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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

February 17, 1995

Mr. George L. Notarianni
42450 West Twelve Mile Road
Suite 300
Novi, MI 48377

Dear Mr. Notarianni:

This is in response to your letter of May 13, 1993, to Mr. Roger Clark, the former director of the Directorate of Compliance Program, concerning requirements for emergency deluge showers and/or eye/face wash units in the immediate area of ethylene oxide sterilizers used by health care facilities. Please accept our apology for the long delay in providing our response. Unfortunately, your inquiry was inadvertently misplaced in our files.

The applicable rule is 29 CFR 1910.151(c) Medical Services and First Aid, which requires, "Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use."

Due to the diversity of the circumstances from workplace to workplace, the Occupational Safety and Health Administration (OSHA) cannot provide a specific response as to whether health care facilities require emergency deluge showers or eye/face wash units in the immediate area of their ethylene oxide sterilizer(s). The Agency must determine on a case-by-case basis during an inspection whether a facility that has not taken such precautionary action is required to do so.

Each health care facility is responsible for determining whether emergency deluge showers or eye/face wash units are required in the immediate area of its ethylene oxide sterilizer(s). If there is risk of eye contact with liquid ethylene oxide, then eye/face wash units are required. If there is risk of employees getting doused with liquid ethylene oxide liquid or there is a risk of the clothing of employees becoming wet through to the skin with ethylene oxide liquid, then emergency deluge showers are required.

Regarding your inquiry as to the required proximity of the eye/face wash units and emergency deluge showers, 29 CFR 1910.151(c) requires that these units, "...shall be provided within the work area for immediate emergency use." OSHA standards are silent on a required distance and therefore the Agency refers to the recommendations with respect to highly corrosive chemicals contained in American National Standard for Emergency Eyewash and Shower Equipment, ANSI Z358.1-1990. OSHA interprets the phrase to require that eye/face wash units and emergency deluge showers both be located within 10 feet of unimpeded travel distance from the ethylene oxide liquid hazard or, in the alternative, within the distance recommended by a physician or appropriate official the employer consulted.

We appreciate the opportunity to clarify these matters for you. Should you require additional information, please contact the Office of Health Compliance Assistance at (202) 219-8036.


Ruth McCully, Director
Office of Health Compliance Assistance

May 13, 1993

Mr. Roger Clark, Director
Directorate of Compliance Programs
United States Department of Labor
Occupational Safety and Health Administration
200 Constitution Avenue
N.W. Washington, D.C. 20210

Dear Mr. Clark:

Re: Clarification of EtO Standard, 29 CFR 1910.1047

As you know, many healthcare facilities use EtO sterilizers to re-process surgical instruments and supplies. While reviewing recent OSHA citations, I have noticed OSHA violations concerning appropriate quick drench showers and eye wash units.

Appropriate emergency procedures are discussed at length in Appendix A of the EtO standard. I have several questions concerning the proper use of these emergency units:

1. Must facilities with EtO sterilizers have emergency deluge showers and/or eye/face wash units in the immediate area of the EtO sterilizers?

2. Are the ANSI guidelines of ten second travel time and/or 100 feet distance appropriate for the location of these units?

It is our experience that very few facilities currently have deluge showers or eye wash units in EtO gas sterilization locations. Thank you for your timely attention to this clarification request. I look forward to your response in the near future.


George L. Notarianni President