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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.
September 9, 1992
R. DAVIS LAYNE
PATRICIA K. CLARK, DIRECTOR
Interpretation of 29 CFR 1910.151(c) with respect to the OPTI-KLENS Eyewash Fountain
This is in response to your memorandum of July 24, on the subject matter.
The MET Electrical Testing Company, Inc., (MET), one of the National Recognized Testing Laboratories (NRTL's) accepted by the Occupational Safety and Health Administration (OSHA), has tested the OPTI-KLENS Eyewash Fountain.
The results of their test, #ESL0101, were issued August 19, 1992, and a copy is attached for your files. The conclusion states that the OPTI-KLENS Eyewash Fountain system complies with regulations of ANSI Z358.1, 1990 Edition. Although OSHA does not require NRTL verification on eyewash fountains, OSHA accepts satisfactory results of NRTL tests conducted on products as proof that the products meet recognized test standard requirements.
Your first specific concern was that two steps are required to operate the OPTI-KLENS Eyewash Fountain: turning on the faucet and then activating the unit. Since the conclusion of the NRTL test was that the OPTI-KLENS Eyewash Fountain can be activated in an average time of 0.78 seconds, the compliance officer may have to run time lapse tests to document a violation.
Your second stated concern was that the unit is connected in such a way that the injured employee may turn on the hot water. If injury to the eyes can be caused due to hot water, then a citation is appropriate.