Current OSHA regulations require that emergency eyewash stations be provided whenever employees may come into contact with chemicals that can cause corrosion, severe irritation, or permanent tissue damage. See Title 8 CCR 5162 (CA) or 29 CFR 1910.151(c) (Fed). Battery charging, battery filling, used battery storage (when the electrolyte may be released due to the condition of the battery), use or dispensing of corrosive chemicals or irritants (often occurring in detail) are processes that require the installation of an eyewash station. Courts have often upheld ANSI standards in enforcement actions.    

OSHA regulations refer to ANSI standards for greater detail in standards and in opinion letters, require employers to refer to ANSI standards regarding eyewash stations.  OSHA inspectors also rely on ANSI standards during enforcement when OSHA regulations fall short on detail. ANSI revised the eyewash standard in 2014 and all eyewash manufacturers follow the latest 2014 standard Z358.1-2014.  This standard is a widely accepted guideline for the proper selection, installation, operation, and maintenance of emergency eyewash station equipment. An interesting discussion on legal implications of ANSI standards is found here https://www.lomont.com/documents/Dembystandardsarticle3-21-2006.pdf. In summary, an employer is well served by complying with ANSI standards. 

ANSI standards should be referred by all employers https://www.gesafety.com/downloads/ANSIGuide.pdf.  This newsletter does not cover all necessary elements of the standard.  We merely summarize some important elements as follows: 

Note 1:     Water hoses, sinks, faucets, showers, and eyewash bottles (sometimes included in first-aid kits) do not comply with Cal/OSHA eyewash standards.  

Note 2:     If there is a water line available in the shop area, then the plumbed unit is preferred as the wall mounted tank requires more maintenance and is expensive to maintain.  Also, if a tech uses the wall mounted unit at 9am, the tech requiring it at 10am goes blind!!! 

Note 3:     The eyewash units should have proper drain available to address the water draining from the unit.  If the unit cannot be plumbed to the shop drain, a 5-gallon plastic bucket can be placed under the eyewash station and disposed of periodically. 

Note 4:     In certain cases, a door opening in the direction of the walking person may be allowed. However, if the chemical hazard is caustic or corrosive such as battery acid in the automobiles, or battery acid in parts departments, then the eyewash station should be directly available and not through a door. 

Note 5:     The handheld drench units support plumbed and self-contained emergency eyewash stations but cannot replace them. In other words, drench hoses are intended only as supplemental units. 

Note 6:     Water temperature delivered shall be tepid (60-100F). 

Note 7:     Use an eyewash tester to ensure water flow covers eyes at no more than 8” above the spray heads. https://cdn.shopify.com/s/files/1/0320/3232/5768/files/Speakman_SE-952_Spec-Sheet.pdf 

All employers must use a checklist to ensure proper operation of the eyewash and an annual performance check (akin to a preventive maintenance) on the eyewash.  The checklist as summarized from ANSI is as follows: 

• Inspection Frequency: Activate all eyewash stations at least weekly. Inspect all eyewash units annually for compliance with the ANSI Z358.1 standard. 
• Location: The eyewash station must be located within 10 seconds from the hazard, approximately 55 feet from the hazard. The eyewash station must be located on the same plane as the hazard, and the travel path to the eyewash station must be unobstructed (no doors with handles to open; see Note 4).  
• Identification: The area around the eyewash station must be well lit, and the unit must include a highly visible sign.
• The eyewash station washes both eyes simultaneously, and the water flow allows the user to hold the eyes open without exceeding 8 inches above the spray heads. See Note 5. 
• Spray heads are protected from airborne contaminants. Covers are pushed open by water flow. 
• The eyewash station delivers at least 0.4 gallons of water per minute for 15 minutes and should have a minimum tank capacity size of 6 gallons. 
• The water flow pattern should be 33 to 53 inches from floor level and at least 6 inches from the wall or nearest obstruction.   
• The equipment should stay hands-free with a stay open valve that activates in one second or less. Please note that any valves placed on the supply line to the eyewash station must have their handles removed so no one accidentally shuts down the water supply to the eyewash station. 

Other Important Items: 

• Clearance: To ensure eyewash units are not obstructed, it is highly recommended that a “Do Not Block” parameter is established. The use of hazard tape can facilitate proper clearance.  
• Training: All employees who may be exposed to potential eye/face injuries from hazardous material should be trained on the operation of the eyewash unit. This includes where to locate the nearest eyewash unit and the importance of keeping the path to the unit obstruction free.
• The eyewash station must have clearance 48 inches from the back wall or obstruction and 30 inches total (on sides) with the eyewash station present in the center.  27 inches knee clearance below the unit.
• The ANSI standard requires that employers provide an accessible workplace to all employees. The eyewash stations must meet wheelchair accessibility requirements as well.
• A single step up into an enclosure where the equipment can be accessed is not considered to be an obstruction. Additionally, installers should allow for adequate overhead clearance to accommodate the presence of cabinets over a counter or faucet-mounted emergency eyewash so as not to create an additional hazard that could be encountered when using the device. 
• Purchasing equipment that is manufactured according to ANSI standards and maintenance and inspection of the equipment according to ANSI standards should be considered mandatory to all employers. 
• OSHA considers violation of this standard to be a “Serious Violation.”  Penalty is $13,653.  Cost of an eyewash on Amazon is $120 (for wall mounted tank) and $200 for a plumbed unit.  No cost benefit analysis needed here. 

Does Parts Need an Eyewash:  The answer is yes according to CA OSHA Appeals Board (COSHAB) decision.  See Dockets 11-R3D2-1929 through 1931.  A big box warehouse store with multiple outlets in California was cited by Cal/OSHA for failure to have eye wash stations.  The employer appealed to COSHAB stating that the eye wash standard does not apply as the chemicals are merely unloaded, unboxed and placed on shelves in sealed containers by employees.  COSHAB held that the employees can be exposed to leaks and spills from packages damaged in transit and when employees unpack these cases.  Employees involved in cleanup in the warehouse where there is a spill have the potential to an eye injury from corrosive and irritating chemical, hence the requirement of an eyewash in the warehouse.

DISCLAIMER:  The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas, and Virginia comply with EPA and OSHA regulations for over 34 years.  Sam is Certified Safety Professional (No. 16515) certified by National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.