CAL/OSHA First Aid Contents Requirement

The Federal OSHA Regulation 29 CFR 1910.151(B) states "Adequate first aid supplies shall be readily available." Cal/OSHA has a slightly different verbiage and regulation that is more stringent. "The minimum first-aid supplies shall be determined by an employer-authorized, licensed physician or in accordance with the following Table:

	Type of Supply Required
	by Number of Employees
Supplies for First Aid				over
Dressings in adequate quantities consisting of:	1-5	6-15	16-200	200
1. Adhesive dressings	X	X	X	X
2. Adhesive tape rolls, 1-inch wide	X	X	X	X
3. Eye dressing packet	X	X	X	X
4. 1-inch gauze bandage roll or compress		X	X	X
5. 2-inch gauze bandage roll or compress	X	X	X	X
6. 4-inch gauze bandage roll or compress		X	X	X
7. Sterile gauze pads, 2-inch square	X	X	X	X
8. Sterile gauze pads, 4-inch square	X	X	X	X
9. Sterile surgical pads suitable for
pressure dressings			X	X
10. Triangular bandages	X	X	X	X
11. Safety pins	X	X	X	X
12. Tweezers and scissors	X	X	X	X
* Additional equipment in adequate
quantities consisting of:
13. Cotton-tipped applicators			X	X
14. Forceps			X	X
15. Emesis basin			X	X
16. Flashlight			X	X
17. Magnifying glass			X	X
18. Portable oxygen and its
breathing equipment				X
19. Tongue depressors				X
Appropriate record forms	X	X	X	X
Up-to-date 'standard' or 'advanced'
first-aid textbook, manual or
equivalent	X	X	X	X

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*To be readily available but not necessarily within the first-aid kit."

§1512. Emergency Medical Services.(c)(1)

National Safety Compliance has a wide range of First Aid Kits to choose from, starting with small personal first aid kits to large 5-shelf First Aid Cabinets.

OSHA Interpretations regarding Safety Showers & Eye Washes

Question 1: We, as a company, have recommended to our customers that they comply with the requirements of ANSI Z358.1-2004, American National Standard for Emergency Eyewash and Shower Equipment. If a customer does so and the equipment is provided within the work area for immediate use by our own employees, have we made a reasonable effort to comply with 29 CFR 1910.151(c)?

Paragraph (c) of 29 CFR 1910.151 requires that suitable facilities for quick drenching or flushing be provided within the work area for immediate use if an employee's eyes or body may be exposed to corrosive materials. The OSHA standard does not set specifications for emergency eyewash and shower equipment, but we agree that equipment that complies with ANSI requirements would usually meet the intent of the OSHA standard. It should also be noted that, in addition to the requirement for emergency flushing and drenching facilities, there are also requirements for personal protective equipment (PPE) when employees are exposed to the hazards which corrosive chemicals present. PPE requirements are found in Subpart I, Personal Protective Equipment, of 29 CFR §1910 and may include, but are not limited to, protection for the eyes, face, and hands, as well as protective clothing. The purpose of PPE is to prevent injury, whereas the purpose of the eye wash or shower is to minimize injury, should that first line of defense fail.

Question 2: Deliveries often occur at night or when the retail location is closed. When our driver arrives at the facility under these circumstances, he or she must use a key to enter the facility and the unloading area. The quick drenching facilities are located in the unloading area. Does the necessity of a key violate the accessibility requirement of the ANSI standard?

Although OSHA often refers employers to ANSI Z358.1-2004 for guidance in the installation and operation of quick drenching and flushing equipment, OSHA does not interpret ANSI standards; OSHA may only provide interpretations of its own regulations. OSHA has its own requirements for the location and accessibility of quick drenching or flushing facilities. 29 CFR 1910.151(c) states that "[w]here 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" (emphasis added). While the need to use a key to unlock a door to reach the quick drenching or flushing facilities would ordinarily pose a problem, it appears that in your case your employee would already be inside the unloading area where the quick drenching facilities are located and where presumably any exposure to the injurious corrosive materials would occur.

Question 3: Who is responsible for providing the quick drenching and flushing facilities?

Every employer with employees exposed to the corrosive chemicals is responsible for the safety and health of their employees. A delivery company may comply with the requirement to provide quick drenching and flushing facilities in a number of ways. The delivery company may elect to provide self-contained, portable equipment on the delivery vehicle. A possibly more convenient option for compliance would be to use the facilities provided by the retail employer for the retail employees. We envision that, in the majority of cases, the retail employer will have employees similarly exposed to the corrosive chemicals and thus would be required to provide quick drenching and flushing facilities for their employees. The delivery and retail employers coordinate other elements of their business relationship, such as delivery time, location, and quantity; the coordination of safety and health responsibilities can and should be included in this process. If the retail employer does not provide these facilities or if facilities are provided but are not appropriately selected and located for immediate emergency use by the delivery employees, then the delivery employer would still be required to provide suitable quick drenching and flushing facilities for its employees. The delivery employer needs to evaluate the work process, assessing factors such as configuration of the work area, the corrosivity of the materials, and the potential created by the work process for the corrosive chemical to come into contact with the employee. The delivery employer would then train employees as to the hazards presented, select and require appropriate PPE, and provide suitable quick drenching and flushing facilities for immediate use by their employees.

Question 4: Are small businesses (e.g., retail stores) subject to 29 CFR 1910.151(c), if they handle corrosive liquid materials?

Yes. All employers, regardless of size, that have employees whose eyes or body may be exposed to injurious corrosive materials must provide quick drenching and flushing facilities.

Question 5: Is there a quantity of corrosive chemical that triggers the requirements of 29 CFR 1910.151(c)?

No, there is no threshold quantity of corrosive material that triggers the requirement. The determining factor for the application of the standard is the possible exposure of an employee to injury from contact with a corrosive material.

As you may know, a number of states administer their own occupational safety and health programs under plans approved and monitored by Federal OSHA. It is possible that some of your customers are located in these State Plan States. Therefore, employers in these states must comply with their own State's occupational safety and health requirements. As a condition of plan approval, States are required to adopt and enforce occupational safety and health standards and interpretations that are at least effective as those promulgated by Federal OSHA. However, some states may have different or more stringent requirements.

Many companies required to post OSHA 300A Recordkeeping Report

February 1 is not far away which means many employers must have their 300A Recordkeeping Report of work-related fatalities, injuries and illnesses posted in the workplace. Below are some common questions regarding the 29 CFR 1904 Recording and Reporting Occupational Injuries and Illnesses:

Question 0-1. Why are employers required to keep records of work-related injuries and illnesses?

The OSH Act of 1970 requires the Secretary of Labor to produce regulations that require employers to keep records of occupational deaths, injuries, and illnesses. The records are used for several purposes.

Injury and illness statistics are used by OSHA. OSHA collects data through the OSHA Data Initiative (ODI) to help direct its programs and measure its own performance. Inspectors also use the data during inspections to help direct their efforts to the hazards that are hurting workers.

The records are also used by employers and employees to implement safety and health programs at individual workplaces. Analysis of the data is a widely recognized method for discovering workplace safety and health problems and for tracking progress in solving those problems.

The records provide the base data for the BLS Annual Survey of Occupational Injuries and Illnesses, the Nation's primary source of occupational injury and illness data.

Question 0-2. What is the effect of workers' compensation reports on the OSHA records?

The purpose section of the rule includes a note to make it clear that recording an injury or illness neither affects a person's entitlement to workers' compensation nor proves a violation of an OSHA rule. The rules for compensability under workers' compensation differ from state to state and do not have any effect on whether or not a case needs to be recorded on the OSHA 300 Log. Many cases will be OSHA recordable and compensable under workers' compensation. However, some cases will be compensable but not OSHA recordable, and some cases will be OSHA recordable but not compensable under workers' compensation.

Question 2-1. How can I get help to find my SIC Code and determine if I'm partially exempt from the recordkeeping rule?

You can access the statistics section of OSHA's internet home page, at http://www.osha.gov/oshstats/. Go to the website and choose SIC Manual and follow the directions. If you still cannot determine your SIC code, you can call an OSHA area office, or, if you are in a state with an OSHA-approved state plan, call your State Plan office. See the OSHA Office Directory.

Question 2-2. Do States with OSHA-approved State plans have the same industry exemptions as Federal OSHA?

States with OSHA-approved plans may require employers to keep records for the State, even though those employers are within an industry exempted by the Federal rule.

Question 2-3. Do professional sports teams qualify for the partial industry exemption in section 1904.2?

No. Only those industry classifications listed in Appendix A to Subpart B qualify for the partial industry exemption in section 1904.2. Professional sports teams are classified under Standard Industrial Classification (SIC) code 794, which is not one of the listed exempt classifications.

Question 4-1. Does an employee report of an injury or illness establish the existence of the injury or illness for recordkeeping purposes?

No. In determining whether a case is recordable, the employer must first decide whether an injury or illness, as defined by the rule, has occurred. If the employer is uncertain about whether an injury or illness has occurred, the employer may refer the employee to a physician or other health care professional for evaluation and may consider the health care professional's opinion in determining whether an injury or illness exists. [Note: If a physician or other licensed health care professional diagnoses a significant injury or illness within the meaning of Section 1904.7(b)(7) and the employer determines that the case is work-related, the case must be recorded.]

Question 5-1. If a maintenance employee is cleaning the parking lot or an access road and is injured as a result, is the case work-related?

Yes, the case is work-related because the employee is injured as a result of conducting company business in the work environment. If the injury meets the general recording criteria of Section 1904.7 (death, days away, etc.), the case must be recorded.

Question 5-2. Are cases of workplace violence considered work-related under the new Recordkeeping rule?

The Recordkeeping rule contains no general exception, for purposes of determining work-relationship, for cases involving acts of violence in the work environment. However, some cases involving violent acts might be included within one of the exceptions listed in section 1904.5(b)(2). For example, if an employee arrives at work early to use a company conference room for a civic club meeting and is injured by some violent act, the case would not be work-related under the exception in section 1904.5(b)(2)(v).

Question 5-3. What activities are considered "personal grooming" for purposes of the exception to the geographic presumption of work-relatedness in section 1904.5(b)(2)(vi)?

Personal grooming activities are activities directly related to personal hygiene, such as combing and drying hair, brushing teeth, clipping fingernails and the like. Bathing or showering at the workplace when necessary because of an exposure to a substance at work is not within the personal grooming exception in section 1904.5(b)(2)(vi). Thus, if an employee slips and falls while showering at work to remove a contaminant to which he has been exposed at work, and sustains an injury that meets one of the general recording criteria listed in section 1904.7(b)(1), the case is recordable.

Question 5-4. What are "assigned working hours" for purposes of the exception to the geographic presumption in section 1904.5(b)(2)(v)?

"Assigned working hours," for purposes of section 1904.5(b)(2)(v), means those hours the employee is actually expected to work, including overtime.

Question 5-5. What are "personal tasks" for purposes of the exception to the geographic presumption in section 1904.5(b)(2)(v)?

"Personal tasks" for purposes of section 1904.5(b)(2)(v) are tasks that are unrelated to the employee's job. For example, if an employee uses a company break area to work on his child's science project, he is engaged in a personal task.

Question 5-6. If an employee stays at work after normal work hours to prepare for the next day's tasks and is injured, is the case work-related? For example, if an employee stays after work to prepare air-sampling pumps and is injured, is the case work-related?

A case is work-related any time an event or exposure in the work environment either causes or contributes to an injury or illness or significantly aggravates a pre-existing injury or illness, unless one of the exceptions in section 1904.5(b)(2) applies. The work environment includes the establishment and other locations where one or more employees are working or are present as a condition of their employment. The case in question would be work-related if the employee was injured as a result of an event or exposure at work, regardless of whether the injury occurred after normal work hours.

Question 5-7. If an employee voluntarily takes work home and is injured while working at home, is the case recordable?

No. Injuries and illnesses occurring in the home environment are only considered work-related if the employee is being paid or compensated for working at home and the injury or illness is directly related to the performance of the work rather than to the general home environment.

Question 5-8. If an employee's pre-existing medical condition causes an incident which results in a subsequent injury, is the case work-related? For example, if an employee suffers an epileptic seizure, falls, and breaks his arm, is the case covered by the exception in section 1904.5(b)(2)(ii)?

Neither the seizures nor the broken arm are recordable. Injuries and illnesses that result solely from non-work-related events or exposures are not recordable under the exception in section 1904.5(b)(2)(ii). Epileptic seizures are a symptom of a disease of non-occupational origin, and the fact that they occur at work does not make them work-related. Because epileptic seizures are not work-related, injuries resulting solely from the seizures, such as the broken arm in the case in question, are not recordable.

Question 5-9. This question involves the following sequence of events: Employee A drives to work, parks her car in the company parking lot and is walking across the lot when she is struck by a car driven by employee B, who is commuting to work. Both employees are seriously injured in the accident. Is either case work-related?

Neither employee's injuries are recordable. While the employee parking lot is part of the work environment under section 1904.5, injuries occurring there are not work-related if they meet the exception in section 1904.5(b)(2)(vii). Section 1904.5(b)(2)(vii) excepts injuries caused by motor vehicle accidents occurring on the company parking lot while the employee is commuting to and from work. In the case in question, both employees' injuries resulted from a motor vehicle accident in the company parking lot while the employees were commuting. Accordingly, the exception applies.

Question 5-10. How does OSHA define a "company parking lot" for purposes of Recordkeeping?

Company parking lots are part of the employer's premises and therefore part of the establishment. These areas are under the control of the employer, i.e. those parking areas where the employer can limit access (such as parking lots limited to the employer's employees and visitors). On the other hand, a parking area where the employer does not have control (such as a parking lot outside of a building shared by different employers, or a public parking area like those found at a mall or beneath a multi-employer office building) would not be considered part of the employers establishment (except for the owner of the building or mall), and therefore not a company parking lot for purposes of OSHA recordkeeping.

Question 5-11. An employee experienced an injury or illness in the work environment before they had "clocked in" for the day. Is the case considered work- related even if that employee was not officially "on the clock" for pay purposes?

Yes. For purposes of OSHA recordkeeping, injuries and illnesses occurring in the work environment are considered work-related. Punching in and out with a time clock (or signing in and out) does not affect the outcome for determining work-relatedness. If the employee experienced a work-related injury or illness, and it meets one or more of the general recording criteria under section 1904.7, it must be entered on the employer's OSHA 300 log.

Question 5-12. Is work-related stress recordable as a mental illness case?

Mental illnesses, such as depression or anxiety disorder, that have work-related stress as a contributing factor, are recordable if the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related, and the case meets one or more of the general recording criteria. See sections 1904.5(b)(2)(ix) and 1904.7.

Question 5-13. If an employee dies or is injured or infected as a result of terrorist attacks, should it be recorded on the OSHA Injury and Illness Log? Should it be reported to OSHA?

Yes, injuries and illnesses that result from a terrorist event or exposure in the work environment are considered work-related for OSHA recordkeeping purposes. OSHA does not provide an exclusion for violence-related injury and illness cases, including injuries and illnesses resulting from terrorist attacks.

Within eight (8) hours after the death of any employee from a work-related incident or the in-patient hospitalization of three or more employees as a result of a work-related incident, an employer must orally report the fatality/multiple hospitalization by telephone or in person to the OSHA Area that is nearest to the site of the incident. An employer may also use the OSHA toll-free central telephone number, 1-800-321-OSHA (1-800-321-6742).

29 CFR 1910.269 CPR/First aid training and "working alone"

Question No. 1: Does the OSHA Standard above require, at all shifts, that an employee in a generating station be reached by another employee or a second person, trained in cardio-pulmonary resuscitation (CPR) and first aid, within 4 minutes?

Reply: No, not in all circumstances. OSHA Standard 29 CFR 1910.269(b)(1)(ii) requires that for fixed work locations such as generating stations, the number of trained persons available shall be sufficient to ensure that each employee exposed to electric shock can be reached within 4 minutes by a trained person. However, where the existing number of employees is insufficient to meet this requirement (at a remote substation, for example), all employees at the work location shall be trained. In the rulemaking, OSHA clarified that this provision was required only for employees exposed to the hazards of electrical shock when they perform work on or associated with exposed lines or equipment energized at 50 volts or more. This does not pertain to employees working near insulated electrical equipment, as the exposure to electrical shock hazard is minimal.

Question No. 2: Does the OSHA Standard prohibit an employee from working alone in a generating station where emergency medical response service (EMRS) can not respond to a work-related accident within 4 minutes?

Reply: Yes, with respect to the working alone issue, OSHA Standard 29 CFR 1910.269 prohibits an employee from working alone if the duties of the employee in the hydroelectric dam generating station fall into one of the categories in paragraph 1910.269(l)(1)(i) and are not exempted by paragraph 1910.269(l)(1)(ii). The working alone issue is not dependent upon first aid/CPR response and the preceding reply addresses the 4 minute response time issue.

Question No. 3: In facilities, other than generating stations, where a hazard may or may not include electrical shock, do we permit "working alone" where EMRS can not respond within 4 minutes to an accident resulting in a critical injury, or within 15 minutes to an accident resulting in a serious non life-threatening injury?

Reply: In facilities other than Electric Power Generation, Transmission and Distribution that fall outside of the scope of OSHA Standard 29 CFR 1910.269, there is no general OSHA Standard that deals with the situation of an employee "working alone" except in specific situations such as emergency response, interior structural firefighting, or working in permit required confined spaces. Again, the working alone requirement is not dependent on medical treatment response time.

In summary, an employee must be accompanied by another employee if the duties of the night shift operator in the hydroelectric dam station fall into one of the categories in paragraph 1910.269(l)(1)(i) and are not exempted by paragraph 1910.269(l)(1)(ii). The CPR and first aid provisions, contained in paragraph 1910.269(b)(1) are dependent upon the type of electrical work performed by employee(s) and not the working alone issue. If an employee could be expected to be exposed to electric shock (at or beyond the 50 volt threshold hazard limit) in the course of performing his or her duties, then these requirements for field work and fixed work locations apply. In all general industry work situations, the medical services and first aid requirements set forth in paragraph[s] 1910.151[(b) and 1910.151(c)] apply. That existing section includes provisions for available medical personnel, first aid training and supplies and facilities for drenching or flushing of the eyes and body in the event of exposure to corrosive materials.

For additional information please visit the following Free Information on First Aid.

1910.151(b) Interpretation of the OSHA First Aid Standard.

Question 1: "Must an employer have individuals trained to render first aid?"

Answer: [No.] The OSHA requirement at 29 CFR 1910.151(b) states, "In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. [Adequate] [f]irst aid supplies approved by the consulting physician shall be readily available." [emphasis added]
[This document was edited on 8/19/1999 to strike information that no longer reflects OSHA policy.]

OSHA's regulation does not set specific response time requirements for the term "near proximity", however, in areas where accidents resulting in suffocation, severe bleeding, or other life-threatening or permanently disabling injury or illness are likely, a 3 to 4 minute response time, from time of injury to time of administering first aid, is required. In other circumstances, i.e., where a life-threatening or permanently disabling injury is an unlikely outcome of an accident, a longer response time, such as 15 minutes, is acceptable. The rationale for requiring a 4 minute response time is brain death when the heart or breathing has stopped for that period of time.
[This letter was edited on 6/12/2002 to strike information that no longer reflects current OSHA policy. Please see the1/16/2007 letter to Mr. Brogan for the current policy.]
Question 2: "If an emergency situation were to occur where first aid was necessary and a trained employee were to panic, forgetting all of their training, and no first aid or improper first aid was administered could the employer be cited?"

Answer: If a trained employee were to panic in an emergency situation and not administer first aid or administer improper first aid, OSHA would not cite the employer. The employer would have met his obligation under the standard by having individuals trained to render first aid. The standard only requires employees to be trained in first aid, but does not address the actual performance of first aid in an emergency situation. Please note, however, that OSHA would conduct an investigation, if deemed necessary, to ensure that proper training certification, e.g., First Aid and CPR certificates were in order.

Question 3: "Would an employer be in violation of OSHA's First Aid standard if the employer were to issue a policy which recommends that employees call "911" in emergency situations?"

Answer: The purpose of first aid is to give injured employees some level of medical attention as quickly as possible to bridge the gap between the accident and full medical treatment. Therefore, the rendering of first aid should be encouraged by trained employees in addition to calling "911." Thus, an employer would not be in violation of OSHA's First Aid standard by issuing such a policy statement as long as the policy does not discourage the rendering of first aid by trained employees.

Is employee first aid/CPR training required when a fire department is within 4 minutes of workplace?

Scenario: The facility, a clinical laboratory, is located an average of four minutes away from a fire department that provides first aid assistance.

Question 1: Would it be acceptable under 29 CFR 1910.151(b) in Subpart K, "Medical and First Aid," for the facility to rely on the fire department and avoid having employees trained in first aid to address emergency situations on site?

Response 1: The OSHA standard at 29 CFR 1910.151(b) states: "In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid . . . ." The primary requirement addressed by this standard is that an employer must ensure prompt first aid for injured employees, either by providing for the availability of a trained first aid provider at the worksite, or by ensuring that emergency treatment services are within reasonable proximity to the worksite. The basic purpose of this standard is to assure that adequate first aid is available in the critical minutes between the occurrence of an injury and the availability of physician or hospital care for the injured employee.

One option this standard provides employers is to ensure that a member of the workforce has been trained in first aid. This option is, for most employers, a feasible and low-cost way to protect employees, as well as putting the employer in compliance with the standard. The other option for employers is to rely upon the reasonable proximity of an infirmary, clinic, or hospital. OSHA has consistently taken the view that the reasonable availability of a trained emergency service provider, such as fire department paramedics or EMS responders, would be equivalent to the "infirmary, clinic, or hospital" specified by the literal wording of the standard. Emergency medical services can be provided either onsite or by evacuating the employee to an off-site facility in cases where that can be done safely.

An employer who contemplates relying on assistance from outside emergency responders as an alternative to providing a first-aid trained employee must take a number of factors into account. The employer must take appropriate steps prior to any accident (such as making arrangements with the service provider) to ascertain that emergency medical assistance will be promptly available when an injury occurs. While the standard does not prescribe a number of minutes, OSHA has long interpreted the term "near proximity" to mean that emergency care must be available within no more than 3-4 minutes from the workplace. This interpretation generally has been upheld by the Occupational Safety and Health Review Commission, an independent tribunal that decides OSHA cases, and by federal courts.

Medical literature establishes that for serious injuries, such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, first aid treatment must be provided within the first few minutes to avoid permanent medical impairment or death. Accordingly, in workplaces where serious accidents, such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes if there is no employee on the site who is trained to render first aid. Since your facility is an average of 4 minutes from the fire department and thus possibly more than 4 minutes away from the fire station in reality, you may not rely on its emergency service providers to fulfill your obligation under the standard if such serious injuries are possible at your workplace. As a matter of enforcement discretion, OSHA recognizes that a somewhat longer response time of up to 15 minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote. If that is the case in your workplace, you are allowed to rely on the fire department, which is an average of 4 minutes away from your workplace.

After this Letter of Interpretation is given, one thing is sure - if an emergency medical facility is not within 4 minutes of the workplace, first aid training and CPR training is a must for at least 1 employee per shift.

Emergency eyewash in areas where chemicals are irritants but not corrosive

"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." - 29 CFR 1910.151(c)

Question: Is there a requirement for an emergency eyewash in the immediate work area for anything other than injurious corrosive chemicals (including chemicals which the MSDS clearly indicates that the product is a severe irritant, but not corrosive to eyes or skin) under 1910.151(c)? Are there any other Federal OSHA regulations that would require provision of eye flushing facilities for use of chemicals other than corrosives?

Answer: No. OSHA's current policy regarding the requirements for providing an emergency eyewash and/or safety shower is explained in its letter of interpretation to Mr. Tom Heslin, May 5, 2004 (attached) as follows:

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 [chemical] (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 [Z]358.1-2004) 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.