Emergency Eyewash Compliance: Putting it All Together

As the safety expert, you are tasked with understanding and complying with OSHA and ANSI guidelines for emergency eyewash. This may seem daunting but, in reality, it is quite simple with all of the support available from manufacturers and compliance professionals.

In 2005, 784 citations were issued to companies that did not have eyewash stations in close proximity to employees, according to a report published by OSHA. Another 1,124 citations were also issued to companies that did not provide employees with hazard information and training. In total, penalties for the two reached nearly $800,000. With these harsh realities it is critical to understand compliance goes beyond just having the right equipment. This requires a balance of knowledge, education, training and maintenance steps to support emergency eyewash programs.

An onsite hazard assessment is the first step that must be taken. Particular attention should be paid to areas where workers come in direct contact with chemicals. As a rule of thumb, eyewash stations are required if work environments contain paint, solvents, battery charging stations, hazardous chemical storage, tool parts washers or chemical pumping/mixing areas. If employees are using chemical-resistant gloves, cartridge- or air-supplied respirators, chemical-resistant goggles or flammable storage containers, emergency eyewash stations are most likely required.

The easiest way to identify if an eyewash station delivering 15-minutes of flushing is required is to review the Material Safety Data Sheets (MSDS) under the first-aid section during your assessment. Dangerous chemicals and substances will note that irrigation of the eyes for 15-minutes is a requirement and therefore signal the need for adequate eyewash stations.

A solid understanding of the ANSI standard will enable companies to make the best decisions when selecting an emergency eyewash station.
Emergency eyewash stations that meet the OSHA and ANSI guidelines and can deliver flushing fluid to the eyes for at least 15 minutes are often referred to as Primary Eyewash Stations. For complete ANSI eyewash guidelines, refer to the ANSI Z358.1-2004 Standard.

When choosing an eyewash station, there are two types to be familiar with: plumbed and self-contained portable stations. Plumbed and portable stations differ in features and overall flushing solutions that they deliver. It is important to be familiar with both to understand the pros and cons of each system and to make informed decisions. Investment cost, flushing solution, maintenance requirements and ease of use should all have an impact on the final decision.

The Choices:
Plumbed stations are permanently connected to a source of tap water. Their greatest attribute is the ability to deliver plentiful amounts of flushing fluid. However, the water quality is only as good as the source it is drawn from. Therefore, if the water source is contaminated then the flushing water drawn from this unit will also be contaminated. These stations must be connected to fixed plumbing and are expensive to install and impractical to move.
Portable eyewash stations contain their own flushing fluid and do not require fixed plumbing. Therefore, these eyewash stations are great for changing work environments or locations where plumbing is not readily available. Portable eyewash stations can be divided into two types: tank-style and sealed-fluid cartridge systems.

The solution in the tank-style unit can be either a mixture of water and additives or water plus a buffered saline mixture to help ensure safe flushing. Mixing and measuring is a requirement to achieve the right balanced flushing solution.

Today, factory-sealed cartridges that require no mixing and contain a purified, buffered saline solution, free of bacteria or contaminations for 24 months, have become a popular choice. These are factory-sealed and contain a flushing solution never exposed to harmful contaminants in the air or work environment. Sealed-fluid cartridge systems are the most recent advancement in the emergency eyewash category.

Knowledge of the standards coupled with a dedicated program of training and education for employees is an essential ingredient to any compliance program.
Training should be given to all workers. Never assume workers are already aware of proper procedures. Before emergency occurs, employees must know what an emergency eyewash station is, when it should be used and where the closest one is located.

Without proper maintenance, which includes inspection, care, cleaning and repair; the effectiveness and functionality of the eyewash station cannot be assumed.

Plumbed units require weekly maintenance. According to ANSI, plumbed eyewash units should be activated weekly to flush out sediment build-up and dangerous microbial contaminants in the pipes. Maintenance of multiple eyewash units can represent a substantial labor and cost commitment to ensure each eyewash station is flushed and checked for usability.

Self-contained units require maintenance according to the manufacturer’s instruction. That typically involves cleaning and changing the flushing fluid as often as every week with untreated tap water, to every six months with tap water mixed with an additive.

Unlike plumbed fixtures or other self-contained portable systems, which require frequent maintenance and measuring and mixing of the solution, sealed cartridges last up to two years and take less than five minutes to replace. Virtually no maintenance other than visual inspection is necessary over the course of the two-year shelf-life to ensure that the cartridges are intact and not activated.

Complying with OSHA and ANSI is a necessary part of ensuring employee safety and avoiding a fine for non-compliance. Of course, prevention is the first step to keep employees safe from eye injuries, but just as important is having a system in place should injury occur. That means not only having emergency eyewash stations available, but also having employees who are educated and trained in their use and maintenance. Help is out there; ANSI (www.ansi.org), OSHA (www.osha.gov) and The International Safety Equipment Association (ISEA) (www.safetyequipment.org) all provide compliance support. Local manufacturers and distributors are also there to answer questions and help with hazard assessments.