Background: Eye injuries in the workplace can have severe consequences, including permanent vision loss. According to the CDC, over 2,000 workers sustain job-related eye injuries daily, leading to significant downtime and economic loss. Implementing proper eye protection and eyewash stations is crucial to ensure safety and compliance with OSHA regulations. This memo outlines the requirements for eye protection and eyewash stations at our dealership and why they are critical.

The Law on Eye and Face Protection: Employees working in locations where there is a risk of receiving eye injuries such as punctures, abrasions, contusions, or burns as a result of contact with flying particles, hazardous substances, projections or injurious light rays which are inherent in the work or environment, shall be safeguarded by means of face or eye protection. Suitable screens or shields isolating the hazardous exposure may be considered adequate safeguarding for nearby employees. Note:  Anyone at risk of an eye injury needs protection!

Types of Eye Protection:  Employees are often exposed to hazards such as flying particles, chemical splashes, and intense light from welding operations. These hazards make appropriate eye protection necessary,

Safety Glasses	– Basic protection against flying objects and large particles. – Must meet ANSI Z87.1 standards. – Limitations include gaps allowing potential entry of chemicals and vapors.
Safety Goggles	– Provides basic protection of safety glasses but includes 360° coverage around the eyes with no gaps. – Additional protection to eyes against chemical splashes (i.e. battery explosion) but doesn’t provide protection to the face. – Ideal for use in scenarios involving battery handling and chemical exposure.
Face Shields	– Secondary protection, used in conjunction with safety glasses or goggles. – Essential for tasks involving splashing or spraying of hazardous materials. – Shouldn’t be used alone or in place of safety glasses/goggles.
Welding Goggles/Helmets	– Required for protection during welding activities. – Goggles: Used in OXYGEN torches when cutting or welding. Shade protection of 3 to 6 (depending on plate thickness) to EYES. –  Helmets: Used in GAS TUNGSTEN torches when welding. Shade protection of 7 to 10 (depending on arc current) to EYES and FACE.

Can I Wear Normal Prescription Lenses/Frames Instead? NO. Normal prescription lenses and frames DO NOT meet safety requirements, are not strong enough and haven’t been tested to ANSI Standards. Prescription Safety Glasses that meet ANSI standards [ANSI Z87-2+] or over-the-glasses safety glasses/goggles may be worn as substitute for safety glasses/goggles.

Eyewash Stations: Cal/OSHA requires eyewash stations (EWS) where employees may encounter corrosive chemicals and specifies requirements for eyewash stations, including accessibility and functionality criteria. Battery charging, battery filling, used battery storage, and use/dispensing of corrosive chemicals or irritants are processes that require the installation of an eyewash station. In general, Cal/OSHA refers to ANSI standards as the widely accepted guideline for the proper selection, installation, operation, and maintenance of emergency eyewash station equipment.  Note:  During routine inspections, remind employees to keep the area clear.

Does Parts Dept Need an Eyewash? YES. A big box warehouse store with multiple outlets in California was cited by Cal/OSHA for failure to have eyewash stations.  The employer appealed to Occupational Safety & Health Appeals Board (COSHAB) stating that the eyewash 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 of an eye injury from corrosive and irritating chemical, hence the requirement of an eyewash in the warehouse.  See OSHA Inspection 315340471. 

Eyewash Station (EWS) Selection: 

Water Temperature	-Tepid (60-100F).
Type	– Plumbed or Wall-mounted tank.-   Plumbed units are preferred where water lines are available and are generally better.
Flow	– Should wash both eyes at no more than 8” above the spray-head.-   Eyewash tester can be used to ensure these two requirements are met (Eyewash Tester).-   Flow needs to deliver at least 0.4 gallons of water/minute for 15 minutes.-   Flow pattern should be 33-55 inches from the floor.
Capacity	– Only applicable if using tank system: minimum capacity of 6 gallons.
Operation	– Can be operated hands-free with a stay-open valve that activates in under 1 second.
Covers	– Must have a cover that protects spray heads from airborne contaminants.-   Covers must move freely enough to be pushed open by the flow of water.

Eyewash Station (EWS) Location:

1	Within 10 seconds from the hazard (~55 ft).
2	On the same plane as the hazard.
3	Have a path that is unobstructed:·        In some instances, a free-swinging door with no handles may be allowed.·        If the chemical hazard is caustic (such as battery acid) the eyewash station needs to be available directly and not through a door.
Clearance	– At least 30 inches clearance on all sides from any obstruction: ▪   48 inches from back wall or nearest permanent obstruction. ▪   27 inches of knee clearance below the unit.
Identification	–  Must be in a well-lit area and include a highly visible sign. –  A “Do NOT BLOCK” parameter is highly recommended to ensure clearance.

EWS Maintenance, Cautions, and Common Misconceptions:

Inspect and perform weekly activations. A weekly maintenance/activation log needs to be maintained and 90-day flushes for wall-mounted units also need to be performed/documented.

–   Any valves on the supply line to plumbed units need to have their handles removed

–    Water hoses, sinks, faucets, showers, and eyewash bottles DO NOT comply with Cal/OSHA standards

–    Handheld Drench units support but do not replace a dedicated EWS

–    Single step into an enclosure where EWS can be accessed is not considered to be an obstruction

o   HOWEVER – this must also meet wheelchair accessibility requirements where applicable

–    PARTS department dealing with any chemicals that can cause Corrosion, Severe Irritation, or Permanent Tissue Damage (battery acid) also need a dedicated EWS

Conclusion:

Adhering to these guidelines for eye protection and eyewash stations is essential to safeguard your employees from potential eye injuries and ensure regulatory compliance. By implementing comprehensive safety measures, we can reduce the risk of injury and promote a safe working environment.

This newsletter does not cover all necessary elements of the standard.  We merely summarize some important elements.

Ref: CAL/OSHA: Title 8 CCR 5162, 3382     FED: 29 CFR 1910.151(c) ,133 (a) (1) ANSI: Z87-1, -2+, 358.1-2014

DISCLAIMER: The contents of this newsletter are 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 across the United States comply with EPA and OSHA regulations for over 38 years. Sam is a Certified Safety Professional (No. 16515) certified by the 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). Sam is a member of the American Chemical Society (No. 31176063), American Industrial Hygiene Association (No. 124715), and National Association of Dealer Counsel (NADC). Sam also serves on the Board of Orange County American Industrial Hygiene Association and on CA Industrial Hygiene Council (CIHC). Our newsletters can be accessed at www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com.