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.

July 26, 1994

Ms. Claudia Harris
Director of Government Relations
National Association of
Plumbing-Heating-Cooling Contractors
P.O. Box 6808
Falls Church, Virginia 22046-1148

Dear Ms. Harris:

Thank you for your letter dated June 22 inquiring about your previous letters of October 4, and March 29 to Mr. Roger Clark requesting interpretation of the Occupational Safety and Health Administration (OSHA) Medical and First Aid standards. I apologize for the delay in responding to your inquiries.

With regard to whether full face shields and access to a water hose can be used as a substitute for a commercially available eye wash facility to comply with 1926.50(g), please be advised that this is acceptable but only under limited conditions. In areas where the extent of possible exposure to injurious corrosive materials is very low, a specially designated pressure controlled and identified water hose can be used when proper personal protective equipment also is used (e.g. full face shield). The hose system must be equipped with a proper face and body wash nozzle and provide copious amounts of low velocity potable water. An appropriate portable eye wash device containing not less than one gallon of potable water, would also be acceptable under these conditions. At locations where hazardous chemicals are handled by employees (e.g. battery servicing facility), proper eyewash and body drenching equipment must be available.

With regard to preparing for unknown hazard emergencies, please be advised that employers are responsible to provide eyewash facilities only if the potential for exposure to corrosive material is known to exist or could reasonably be expected to exist.

If we can be of any further assistance, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh in the Office of Construction Compliance Assistance at (202) 219-8136.


Joseph A. Dear
Assistant Secretary