- Standard Number:
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 http://www.osha.gov.
June 21, 1995
Carolyn S. Langer
Director of Occupational Health
and Safety Services
701 Pennsylvania Ave. N.W.
Washington, D.C. 20215
Dear Ms. Langer:
This is in response to your letter of May 3, in which you asked for clarification regarding the frequency with which showers must be tested.
The routine inspections of showers mentioned in Appendix A of Section 1910.1450 is not a mandatory requirement for which OSHA would normally issue a citation. Although the term "routine" does not indicate a specific frequency, it does mean that the inspections should be performed at regular intervals which are determined by someone familiar with the equipment and the work environment. The inspections are to be frequent enough to assure that the showers are in good working order when needed. This is recommended as a sound practice which is based on a consensus of the Committee on Hazardous Chemicals in the Laboratory, a select committee of the National Research Council. You will note that the report of this committee is cited (169) in the portion of the Standard to which you referred in your letter (see enclosure), 29 CFR 1910.1450, Appendix A, D. 4. (c). You will also note that the passage that you question came directly from the Committee Report.
If we can be of further assistance, please contact [the Office of Health Compliance Assistance at (202) 693-2190].
Raymond E. Donnelly, Director
Office of General Industry Compliance Assistance
May 3, 1995
Office of General Industry Compliance
Occupational Safety and
200 Constitution Avenue, N.W.
Washington, D.C. 20215
Dear Sir or Madam:
I am writing to request clarification on the frequency with which safety showers must be tested. Do any other OSHA regulations aside from 29 CFR 1910.1450 or 29 CFR 1910.151 cover this topic? Do you automatically apply the ANSI standard?
Under Appendix A to Section 1910.1450, OSHA recommends that safety showers be tested routinely. Although I understand that this standard is performance oriented, what does OSHA consider sufficient frequency of inspecting and flushing of safety showers? For example, if hospital personnel flushed a safety shower in the morning and an OSHA compliance officer came by in the afternoon to perform an inspection and in the interim the shower had become clogged, would the OSHA compliance officer cite the hospital for this condition? What if the hospital had instead flushed the shower one week prior to inspection or one month prior to the inspection? Would it make any difference if the hospital could or could not support their claims with written documentation?
Please respond to my inquiry at the above address or fax your response back to me at 617/542-2241. Thank you very much for your consideration of this matter.
Carolyn S. Langer, M.D., J.D., M.P.H.
Director of Occupational Health and