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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.
May 5, 2004
Mr. Tom Heslin
537 N. Edgewood Ave.
Wood Dale, IL 60191
Dear Mr. Heslin:
Thank you for your February 25, 2004 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. 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. You had specific questions regarding spray finishing operations and the application of OSHA regulations concerning emergency eyewash and shower facilities. Your paraphrased inquiries and our responses follow.
Question: We are installing a spray booth in our facility for use with lacquer and contact adhesive. A local building inspector indicated that we are required to have a shower and eyewash station in the vicinity of the spray operation. Do OSHA regulations require a shower and eyewash station, and if so, what are the design and use specifications for the shower and eyewash station?
Response: The OSHA regulations for spray finishing operations using flammable and combustible materials can be found at 29 CFR 1910.107. While this standard contains a number of provisions relevant to the operation that you have described, it does not require an emergency eyewash or shower in the vicinity of spray finishing operations using flammable and combustible materials. The OSHA requirements for emergency eyewashes and showers, found at 29 CFR 1910.151(c), specify that "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." As the standard states, an eyewash and/or safety shower would be required where an employee's eyes or body could be exposed to injurious corrosive materials. If none of the materials used in this work area is an injurious corrosive (as indicated by the Material Safety Data Sheet (MSDS) for each product), then an emergency eyewash or shower would not be required pursuant to 1910.151(c).
While not having the force of a regulation under the OSH Act, the current ANSI standard addressing emergency eyewash and shower equipment (ANSI Z358.1-2004) provides for eyewash and shower equipment in appropriate situations when employees are exposed to hazardous materials. ANSI's definition of "hazardous material" would include caustics, as well as additional substances and compounds that have the capability of producing adverse effects on the health and safety of humans. ANSI's standard also provides detail with respect to the location, installation, nature, and maintenance of eyewash and shower equipment. You also may wish to consult additional recognized references such as W. Morton Grant's Toxicology of the Eye (Charles C Thomas Pub. Ltd., 4th edition, August 1993) when considering potential chemical exposures to the eye and the appropriateness of installing eyewash facilities to protect employees against hazards associated with particular chemicals and substances.
From your letter, we cannot ascertain the basis for the building inspector's conclusion that a shower and eyewash station are required in the vicinity of your spraying operation. Please be aware that, while OSHA may not have promulgated a standard that mandates eyewash or shower equipment for the particular substances that your company will use in the spray booth facility, Illinois state laws or municipal codes may create independent requirements for employers who use such substances in the workplace.
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 Enforcement at (202) 693-1850.
Richard E. Fairfax, Director
Directorate of Enforcement Programs