Our meeting topic is ANSI (ISEA) Z358.1 - 2009. Our Plumbing Code (IPC-2006) references the 2003 version of Z358.1. As you may know, the next Code 'Update' cycle is upon us and the 2009 Edition will be considered. Over the years, I had the opportunity to share some thoughts on the emergency showers and eyewashes. You may (or may not) recall communication with OSHA on the topic. OHSA requires emergency fixtures where there may be corrosive materials. OSHA will not provide a list of chemicals they consider corrosive - which just seems silly. So we have two basic questions with OSHA's responses in italic:
1. Where are emergency eyewashes and showers required?
The OSHA requirements for emergency eyewashes and showers, found at 29 CFR 1910.151(c) and 29 CFR 1926.50(g), specify: "Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use."
2. Is there a list of "corrosive" materials?
Although the standards discussed above do not define these terms, OSHA's Hazard Communication Standard is instructive. The standard at 29 CFR 1910.1200, Appendix A, defines a corrosive as:
A chemical that causes visible destruction of, or irreversible alterations in, living tissue by chemical action at the site of contact. For example, a chemical is considered to be corrosive if, when tested on the intact skin of albino rabbits by the method described by the U.S. Department of Transportation in appendix A to 49 CFR part 173, it destroys or changes irreversibly the structure of the tissue at the site of contact following an exposure period of four hours. This term shall not refer to action on inanimate surfaces.
Generally speaking, corrosive materials have a very low pH (acids) or a very high pH (bases). Strong bases are usually more corrosive than acids. Examples of corrosive materials are sodium hydroxide (lye) and sulfuric acid….
By almost any standard we might apply, OSHA has been unhelpful in clarifying where we need emergency fixtures. However, they will cite (fine) owners when they are not provided. This makes very unhappy owners (clients). Here is a recommended heuristic for where to provide emergency fixtures - If you think you might need one, you probably do. The NYS Plumbing Code requires:
"EMERGENCY SHOWERS AND EYEWASH STATIONS
§P411.1 Approval. Where required, emergency showers and eyewash stations shall conform to ISEA Z358.1."(2003 Edition)
Z358.1 is helpful in locating the fixtures where a hazard has been identified, flow rates of fixtures, durations of flow, and temperature of the water.
Fixtures are to be located so they can be reached within 10 seconds (or 55 feet) of the hazard. As a Code Enforcement Official, I like the 55 feet requirement since it can be enforced. We'll find out at the meeting if 55 feet, or just the 10 seconds, is the requirement. I suspect there will be lots of discussions on the other items at the June meeting.
The NYS Property Maintenance Code requires:
"§PM504.1 General. All plumbing fixtures shall be properly installed and maintained in working order, and shall be kept free from obstructions, leaks and defects and be capable of performing the function for which such plumbing fixtures are designed. All plumbing fixtures shall be maintained in a safe, sanitary and functional condition."
This should include the emergency fixtures. I have been to many buildings where the emergency fixtures have not been periodically tested per ANSI Z358.1. Most Code Enforcement Officials do not get to inspection buildings after they are built. In my opinion, owners are violating Z358.1 and the Property Maintenance Code by not testing and maintaining their emergency fixtures. If there is an injury and the closest emergency fixture has not been tested and does not work, folks with "esq." after their name will have a proverbial field day. Remind your clients to test their emergency fixtures.