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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

June 21, 1994

Mr. Robert J. Burke
Manager, Sales and Marketing
Therm-Omega-Tech, Inc.
207 Witmer Road
Horsham, Pennsylvania 19044-2212

Dear Mr. Burke:

Thank you for your inquiries of April 12, and April 20, requesting clarification of requirements for out-of-doors emergency eyewash and shower installations in freezing and hot temperature areas. Please accept our apologies for the delay in responding.

The Occupational Safety and Health Administration (OSHA) standard at 29 CFR 1910.151(c) requires suitable facilities for quick drenching or flushing of the eyes and body where the eyes or body of any employee may be exposed to injurious corrosive material. Employers of employees that are exposed to injurious materials must provide reliable emergency eyewash and shower equipment that will wash away injurious material without damage to the eyes or body due to the temperature of the eyewash or shower flushing fluid.

OSHA does not, at this time, have standards or requirements specific to the installation and operation of emergency eyewashes and showers in freezing and hot temperature areas. Section 5.1.1, of the American National Standard for Emergency Eyewash and Shower Equipment, ANSI Z358.1-1990, specifies that where the possibility of freezing conditions exists, equipment must be protected from freezing or freeze-protected equipment shall be installed. Section 4.5.1(4) of Z358.1.1990, specifies that the control valve on the water supply must be adjusted to deliver a minimum of 113.6 liters (30 gallons) per minute and that the water must be substantially dispersed throughout the pattern (a frozen shower cannot deliver and disperse this amount of water). Such consensus standards may be referenced by OSHA in enforcing safety in the workplace when serious hazards are encountered.

ANSI Z358.1-1990 does not address the dispensing of water that is hot due to the installation location. However, an installation that would be hazardous to an employee due to elevated water temperatures would constitute a violation of the OSHA standard at 1910.151(c).

We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.


John B. Miles, Jr., Director
Directorate of Compliance Programs