Eyewash and shower devices are installed in the work environment to provide emergency first aid when an employee is exposed to hazardous substances. These substances, which may be present in solid, liquid, powder, mist or vapor form, can cause severe injury if the substance contacts the eye or skin of the employee.
Like other emergency devices (fire extinguishers, for example), emergency eyewash and shower equipment generally finds infrequent use. However, when there is an emergency, we rely on these devices to perform. If, for any reason, there is a failure to perform, the consequences are usually very serious.
For example, a chemical burn of the eye is an emergency situation requiring immediate first aid to limit damage that could lead to vision loss. Medical experts agree that the most important first aid procedure for the chemically burned eye is copious irrigation within seconds after the exposure. When chemically burned eyes are flushed promptly, studies have shown that patients require less surgery, have shorter hospital stays and experience more-rapid recoveries.
OSHA regulations require employers to provide emergency first aid when a potentially hazardous chemical is present in the workplace. OSHA medical services and first aid standard 1910.151(c) states, "Where the eyes or body of any person may be exposed to injurious corrosive chemicals, suitable facilities for quick drenching of the eyes and body shall be provided in the work area for immediate use." OSHA defines "exposed" as "an employee (who) is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption) and includes potential (e.g., accidental or possible) exposure."
There is a close link between OSHA's first aid standard and its hazard communication standard, 1910.1200. Compliance with the hazard communication standard is the key to the first aid standard requiring suitable equipment for quick drenching of the eyes and body. In fact, an OSHA standards interpretation and compliance letter references both standards in a written clarification letter. That letter states:
"Under the provisions of OSHA's Hazard Communication Standard [29 CFR 1910.1200(g)], employers are required to have a material safety data sheet (MSDS) in the workplace for each hazardous chemical which they use. The MSDS provides information you need to ensure proper protective measures are implemented prior to exposure, including emergency and first aid procedures" (emphasis added).
The hazard communication standard (HCS) requires employers to evaluate hazards and communicate information about those hazards to employees. That communication is to include:
- Identities of chemicals in the workplace;
- Hazards, both physical and health, of those chemicals;
- Protective measures to be used; and
- Proper work practices.
Most chemicals used in the workplace have some hazard potential that is communicated to employers through information in MSDSs or on product container labels. An MSDS, usually in the first aid section, will state the requirements for emergency flushing of the eyes or body.
In the last three annual reporting periods, OSHA reports show that violations of the hazard communication standard and the first aid standard pertaining to an eyewash or an emergency shower not in near proximity were two of the most frequently cited violations during agency inspections.
Eyewash Shower Survey
Because chemical burns, especially to the eyes, require urgent, effective first aid, emergency eyewash stations must be located near the hazard, have unobstructed access and be properly maintained so the station is ready for use in an emergency.
What steps should employers take to ensure that these important first aid devices are available for emergencies and the company is in compliance with regulations? Fendall Co. developed an Eyewash/Shower Plant Compliance Survey to help employers determine if their facilities and eyewash units are in compliance with OSHA and American National Standards Institute (ANSI) standards. The survey includes four elements:
1. Review first aid requirements as established by MSDS sheets on file at the facility.
2. Identify potential hazards that require eyewash or shower equipment through a tour of the facility.
3. Evaluate the condition and performance capability of installed emergency eyewash (plumbed and gravity-fed) stations and showers.
4. Assess the quality of flushing fluids used in emergency eyewash units.
The ANSI Z358.1-1998 standard for emergency shower and eyewash equipment establishes minimum performance and use requirements. The standard also addresses installation requirements, test procedures, maintenance of installed units and training of employees in the proper use of eyewash and shower equipment.
In 1999, Fendall teams surveyed approximately 200 U.S. manufacturing facilities. These surveys were conducted with plant safety and operating staff and used a standard format and a survey document that recorded potential problem areas, service requirements and recommendations for additional eyewash or shower equipment. The completed survey was given to the company representative for follow-up and action.
Survey Identifies Problems
The survey identified a need for additional eyewash units or showers at many of the survey sites. It also found serious problems with eyewash units installed at the same locations. More than a third of the stations inspected were inoperable or would not function properly. Why? Figure 1 lists the most frequent problem areas. Almost all are the result of improper maintenance.
During the initial plant surveys, we found evidence that flushing fluid in plumbed and self-contained eyewash stations was of potentially poor quality. A flushing fluid sampling procedure was added to our survey format to assess fluid quality. As part of the inspection, fluid samples were taken from self-contained and plumbed eyewash units (Note: Not all eyewash units were sampled.). Samples were collected in sterile containers, sealed and sent to an independent laboratory for testing. The flushing fluid sample tests documented problems in more than 50 percent of the samples:
- 60 percent had visible debris or coloration.
- Almost two-thirds had total plate counts above 500 cfu/ml.
- 58 percent contained the pseudomonas bacteria.
- 10 percent had a pH above or below the acceptable range.
Why is flushing fluid quality a problem? Particles in the flushing stream can impact and injure the eye. The presence of amoebae, bacteria and fungi in solutions used for emergency flushing of the eye, including water, poses a threat to injured eye tissue. Contaminants can obstruct nozzles, pressure-regulating devices, and pipes feeding plumbed units and filters, thereby restricting or limiting fluid flow.
Because there are several factors that individually, or in combination, create unacceptable levels of contamination in flushing fluid, quality of fluid in self-contained and plumbed eyewash and eye/face wash devices will fluctuate over time.
Proper Maintenance of Eyewash Device Essential
ANSI Z358.1-1998 requires manufacturers to provide operation, inspection and maintenance instructions and further requires that eyewash units be inspected and maintained in accordance with the manufacturer's instructions. Specific requirements for emergency eyewash units, according to Section 5.5.2 of Z358.1-1998:
- Plumbed eyewash equipment shall be activated weekly to verify proper operation and shall be inspected and maintained in accordance with manufacturer's instructions. Weekly activation of plumbed devices verifies proper operation and causes water to flow through the pipes feeding the device, bringing the pH and chlorine concentration to the level of the source water, if there is sufficient flow volume and flow time.
- Self-contained eyewash units shall be inspected and maintained in accordance with manufacturer's instructions.
As a general rule, self-contained units should be inspected weekly to ensure there is a proper level of flushing fluid and the unit activating device is intact. Self-contained units require periodic fluid changes.
When refilling a self-contained station that uses water or water with an additive, the station should be completely drained, disinfected and rinsed prior to being refilled and returned to service.
If the unit is filled with water only, the fluid should be changed weekly.
If the fluid is water with a preservative, the fluid replacement cycle can be as frequent as monthly or may go as long as four months. The fluid should be tested to determine the maintenance cycle, as local conditions (water, temperature range, environment) bear on the quality of the flushing fluid and the potential bacterial load of that fluid.
If the fluid is water plus a factory-prepared liquid concentrate with an additive, the same basic testing is required to determine the frequency of fluid change. Manufacturers recommend fluid changes in a range of three months to six months.
Preservatives used in water or a flushing fluid assist in controlling levels of bacteria. However, bacteriostatic additives currently in use are not effective against all bacteria. The ability of the additive to control bacterial population depends on several factors, including the initial bacterial load in the source water or in a biofilm inside the station.
Some units use flushing fluid cartridges, which are factory-sealed and require changing only at the cartridge expiration date (24 months from date of manufacture), unless the unit is activated. The fluid in these units does not require periodic testing, nor does the unit require cleaning and disinfecting of interior surfaces because the fluid is contained in replaceable, sealed cartridges.
If devices are not properly maintained, the flushing fluid (water in plumbed devices) remains stagnant for an extended period, significantly increasing the risk of contamination. A biofilm may form, attach to the inside surface of the water line or the self-contained device and continue to grow, providing a source of bacterial contamination that resists removal by periodic flushing. The presence of a biofilm increases the difficulty of controlling microorganisms in the water pipes to a plumbed station, in the components of the station and on the interior surfaces of a self-contained station. Treatment with biocides may not eliminate the biofilm.
Maintenance -- The Key to Performance
Are the emergency eyewash and shower units in your company ready to perform in an emergency? Is there an eyewash and shower maintenance program in place? Is that maintenance program being followed, or is maintenance being deferred or ignored?
If there are any doubts, do your own survey, testing each of the eyewash and shower units. Identify problem areas and implement a planned maintenance program. Use the eyewash and shower equipment manufacturer's manual and the ANSI Z358.1-1998 standard to prepare inspection and maintenance procedures. Replace or repair malfunctioning components or devices. Include an assessment of flushing fluid quality in your eyewash and shower equipment in the maintenance program.
Eyewash and shower units are emergency first aid devices, the bridge between a chemical exposure and medical care. Chemical injuries to the eye or skin can result in severe trauma, lost time and significant costs. A solid, well-managed emergency first aid program, which includes rigorous device maintenance procedures, is essential in dealing with these emergencies.
Robert B. Hurley is president of Fendall Co. Bob is an active member of ISEA -- The Safety Equipment Association, serving on the board of trustees. He also serves on Safety Equipment Distributors Association's board of directors and Prevent Blindness America's board of directors. Bob holds several patents for safety products.