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 https://www.osha.gov.

October 10, 1990

Mr. Gary Allison, President
Desert Assembly, Inc.
718 Eugene Road
Palm Springs, California 92264

Dear Mr. Allison:

This is in response to your letter of July 24, addressed to Mr. Ray Donnelly, Director of the office of General Industry Compliance Assistance, requesting a letter from the Occupational Safety and Health Administration (OSHA) regarding the acceptability of your emergency eye and face wash products and their compliance with OSHA standards. Enclosed with your letter were copies of the reports from an independent consultant, who evaluated and determined that your products meet the applicable American National Standards Institute (ANSI) requirements.

The independent consultant's report verified that your products, eyewash unit (Opti-Klens I) and eye/face wash unit (Opti-Klens II), meet the requirements of ANSI Z358.1-1981, specified in paragraphs 5.1.1 through 5.2 and 7.1.1 through 7.2, respectively. Under the de minimis violation policy, copy enclosed, OSHA does not issue citations against products which meet or exceed industry consensus standards, such as ANSI Z358.1, if those standards are at least as effective as the applicable OSHA standards.

The products Opti-Klens I and Opti-Klens II provide for compliance with the requirements of OSHA standards with respect to emergency eyewash units, provided these units are installed, used, and maintained in a manner recommended by your company. OSHA does not approve or endorse products, since, otherwise safe equipment may be misused or misapplied by your customer. Therefore, acceptance can only be evaluated by a safety and health professional at the site of installation.

If we can be of further assistance, please contact us. Thank you for your interest in safety and health.


Thomas J. Shepich Director
Directorate of Compliance Programs