Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

August 16, 1976

Mr. John W. Trollen, Manager
Sanitation, Safety and Fire Safety
Hormel Foods
P.O. Box 933
Austin, Minnesota 55912

Dear Mr. Trollen:

This letter is in further reply to your letters of March 4, 1976 and December 31, 1975, concerning our regulation CFR 1910.151(c). I refer also to our phone conversation of March 24, 1976.

1. Battery charging areas are not specifically mentioned in CFR 1910.151(c) but are considered to be covered if the battery caps are removed and if electrolyte acid is added, removed, or spilled. If the battery is simply undergoing charge, it is not necessary to have quick drenching or flushing facilities for the eyes or skin.

2. In the strictest sense, quick drenching or flushing of the eyes can be done in some cases and in a limited and perhaps insufficient way with "neutralize" solution. You have agreed that such solution should be clean and should be changed at least weekly. May I suggest that where you use "neutralize" solution that you show the date it was last changed or replenished. The intent of our standard is to provide adequate first-aid for eye or skin splashes of harmful acids or alkalis. The water or solution should obviously be of adequate quantity, quality, and at an acceptable temperature. I would suggest that it should be between 105 deg. F and 60 deg. F. If only one water supply is available, then the "cold" water line is preferable to the "hot" (which might cause skin burns). This is not a requirement to temper cold water. It is a (text missing) We do not dispute Dr. Poser's statements or findings on "neutralize."

The way to accomplish your objective is to petition the Assistant Secretary of Labor, Dr. Morton Corn, to amend CFR 1910.151(c) and suggest wording as you would have the standard read. Remember, please, that the requirement must cover many types of worker exposures, not just in meat processing, as at Hormel.

Portable eye washing stations are acceptable if the water or solution is clean and of adequate amount to neutralize or flush away the acid or alkali. A bottle of "neutralize" would not be acceptable in very hazardous exposures. The 15 minute flushing time is not now a requirement, but if you look at the labeling requirement in our proposed standard for ammonia (enclosed) you will see 15 minute flushing as a part of the labeling requirement. You may state your views on this matter as detailed in the proposal. There is no requirement for weekly or monthly changing of "neutralize". The Communicable Disease Center of Health, Education, and Welfare has proposed weekly changes. This is acceptable to OSHA. The intent is that the solution be clean enough to use in the eye.

It would not be necessary to have an eye wash fountain or deluge shower for a janitor using "Dutch Cleanser" bowl cleaner or a general purpose cleaner. The regulation is meant to cover strong acids and alkalis. Detergents used on the "kill floors" would not require emergency eye wash fountains or emergency showers.

The five gallon stainless steel tank etc. you described in your letter of December 31, 1975, is acceptable to OSHA as meeting the requirements of CFR 1910.151(c), in your case.

We are still at a loss as to what you mean by "credit for using neutralize." It will be acceptable in certain situations and in others such as open tanks of strong acid or alkali it would be insufficient. You have indicated that this has been your policy also. If by "credit" you mean that OSHA should consider "neutralize" as totally meeting the requirements of CFR 1910.151(c) in all cases, the answer is no. Our requirement depends on the exposure and the strength of the hazardous chemical in each separate case.

I believe that this covers the issues in your inquiry. This letter is being sent to all OSHA offices for guidance. Please feel free to petition the Assistant Secretary of Labor to amend the standards, feel free to request a variance, or ask for clarification or an interpretation, at any time.

Your interest is appreciated and thank you for calling this matter to our attention.


Charles R. McClure, Chief
Division of Occupational Health Programming