OSHA Instruction STD 1-8.2 March 8, 1982 of Compliance Programming
Subject: 29 CFR 1910.151(c), Medical Services and First Aid; 29 CFR 1926.50
and 51, Medical Service and First Aid, and Sanitation, Respectively;
Applicable to Electric Storage Battery Charging and Maintenance Areas
A. Purpose. This instruction provides guidelines regarding eye wash and
body flushing facilities required for immediate emergency use in electric
storage battery charging and maintenance areas.
B. Scope. This instruction applies OSHA-wide.
C. Action. OSHA Regional Administrators/Area Directors shall ensure that
OSHA field staff apply the requirements the subject standards to electric
storage battery charging areas as set forth in E. of this instruction.
D. Federal Program Change. This instruction describes a Federal program
change which affects State programs. Each Regional Administrator shall:
1. Ensure that this change is forwarded to each State designee.
2. Explain the technical content of the change to the State
designee as requested.
3. Ensure that State designees are asked to acknowledge receipt of
the Federal Program change in writing, within 30 days of notification, to the
Regional Administrator. This acknowledgment should include a description
either of the State's plan to implement the change or of the reasons why the
change should not apply to that State.
4. Review policies, instructions and guidelines issued by the State
to determine that this change has been communicated to State program
personnel. Routine monitoring activities (accompanied inspections and case
file reviews) shall also be used to determine if this change has been
implemented in actual performance.
OSHA Instruction STD 1-8.2 March 8, 1982 Office of Compliance Programming
E. Guidelines. OSHA field staff will evaluate the potential circumstances
for employee exposure to electrolyte(s) in electric storage battery handling,
charging and maintenance areas.
1. The safety or health compliance officer shall document the
following observations in the case file:
a. Employee use of personal protective equipment.
b. Type and chemical concentration of electrolyte(s).
c. Special guards and/or precautions intended to provide for
employee protection from electrolyte exposure.
d. Based upon employee job functions, record the extent and
type of probable employee exposure to electrolyte(s).
e. Note the availability and location of eye wash and body
flushing equipment/facilities (An arrangement, which includes a hose equipped
with a proper face and body wash nozzle, shall also be noted.)
2. The compliance officer and Area Director shall evaluate the data
documented in E.1. Where potential employee exposure to hazardous storage
battery electrolyte(s) exists, the circumstances and extent of exposure shall
determine the application of the following alternatives:
a. The use of effective personal protective equipment in
combination with an eye wash and body flushing station in near proximity to
the work area(s), shall be deemed to provide adequate minimum protection for
b. In areas where the extent of possible exposure to
electrolyte is small, (i.e., such as auto garages, service stations and in
certain industrial and construction situations), a specially designated
pressure controlled and identified water hose equipped with a proper face and
body wash nozzle which will provide copious amounts of low velocity potable
water, or an
OSHA Instruction STD 1-8.2 MARCH 8, 1982 Office of Compliance Programming
appropriate portable eye wash device containing not less than
one gallon of potable water which is readily available and mounted for use,
is considered to provide minimum employee protection when proper personal
protective equipment is used.
c. In addition to emergency eye and/or face wash procedures,
the employer shall ensure that adequate provisions have been established for
the emergency care of employees exposed to eye or face contact with
d. At construction sites and in commercial and manufacturing
facilities at locations where powered industrial trucks are parked for
overnight storage and routine battery recharging only, no need for emergency
facilities exists unless potential exposure to electrolyte is substantiated.
Where exposure is possible (i.e., servicing batteries) the provisions of
E.2.b and E.2.e. should be evaluated for applicability.
e. At construction sites and in commercial manufacturing
facilities where batteries (such as industrial truck batteries) are serviced
and handled, proper plumbed eye wash and body drenching equipment shall be
available immediately adjacent to the work station(s) and within the work
area regardless of the personal protective equipment required and
3. Where employee exposure to hazardous electric storage battery
electrolyte(s) exists and minimum protection measures are not provided,
citations shall be issued as appropriate for violations of:
a. 29 CFR 1910.151(b) or 29 CFR 1926.50(c), a person or persons
adequately trained to render first aid shall be readily available in the
absence of an infirmary, clinic, or hospital in near proximity to the
workplace which is used for the treatment of all injured
OSHA Instruction STD 1-8.2 March 8, 1982 Office of Compliance programming
b. 29 CFR 1910.151(c) and as adopted by 29 CFR 1926.51, 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
c. 29 CFR 1910.132(a) or 29 CFR 1926.28(a), personal protective
equipment for eyes, face, head, and extremities, protective clothing and
protective shields and barriers, shall be provided, used and maintained in a
sanitary and reliable condition wherever it is necessary by reason of
chemical hazards encountered in a manner capable of causing injury or
impairment in the function of any part of the body through absorption,
inhalation or physical contact.
F. Background. 29 CFR 1910.151 (c) , Medical Services and First Aid, needs
clarification regarding its applicability to the hazards of electric storage
battery charging areas and the potential exposure of employees to
electrolyte(s). There is a clear need to identify the extent and suitability
of minimum acceptable eye wash and body quick drenching facilities which are
available to potentially exposed employees. 1. The extent of potential
employee exposure varies with workplace situations such as:
a. Employee functions.
b. Type of electrolyte(s) and concentration.
c. Type and size of batteries.
d. Facility layout.
e. Personal protective equipment used.
2. The need for eye wash and body quick drenching equipment varies
with the factors noted in F.1. Therefore, judicious enforcement of the
OSHA Instruction STD 1-8.2 March 8, 1982 Office of Compliance Programming
should provide for an evaluation of the contributing factors
relative to the potential hazardous exposure, and should permit appropriate
minimum assurances for adequate first aid and subsequent
3. Various forms of eye wash equipment are available today. Many
are of the portable or self contained wall mounted type which are limited in
the quantity of water available for eye wash purposes, and usually do not
provide for body drenching. This equipment may be used for compliance with
29 CFR 1910.151(c) only when it is not economically feasible to provide
plumbed equipment and/or where the potential employee exposure to
electrolyte(s) is determined to be slight.
4. Eye wash equipment should provide copious low velocity flow of
portable water at a suitable temperature, generally between 60 degrees F and
105 degrees F.
Thorne G. Auchter Assistant Secretary DISTRIBUTION: National, Regional and
Area Offices All Compliance Officers State Designees NIOSH Regional Program