OSHA Instruction STD 1-8.2 March 8, 1982 of Compliance Programming

Subject: 29 CFR 1910.151(c), Medical Services and First Aid; 29 CFR 1926.50 and 51, Medical Service and First Aid, and Sanitation, Respectively; Applicable to Electric Storage Battery Charging and Maintenance Areas

A. Purpose. This instruction provides guidelines regarding eye wash and body flushing facilities required for immediate emergency use in electric storage battery charging and maintenance areas.

B. Scope. This instruction applies OSHA-wide.

C. Action. OSHA Regional Administrators/Area Directors shall ensure that OSHA field staff apply the requirements the subject standards to electric storage battery charging areas as set forth in E. of this instruction.

D. Federal Program Change. This instruction describes a Federal program change which affects State programs. Each Regional Administrator shall:

1. Ensure that this change is forwarded to each State designee.

2. Explain the technical content of the change to the State designee as requested.

3. Ensure that State designees are asked to acknowledge receipt of the Federal Program change in writing, within 30 days of notification, to the Regional Administrator. This acknowledgment should include a description either of the State's plan to implement the change or of the reasons why the change should not apply to that State.

4. Review policies, instructions and guidelines issued by the State to determine that this change has been communicated to State program personnel. Routine monitoring activities (accompanied inspections and case file reviews) shall also be used to determine if this change has been implemented in actual performance.

OSHA Instruction STD 1-8.2 March 8, 1982 Office of Compliance Programming

E. Guidelines. OSHA field staff will evaluate the potential circumstances for employee exposure to electrolyte(s) in electric storage battery handling, charging and maintenance areas.

1. The safety or health compliance officer shall document the following observations in the case file:

a. Employee use of personal protective equipment.

b. Type and chemical concentration of electrolyte(s).

c. Special guards and/or precautions intended to provide for employee protection from electrolyte exposure.

d. Based upon employee job functions, record the extent and type of probable employee exposure to electrolyte(s).

e. Note the availability and location of eye wash and body flushing equipment/facilities (An arrangement, which includes a hose equipped with a proper face and body wash nozzle, shall also be noted.)

2. The compliance officer and Area Director shall evaluate the data documented in E.1. Where potential employee exposure to hazardous storage battery electrolyte(s) exists, the circumstances and extent of exposure shall determine the application of the following alternatives:

a. The use of effective personal protective equipment in combination with an eye wash and body flushing station in near proximity to the work area(s), shall be deemed to provide adequate minimum protection for employees.

b. In areas where the extent of possible exposure to electrolyte is small, (i.e., such as auto garages, service stations and in certain industrial and construction situations), a specially designated pressure controlled and identified water hose equipped with a proper face and body wash nozzle which will provide copious amounts of low velocity potable water, or an

OSHA Instruction STD 1-8.2 MARCH 8, 1982 Office of Compliance Programming

appropriate portable eye wash device containing not less than one gallon of potable water which is readily available and mounted for use, is considered to provide minimum employee protection when proper personal protective equipment is used.

c. In addition to emergency eye and/or face wash procedures, the employer shall ensure that adequate provisions have been established for the emergency care of employees exposed to eye or face contact with electrolytes.

d. At construction sites and in commercial and manufacturing facilities at locations where powered industrial trucks are parked for overnight storage and routine battery recharging only, no need for emergency facilities exists unless potential exposure to electrolyte is substantiated. Where exposure is possible (i.e., servicing batteries) the provisions of E.2.b and E.2.e. should be evaluated for applicability.

e. At construction sites and in commercial manufacturing facilities where batteries (such as industrial truck batteries) are serviced and handled, proper plumbed eye wash and body drenching equipment shall be available immediately adjacent to the work station(s) and within the work area regardless of the personal protective equipment required and used.

3. Where employee exposure to hazardous electric storage battery electrolyte(s) exists and minimum protection measures are not provided, citations shall be issued as appropriate for violations of:

a. 29 CFR 1910.151(b) or 29 CFR 1926.50(c), a person or persons adequately trained to render first aid shall be readily available in the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees.

OSHA Instruction STD 1-8.2 March 8, 1982 Office of Compliance programming

b. 29 CFR 1910.151(c) and as adopted by 29 CFR 1926.51, 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.

c. 29 CFR 1910.132(a) or 29 CFR 1926.28(a), personal protective equipment for eyes, face, head, and extremities, protective clothing and protective shields and barriers, shall be provided, used and maintained in a sanitary and reliable condition wherever it is necessary by reason of chemical hazards encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.

F. Background. 29 CFR 1910.151 (c) , Medical Services and First Aid, needs clarification regarding its applicability to the hazards of electric storage battery charging areas and the potential exposure of employees to electrolyte(s). There is a clear need to identify the extent and suitability of minimum acceptable eye wash and body quick drenching facilities which are available to potentially exposed employees. 1. The extent of potential employee exposure varies with workplace situations such as:

a. Employee functions.

b. Type of electrolyte(s) and concentration.

c. Type and size of batteries.

d. Facility layout.

e. Personal protective equipment used.

2. The need for eye wash and body quick drenching equipment varies with the factors noted in F.1. Therefore, judicious enforcement of the standard

OSHA Instruction STD 1-8.2 March 8, 1982 Office of Compliance Programming

should provide for an evaluation of the contributing factors relative to the potential hazardous exposure, and should permit appropriate minimum assurances for adequate first aid and subsequent treatment.

3. Various forms of eye wash equipment are available today. Many are of the portable or self contained wall mounted type which are limited in the quantity of water available for eye wash purposes, and usually do not provide for body drenching. This equipment may be used for compliance with 29 CFR 1910.151(c) only when it is not economically feasible to provide plumbed equipment and/or where the potential employee exposure to electrolyte(s) is determined to be slight.

4. Eye wash equipment should provide copious low velocity flow of portable water at a suitable temperature, generally between 60 degrees F and 105 degrees F.

Thorne G. Auchter Assistant Secretary DISTRIBUTION: National, Regional and Area Offices All Compliance Officers State Designees NIOSH Regional Program Directors

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