Eye Washes & Deluge Showers
I. The Issue:
Even after a thorough hazard analysis, a review of safety procedures, and the proper use of personal protective equipment, accidents can still happen. In the case of accidental chemical exposures to the eyes a quick and effective response is essential to prevent lasting damage or a loss of sight. In addition, federal health and safety regulations exist which specifically mandate that emergency eyewash units must be installed and maintained where corrosive chemicals will be used. Regardless of the legal requirements, most would agree that it is a prudent practice to install and maintain an emergency eye wash unit wherever a chemical or physical hazard may pose a serious risk of injury to someone's eye.
II. The approach taken:
As public employees, the school department staff are not under the purview and jurisdiction of the federal Occupation Safety and Health Administration. In addition, the Commonwealth of Massachusetts has not formally adopted emergency eyewash standards for public employees. Based on the lack of legal requirements, we decided to use the federal requirements outlined in 29 CFR 1910.151(c) as well as the guidance specified in the American National Standards Institute (ANSI) Emergency Eyewash Standard that OSHA has adopted as a consensus standard as a minimum local standard. In addition, we felt that it may be appropriate to seek the installation of eyewash units wherever a chemical or physical hazard may injury an eye rather than just were corrosive liquids were used as specified in the federal standard.
Using this criteria, we identified the following areas where the installation and maintenance of an eyewash may be most appropriate: the high school and middle school science laboratories, the high school woodworking shop, the high school ceramics area, the Burlington science center, and the school department chemical storage warehouse. An initial assessment of these areas determined that emergency eyewashes were only available in four of the high school science laboratories.
III. Observations made:
An initial survey of eighteen rooms and laboratories where activities occurred that could result in eye injuries determined that only four of the rooms were equipped with emergency eyewash units. These units were located in two chemistry classrooms and two adjoining laboratories. As a result only a limited emergency response was possible in the remainder of the school district.
Another observation noted during the initial survey was that the eyewash units were not always free of debris and appeared to be subject to abuse and vandalism. In addition, there existed confusion amongst the school department staff with regard to who was responsible for testing and maintaining the eyewash units. Furthermore, we could not locate records which indicated that the flow rates had been monitored on a semiannual basis or if the units had been tested on a weekly basis as recommended by OSHA. Several tests of the units conducted during our initial review resulted in the observation of rusty water discharging the units. This suggested that the units may not have been discharged on a weekly basis as suggested by OSHA.
Another observation noted was that much of the staff did not believe that significant eye hazards existed in their work area, and consequently many did not place importance on installing and maintaining an eyewash unit in their work area. Also, those staff members that had been provided with eyewash units automatically assumed the units would work if needed, but these staff members did not actively inspect, test or monitor the units for access or proper operation.
IV. Problems or concerns noted:
- Emergency eyewash units were not available in most of areas where potential eye injuries could occur.
- No records are available to indicate when and how the existing eyewash units are inspected and maintained.
- Upon testing, the existing units have been observed to discharge rusty water which could aggravate an injury or cause an individual not to use the unit.
- Additional eyewash units have been purchased, unfortunately not all the new units comply with the ANSI design and operation standards.
- Confusion still exists with regard to who should inspect and maintain the eyewash units, consequently many routine inspections of these units are not completed.
- Several areas where optical hazards exist have not yet been equipped with eyewash units.
V. Actions taken:
A. We developed a local protocol to determine areas where activities occurred that could pose the risk of an eye injury.
We used the requirements of the federal Occupational Safety and Health Administration standard 29 CFR 1910.151 and the ANSI Emergency Eyewash protocol that OSHA has adopted as a consensus standard for the basis for our approach.
B. Using the local standard, we surveyed the school district to identify activities that posed a potential risk.
Using this information, we identified the following locations where chemical and physical hazards existed that could result in eye injuries: the high school and middle school science laboratories, the high school woodworking shop, the high school ceramics area, the Burlington science center, and the school department chemical storage warehouse.
C. Additional eyewash units were purchased for some of the hazard areas.
Additional eyewash units have been installed in high school and middle school science laboratories.
1. Buy ANSI approved eyewash units and not faucet mounted units.
Most of the eyewash units purchased in order to enhance eye protection within the school district were faucet mounted units. Two types of units have been purchased. One unit has a single hand held nozzle that is connected to the faucet by a screw on hose. The second unit has a double nozzle dispenser that can be mounted on the faucet. This unit is also connected to the faucet by a screw on hose. The problems with these units include that the units are not always connected to the faucet and ready for immediate operation. In addition, the single dispenser unit must be held when operated and may not provide adequate coverage for both eyes, consequently it may be difficult to rinse the eyes without assistance.
The recommended approach would be to utilize an eyewash which complies with the following minimum design parameters established by ANSI. The unit should be capable of providing 0.4 gallons of tepid water per minute for 15 minutes via two dispensing units. The unit should also be self discharging so that the operator's hands are free to assist with the flushing process. This is important because the injured party may be required to hold their eye lids open or remove contact lenses.
2. Develop a plan and designate responsibility for inspecting, testing and maintaining the units.
The establishment of an inspection and maintenance plan is critical for ensuring that access to the units is maintained at all times and that the units are clean, sanitary, and fully functional at all times. Routine inspection and testing will promote this as well as prevent the build up of sediment or rust within the unit.
Tips and Suggestions:
1. Have someone who has been injured discuss the accident with staff and/or students.
A first hand account can have a tremendous impact on the unconvinced. Your local hospital may be able to assist you in locating a speaker.
2. Do not purchase faucet mounted units.
These units will frequently be disabled so that the faucets can be used for other purposes. As a result, valuable time can be lost while someone tries to reassemble the device during a crisis.
During this investigation, I utilized the resources available via the U.S. Department of Labor - Occupational Safety and Health Administration, and the American National Standards Institute. These groups can be contacted via the Internet at:
prepared by Todd H. Dresser, Environmental Engineer
Burlington Board of Health, 29 Center Street, Burlington, MA 01803