There seems to be a misunderstanding among facility owners and operators these days about requirements for emergency fixtures (eyewashes and drench showers). Plumbing codes do not prescribe when or where to locate eyewash fixtures. Rather, they address the installation of these emergency fixtures if or when they are required. The Owner is responsible for knowing and understanding their building program, sharing that information with architects and engineers during planning and design of new and renovation projects, and implementing safety protocols to keep building occupants safe. There are some important things to consider when thinking about where to locate emergency fixtures in your facility.
The Occupational Safety and Health Association (OSHA) is the governing body that has jurisdiction in this case. The OSHA regulation that applies reads as follows:
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.OSHA 29 CFR 1910.151.(c).
Considering that the terms “work area” and “immediate” are vague, one could argue that the location and quantity of eyewash fixtures could be left open to interpretation. However, OSHA looks to ANSI Z358.1, The Standard for “Emergency Eyewash and Shower Equipment”, when reviewing requirements for eyewashes and investigating your facilities. While OSHA does not officially adopt ANSI Z358.1, they consider it public knowledge available for the betterment of building safety programs, they expect you to do the same, and it serves as their roadmap when doing inspections and investigating incidents.
Emergency equipment must be installed within 10 seconds walking time from the location of a hazard (approximately 55 feet). The equipment must be installed on the same level as the hazard (i.e. accessing the equipment should not require going up or down stairs or ramps). The path of travel from the hazard to the equipment should be free of obstructions and as straight as possible.ANSIZ358.1
“Free from obstruction” and “straight as possible” are subjective terms and will be interpreted by the local OSHA duty officer who may inspect your facility or investigate an incident report. We spoke with a local OSHA inspector to discuss these terms and how these terms are generally interpreted. The inspector explained that doors are often overlooked when eyewash fixtures are planned for a facility. If a closed door is between the compromised/endangered employee and the emergency fixture, the travel time is significantly affected, and the eyewash must be closer than 55 feet. Your local OSHA inspector will not consider a path of travel that includes a doorway to be “free from obstruction”.
Please take the initiative to review your facilities and the placement of emergency plumbing fixtures. You may find some deficiencies and choose to add a few new emergency fixtures to meet the ANSI Z358.1 standard. Some day you may be glad you did. For more information, please do not hesitate to contact Jonathan B. Slagel, PE, LEED AP HFDP, at (717)-817-2277 or firstname.lastname@example.org.