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.

April 18, 2002

Mr. Paul Hagmann
5877 Sand Drive
West Bend, Wisconsin 53095

Dear Mr. Hagmann:

Thank you for your October 2, 2001 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs. You requested clarification of OSHA standard 29 CFR 1910.151 (Medical Services and First Aid). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. Your questions have been restated below for clarity. We apologize for the delay in your response.

Question 1: Will OSHA cite a facility for not following the recommendations as stated in ANSI standard Z358.1-1990? Specifically, will an OSHA inspector cite a facility for not supplying tempered water to an emergency eyewash and shower?

Reply: Paragraph (c) of 29 CFR 1910.151 requires the employer to provide suitable facilities for quick drenching or flushing of the eyes and body when employees may be exposed to injurious corrosive materials. ANSI standards become mandatory OSHA standards only when, and if, they are adopted by OSHA; ANSI Z358.1 was not adopted by OSHA. In comparison with the OSHA standard at 29 CFR 1910.151(c), however, ANSI Z358.1 provides detailed information regarding the installation and operation of emergency eyewash and shower equipment. OSHA, therefore, has often referred employers to ANSI Z358.1 as a source of guidance for protecting employees who may be exposed to injurious corrosive materials.

As you may know, 29 CFR 1910.151(c) does not provide specific instruction regarding the installation and operation of emergency eyewash and shower equipment. Therefore, it is the employer's responsibility to assess the particular conditions related to the eyewash/shower unit, such as water temperature, to ensure that the eyewash/shower unit provides suitable protection against caustic chemicals/materials to which employees may be exposed.

Question 2: Would the citation (in the situation described above) be written under 29 CFR 1910.151 or under the General Duty Clause, Section 5(a)(1)?

Reply: Since OSHA has a standard related to drenching/flushing facilities, any citation for the failure to provide suitable drenching/flushing facilities must be issued pursuant to 29 CFR 1910.151(c).

Question 3: While reading product literature on emergency shower units, it stated that 30 gpm was fairly standard among drench showers; are there specific requirements for the rate of flow for an emergency eyewash or shower unit?

Reply: OSHA has adopted no specific requirements regarding flow rates for drenching/flushing facilities. ANSI Z358.1 provides detailed information regarding the installation and operation of emergency eyewash and shower equipment, including the requirements for flow rate. Section 4.1 of ANSI Z358.1 specifies that emergency shower heads shall be capable of delivering a minimum of 75.7 liters per minute (20 gpm) of flushing fluid at a velocity low enough to be non-injurious to the user. A sufficient volume of flushing fluid shall be available to supply the flow rate for a minimum fifteen minute period.

Question 4: If OSHA is using the ANSI standard Z358.1-1990 for the basis of the OSHA standard 1910.151, doesn't OSHA need to make the ANSI standard available to the general public and/or industry? Where can I obtain a copy of the ANSI standard Z358.1-1990?

Reply: You may obtain copies of ANSI standards by contacting ANSI at:

 

 

American National Standards Institute, Inc.
11 West 42nd Street
New York, New York 10036
Phone: (212) 642-4900


Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions, please feel free to contact the Office of General Industry Compliance Assistance at (202) 693-1850.

Sincerely,



Richard E. Fairfax, Director
Directorate of Compliance Programs