Wednesday, September 28, 2011

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.