplace was an afterthought, if it was thought of at all. As personal safety became more of a focus, those unsafe conditions gave way to increasingly stringent current regulations and penalties for violations of those regulations.
There are good reasons for all of this scrutiny and concern: Per the National Safety Council, losses from unintentional worker injuries cost the U.S. economy over $650 billion dollars in 2006. Wage and productivity losses accounted for a whopping $330 billion of the total. And that doesn't include potential long-term disabilities, litigation costs and other losses associated with downstream liabilities.
This is a huge problem that put into perspective, is equivalent to 62 percent of the total revenue the government collects in personal income taxes each year or 52 percent of the total cost of feeding the entire population of the United States.
There were 110 million workers employed in the private sector in 2005. Of that number, there were 118,000 deaths from job related causes, with an additional 1.2 million reported non-fatal accidents, of which over 18,000 involved lost-time injuries due to chemical-related trauma. Almost 35,000 of the reported non-fatal injuries were due to injuries to the eyes. These figures do not include federal, state and local government employees or the self-employed.
In an attempt to better control this situation, there currently are very clearly defined operational safety protocols and preparation requirements to deal with incidents that could or do cause harm to employees. The availability of adequate first aid assets is a critical element of the plan for all businesses. Those assets most often are regulated by OSHA, using ANSI and other standards and guidelines.
ANSI Z 358.1
The ANSI standard for emergency showers and eyewashes is ANSI Z358.1, which was last revised in 2004. In its current permutation, it is the clearest and most useful tool for preparing to meet most workplace incidents necessitating the use of an emergency shower or eyewash. While this discussion does not attempt to interpret Z358.1, it will provide a checklist aimed to help assist safety personnel in understanding some of the significant requirements included in the standard.
It should be understood that compliance is not a once-a-year or once-a-month thing. Compliance is an all-day, every-day requirement. Accordingly, emergency showers and eyewashes are required to be activated weekly, with a more thorough evaluation on an annual basis. This requirement is established in Sections 4.6.2, 4.6.5 and others in ANSI Z358.1. Many companies today opt to have an outside, third-party inspection performed annually, which provides an added measure of credibility to the review process.
Beyond that, the following areas should be reviewed:
Emergency showers, eyewashes and combination showers/eyewashes must be accessible within 10 seconds, must be on the same level as the hazard and the travel path must be free of obstructions (Sections 4.5.2, 5.4.2, 6.4.2, 7.4.2).
Emergency shower, eyewash and combination shower/eyewash stations should be designated by highly visible signage (Sections 4.2, 5.2, 6.2, 7.4.3), positioned so that the signs are visible in all areas served by that specific equipment.
Control valves on emergency showers, eyewashes and combination shower/eyewash equipment should be designed to enable them to be moved from “off” to “on” in one second or less and to remain open until intentionally closed (Sections 4.2, 5.2, 6.2, 7.2).
Spray nozzle outlets on eyewashes and eye/face washes should be protected from airborne contaminants when idle. This should not require a separate motion (from equipment activation) to remove the protection for equipment use (Sections 5.1.3, 6.1.3).
Plumbed and self-contained eyewash equipment must be capable of delivering flushing fluid to the eyes at a flow of not less than 1.5 liters per minute (.4 gpm) for the full, required 15-minute irrigation cycle (Sections 5.1.6, 6.1.6).
For eyewashes, a means must be provided to ensure a controlled flow of flushing fluid to both eyes simultaneously (Section 5.1.1). With respect to eye/face washes, the standard includes both eyes and face (Section 6.1.6).
There should be a minimum distance of 6 inches between the eyewash outlet nozzles and any adjacent obstruction, such as walls, etc. (Section 5.4.4).
The proper heights for eyewash or eye/face wash heads is between 33 inches and 45 inches above the floor (Section 5.4.4).
Drench showers must deliver a minimum of 20 gpm flow (Section 4.1.4).
The proper height for drench shower or combination drench shower and eyewash shower heads is between 82 inches and 96 inches above the floor (Section 4.1.2).
Drench shower flow patterns should be a minimum of 20 inches wide at 60 inches above the floor (Section 4.1.5).
There should be no barrier closer than 16 inches from the center point of the installed emergency drench shower or combination shower and eyewash (Section 4.1.5).
Combination shower and eyewash equipment is subject to the same individual component requirements, even when those components are used simultaneously. Sufficient pressure and volume of fluid to “drive” both features is necessary (Section 7.4.4).
Combination shower and eyewash equipment must be capable of simultaneous use of the shower and eye or face wash by the same user (Section 7.4.4).
Flushing fluid must be tepid, which is between 60°F and below 100°F for the full, 15-minute use cycle (Section 7.4.4).
ANSI Z358.1 also establishes other requirements,but the ones noted here are the most commonly overlooked or the ones that are not followed.
Every month, there are published recaps of the OSHA violations processed and the fines levied against companies who neglect to live by the requirements. Fines usually are in the six-figure range!
Aside from the potential punitive regulatory assessments that are possible, there is the potential for negligence claims and litigation. For example, the company that was fined $213,000 a while back for, among other things, a “blocked eyewash,” might have gotten off easy compared to having an employee become permanently blinded due to that negligence.
Then there is the whole issue of tepid water, our final checklist item. The tepid water requirement has been in Z358.1 for some time now. Prior to 2004, it was left to interpretation as to what was the acceptable temperature range. In the 2004 revision, the standard was clarified to provide the specifics outlined here.
Tepid water is essential to assuring that an injured worker remain under the shower or submersed into an eyewash for the full, required, fifteen-minute use cycle. Cutting short the time risks a less-than-complete removal of the hazardous material, as well as failure to adequately cool the area affected by, for example, a chemical burn. Likewise, remaining in contact with the water supplied by most municipal authorities for that time can lead to hypothermia.
However, it is estimated that the vast majority of multiple shower and/or eyewash installations in the United States still do not provide tepid water. Forget about OSHA violations for a minute. Think about it from the standpoint of litigation by an employee after an accident: There is a frightening amount of risk still out there, in which the ANSI standard potentially could be used as the proof for a negligence claim.
Finally, technological advancements in emergency shower and eyewash designs should be considered, such as the launch of the AXION MSR eyewash and eye/face wash heads.
While traditional configurations for eyewash flow patterns spray water from the outside corners of the eyes inward, the medical community irrigates eyes in the opposite direction, with the flushing fluid entering the eye at the inner corner, moving outward on either eye, to avoid driving hazardous materials toward the lacrimal punctum (or the occual cavity's drains). Since the lacrimal punctum drain directly into the nasal cavity, doctors are concerned that the hazardous materials might be inhaled or swallowed. The design of the AXION MSR products inverts the flow pattern versus traditional eyewashes, duplicating the protocol used in emergency rooms and by EMTs.
Today, simply providing emergency showers and eyewashes isn't enough. We need to monitor their condition and the areas surrounding each shower and/or eyewash installation. And, importantly, we need to stay current with new technology in product features and designs.
Casey Hayes is the director of Engineering at Haws Corp. He can be reached at 775-353-8320 or [email protected]. For more information, visit http://www.hawsco.com or call 888-640-4297 to arrange a free, third-party inspection at your facility.