Q&A: Emergency Shower Installation Requirements

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Question:

I currently have an indoor safety shower, and want an outdoor safety shower just outside the building, does the supply need to be sized in case both showers are used at once?

Answer:

OSHA’s applicable regulation is 1910.151(c): “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.”

This is a performance based regulation because it states what the safety shower must accomplish to meet the regulation. This is different from a prescription based regulation that defines an action or a limit, like the occupational noise exposure limit of an 85 decibel limit over eight hours. A prescriptive regulation is the result of a threshold being tested enough times to ensure safety within the stated limit.

The key word to the regulations is “suitable”, meaning the emergency shower has to work good enough considering the hazards at that particular worksite. OSHA explains its stance in an interpretation of the regulation:

“29 CFR 1910.151(c) does not provide specific instruction regarding the installation and operation of emergency eyewash and shower equipment. Therefore, it is the employer’s responsibility to assess the particular conditions related to the eyewash/shower unit…to ensure that the eyewash/shower unit provides suitable protection against caustic chemicals/materials to which employees may be exposed.”

Over the years OSHA has published several interpretations on this regulation, answering questions submitted to them.

In them OSHA refers employers to ANSI Z358.1. The American National Standards Institute (ANSI) is a private organization that develops voluntary standards. Unlike others, OSHA did not adopt this standard, but refers employers to it as a guide with detailed information for installing and operating emergency eyewash and shower equipment. But that means any citation will be the result of not having a suitable emergency shower for the workplace condition.

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