Occupational hearing loss affects millions of workers across the country. This type of injury can severely limit an individual’s ability to function normally, and reduces their quality of life. Businesses can expect to see a negative impact on productivity and profit as well as an increase in lost-time and workers’ compensation claims, leading to numerous additional hidden costs. Not only is it in your best interest to limit noise exposure in order to protect your bottom line, it is your duty and responsibility to provide your employees with a safe and healthful workplace.
How Does The Ear Work?
Sound begins by hitting the outer ear. When this happens, vibrations move towards and touch the ear drum, which transmits them to the middle and inner ear. Once at the middle ear, three bones (the malleus, the stapes, and the incus – also known as the hammer, stirrup, and anvil, respectively), take the vibrations and amplify them towards the inner ear. Within the middle ear, the cochlea, a spiral-shaped section of the ear filled with fluid and hair-lined cells, take the vibrations and translate them into nerve pulses by way of movement of the microscopic hairs. This translation becomes the sound we hear. When extremely loud noise makes its way into the cochlea, these hairs can be damaged or destroyed, resulting in hearing loss.
Measuring Noise Exposure
When measuring noise, we observe unites of sound pressure levels called decibels (dB). This term originated in the early 20th century based on measuring telephony power in the United States, through the Bell system of companies. A decibel is one tenth of a bel, named after Alexander Graham Bell. The version of the measurement we use for occupational noise exposure is the A-weighted version (dBA), which gives less weight to very low and very high noise frequencies has a stronger correlation with noise-related hearing damage. Decibels are further measured on a logarithmic scale, meaning that a small difference in the number of decibels corresponds with a massive difference in actual noise, and thereby potential for hearing loss. Dangerous decibel levels require monitoring, planning, and controls to keep noise from causing worker injury. Any noise with a decibel measurement over 85 dbA is considered hazardous.
What Kind of Damage Can You Expect?
Workers exposed to high levels of noise can expect the potential for permanent hearing loss, even if the exposure is infrequent. Hearing lost in this way is irreparable; there are currently no surgical or auxiliary options available today which can repair loss caused by damaged or destroyed cochlear hair cells. Singular incidents of extreme noise exposure may also lead to short-term hearing loss or changes in hearing (e.g. an individual may feel like their ears are plugged, or hear a persistent ringing). While often temporary to a matter of minutes or hours, frequent exposure can easily lead to these symptoms being permanent. Furthermore, those with noise-related hearing loss may be unable to understand speech or recognize sounds at higher frequencies.
Physiological damage aside, excessive noise can also increase stress in afflicted individuals, both physically and psychologically. It can inhibit the ability to communicate effectively, and increase the potential for dangerous incidents by making it difficult to concentrate or hear important safety or warning alarms and signals.
Engineering controls are the most preferred option in any hazard-mitigation hierarchy. They essentially involve eliminating a hazard altogether through displacement, replacement, installations, or other physical changes. Where noise is concerned, engineering controls take the source of noise and either eliminate it or, somewhere along its path, intercept it and reduce it below hazardous levels before it reaches the worker. Examples include selecting equipment which generates less noise as the same efficiency, installing barriers such as walls or insulation between the source and the worker, maintaining noise-generating equipment (e.g. proper lubrication) to eliminate preventable noise, and isolating the noise altogether.
Administrative controls involve modifying procedures, schedules, or behaviors in order to reduce hazard exposure as much as possible. These controls fall just below engineering controls in terms of effectiveness and desirability. Some examples of administrative controls which can reduce noise exposure include scheduling workers in limited, short shifts to work in noisy situations, positioning work at a long distance from loud noise sources, providing quiet rest areas for reprieve and relief, and scheduling work which generates excessive noise while the fewest workers possible are on site.
Personal Protective Equipment
Although personal protective equipment (PPE) is the least effective control method for mitigating hazards, it should always be used in conjunction with the others. Workers involved in operations where noise levels are above 85 dBA should wear ear plugs or other noise-reducing or –cancelling devices, so long as they don’t interfere with the worker’s ability to work safely and communicate properly.
Hearing Conservation Programs
Developing a thorough, comprehensive hearing conservation program is essential in any business’ efforts to prevent hearing loss, protect existing hearing, and convey crucial information to workers in the form of knowledge and training. Employees from the top down need to know how to operate a workplace in such a way that everyone involved with noisy work is properly safeguarded. Employers need to measure and monitor noise levels in the work place, give workers access to hearing exams, and provide workers with necessary PPE and training.
Workplaces with strong hearing conservation programs see more productivity and fewer losses through injuries and lost-time claims. To learn how Safety Services Company can assist you with creating such a program, or perfecting an existing one, visit www.safetyservicescompany.com.
As we transition to warmer temperatures, it’s important to revisit your workplace’s Heat Illness Prevention Program to ensure your employees are equipped to combat heat-related stress and illnesses. Heat is the number one cause of weather-related fatalities in the United States despite the fact that most heat-related deaths are preventable.
Average high temperatures have seen a steady increase across the country over the past couple of decades. The Environmental Protection Agency (EPA) anticipates that average temperatures will continue to increase, and heat waves will become more frequent and impactful. This prediction should encourage all businesses to look at how their employees are exposed to high temperatures, and what they can do to accommodate.
Businesses with employees who perform work in moderate to high temperatures or humid conditions, especially where increased heart rate and perspiration are concerned, must be given the necessary tools to recognize, understand, and prevent heat stress illnesses.
Essentially, heat stress prevention comes down to workplace design, employee training, and effective work procedures. Design and procedures will vary greatly depending on geographical location and the type of work being performed. Businesses should keep in mind that heat stress can occur regardless of the time of year, in both outdoor and indoor conditions. Required personal protective equipment (PPE) can also have a significant impact on the body’s ability to expel heat. Workers involved with hazardous waste operations or asbestos removal, for example, are often required to wear impermeable protective equipment which can trap heat close to the body. A thorough risk assessment will help businesses identify risk elements such as these.
A strong working knowledge of how the body regulates heat, and how personal factors can affect that regulation, is an extremely valuable tool in prevention. The human body needs to maintain a core temperature between 96.8 (36) and 100.4 (38) degrees Fahrenheit to function at peak performance. Weather conditions, manual labor, and personal factors can cause the core temperature to increase, which can lead to the development of a series of heat-related illnesses.
To regulate internal temperature, the body uses two basic mechanisms. The first is to increase the heart rate which assists in moving blood and heat away from vital organs to the skin. The second is perspiration, during which the body expels heat in moisture through the pores, which then evaporates and carries heat away in the process. Personal factors, such as acclimatization, caffeine and alcohol consumption, hydration replenishment, general health, age, and certain prescription medications can affect how well these mechanisms work and should be taken into consideration before performing work in high temperatures. Perspiration is the more effective of the two mechanisms, which means that proper hydration to replenish fluids lost as sweat is absolutely essential.
There are four common disorders which surface as a result of heat stress, ranging from mild discomfort to life-threatening conditions:
Heat rash is the most common ailment which occurs while working in the heat. It is also called “prickly heat.” Symptoms include red, blotchy, itchy skin, particularly in areas of the body with high perspiration, and a prickling sensation. Rashes which aren’t cleaned thoroughly and frequently may become infected. Moving to a cool environment, cleaning the affected area with cool water, and complete drying are often effective treatments.
Heat cramps occur as a result of salt being lost through perspiration. They are painful muscle spasms causing lumps in the affected muscles, usually the back, legs, and arms. The pain can be severe enough to greatly inhibit movement. Workers should cease activities to tend to cramps as soon as they feel them. Stretching and massaging the affected muscle as well as replacing salt by drinking electrolyte replacement fluids are useful techniques in tending to heat cramps.
Heat exhaustion is a dangerous result of heat stress which can lead to a heat stroke if not treated promptly with first aid. It happens when the body is so overexerted that it cannot supply blood simultaneously to vital organs and the skin for temperature regulations. Inflicted workers may experience weakness, headache, breathlessness, nausea, vomiting, faintness, or loss of consciousness. Call 911 and move workers exhibiting these symptoms to a cool place and give them water to drink. Remove any clothing that isn’t necessary and loosen other clothing. Shower or sponge them down with cool water. It will take at least 30 minutes for the body to cool down after experiencing heat exhaustion.
Heat stroke is a disorder which requires immediate medical attention, and can lead rapidly to fatality if not treated quickly. A person experiencing a heat stroke may experience confusion, hot, dry skin, high body temperatures, lack of sweating, irrational behavior, convulsions, and/or a loss of consciousness. Call 911 right away and take the victim to a cool area to immerse or shower them with cool water. Wrap them in wet sheets and fan them until you can transport them to a hospital or an ambulance arrives.
Knowledge can mean the difference between life and death during a critical victimization of heat stress. Workers should understand the nature and symptoms of heat-related illnesses both in a sense of recognizing them in themselves, and when a coworker is suffering. In many cases, a quick and efficient response can save a heat stress victim from numerous long-term effects that would have otherwise occurred had symptoms gone untreated. Proper training and a strong Heat Stress Prevention Program will help protect worker health year round.
Workplaces are feeling the effects of both medical and recreational marijuana legalization. These new laws are making it more difficult to discipline someone who tests positive for marijuana. Ambiguous language protects impaired drivers from prosecution and makes it hard for employers to prove impairment at work.
Unlike alcohol, a test that shows level of marijuana impairment is not available. Instead a person can test positive weeks after using marijuana. One alternative approach to simply banning marijuana use as a component of the company drug and alcohol policy is to cover impairment in the safety policy under fitness for duty.
Start off by requiring employees disclose when they start taking any drug that causes impairment when working a safety sensitive job. This can be marijuana or a cold medicine, and the employee doesn’t have to disclose the drug or medical condition.
Be sure to update all job descriptions to define all safety sensitive jobs in compliance, by just listing essential job functions. Have a policy that states when an employee works in a safety sensitive job they should be able to work in a constant state of alertness and in a safe manner, and disclose when they have taken an impairing effect prescription or other substance.
Then the employer has the right to make a fitness for duty determination or send the employee to an occupational doctor for a fitness for duty evaluation with a copy of the job description. If it comes back that they are impaired and didn’t tell you, then you can manage that under your safety policy, and not your drug policy.
Make sure that all employees have a copy of the written company policy and education on drug and alcohol abuse that includes where to get more information. Supervisors need recurrent training on the effects of drugs and alcohol and how to determine reasonable suspicion.
Everybody needs to know the company position on medical and recreational marijuana and other prescription drug use through a consistent and proactive policy that includes appropriate testing.
The strong cultural presence, acceptance and legality of alcohol make it easy to forget what an impact it can have on health. In 2014, according to the World Health Organization, there were over 300,000 alcohol-related deaths in the United States alone, and over 3 million worldwide.
In 2013, over 10,000 people were killed in traffic collisions where alcohol was involved, accounting for 31 percent of all vehicle fatalities. To understand how profoundly drinking alcohol can affect the safety of a workplace, it’s important to learn how it affects the body. When we drink, alcohol’s active ingredient, ethanol, is absorbed into the blood stream and begins to interrupt chemical processes in the brain that ordinarily allow it to function normally. Contrary to popular belief, alcohol doesn’t actually kill brain cells but rather damages nerve cell endings, which bring messages to the cells, leading to a change in overall brain function.
Typical symptoms of alcohol consumption often include slurred speech, clumsiness, and slowed reflexes, all highly dangerous conditions, especially in situations where hazardous work is concerned. Brain function is only a small area affected by alcohol – it can damage the heart, liver, and pancreas as well, and has been linked to several forms of cancer.
The consumption of alcohol can bring extreme hazards to every workplace environment; however, the associated risks are heightened where hazardous machine operation or vehicle use are required.
Additionally, workers who drink heavily are more likely to work at reduced capacity and call in sick, leading to losses in productivity. Workplace effects are noticeable even when alcohol is consumed by a worker the night before a given work day.
How long can alcohol remain in our system? It can vary, depending on multiple factors: body weight and body fat affect the rate of alcohol absorption. Alcohol can be detected through urine testing and, considering the amount of alcohol ingested, can still be evident up to four days after consumption.
In order to protect workers from the harmful effects of alcohol-related incidents in the workplace, a Drug Free Workplace Program (DFWP) with associated training is necessary.
To find out more about how Safety Services Company can help develop a DFWP unique to your business, visit safetyservicescompany.com.
The U.S. Bureau of Labor Statistics reported that there were over 200,000 cases involving falls, slips, trips in 2012, and that’s not counting the ones that went unreported.
Many safety professional believe that these accidents are among the most under reported incidents. If you add in the slip or trip injuries that are reported incorrectly because they resulted in strains and sprains or are “bodily reaction” (a slip/trip/balance issue that didn’t result in impact)?
This issue affects companies worldwide. A 2013-14 report from Great Britain estimated that falls and slips & trips accounted for over a third of all employee injuries
The level of these injuries has been holding steady over the last few years, and even with best engineering and administrative controls, PPE, and training the number don’t change much.
Perhaps it’s time to consider another option, instead of focusing on what happened and who is responsible; it’s time to examine “why did it happen?”
There are studies indicating that mental factors can cause accidents. Attention lapses and distractions may account for many of these incidents.
A noted psychologist sees attention as having two dimensions: width and direction. Width means what you see and/or hear or smell or feel can be too broad or too fine. Direction refers to where you focus, either internally (proper procedures, a chronic pain in part of body, etc.) or externally (your surrounding or environment). We may so focused on our task that we fail to see that we could have walked around that slippery area, or are trying to be so externally aware that we didn’t notice we were holding our breath when walking on a slippery surface.
When you combine the estimate that 90 percent of the brain’s energy output is used for maintaining balance in space with other factors, it becomes easier to understand the even the most conscientious workers can become distracted.
The primary contributing factors most often cited are fatigue, stress, and age.
If workers are pushed, or pushes themselves too hard to keep up with their workload, physical and mental exhaustion can result. This can lead to impaired judgment, slower reflexes, a delayed response to emergencies, and inattention to details and instructions.
Job security, finances, health, and anxiety about personal issues can all increase a workers stress. When employees are distracted by real or perceived threats, they are more likely to make mistakes that could cause injury, and are more susceptible to increased risks of a heart attack, stroke, or hypertension.
Aging workers are more at risk for slips, trips, and falls. Than younger workers. The reasons for this can be:
It takes older people longer than younger people to reestablish their balance, due to lessened sensitivity of nerves in the inner ear that detect changes in balance.
Older workers may no longer have the leg strength to compensate for a slight loss of balance that can result in any misstep.
Vision changes that make it harder to see and adjust to surface changes or obstacles.
Loss of joint flexibility that can reduce agility
A fixation with the task at hand, a lack of awareness about your surroundings, and the inability to react to changing conditions, may all be contributing factors in slip, trip, and fall incidents.
Workplace safety isn’t just training and equipment; it’s a state of mind.
Near miss reporting is a fundamental piece of a strong safety culture. While OSHA doesn’t require near miss reporting, companies capturing that information can gain insight into potential problem areas. Understanding the difference between incidents, near misses, and accidents is important when developing a comprehensive safety meeting topics.
An Incident is an unplanned, undesired event that hinders completion of a task and usually causes injury, illness, or property damage. The terms “unplanned and undesired” don’t mean unpreventable, nor do they mean that you can’t prepare for them. Analysis and planning are how we prepare for serious incidents that may occur, and how we take action to eliminate them.
A near miss is defined as an incident that could have resulted in injury, illness, or property damage, but didn’t. Near misses, also known as ‘close calls’, should really be near hits.
The definition of accident is similar to that of incident, but implies that the occurrence was unpreventable. An accident, using this definition, contradicts the basic concepts of a safety program, which is to find and fix hazards, and prevent incidents. If we accept that accidents have no cause, that means they are unpreventable, and they will happen again.
Training employees on the importance of reporting near misses not only will raise their awareness of potential hazards; it moves your safety program from a purely reactive mode toward a more proactive effort. Near misses are often a precursor to more serious incidents, and may be a warning that procedures and practices need to be examined.
The reporting and investigation of near misses can be instrumental in preventing injuries. Near misses are really a zero-cost learning opportunity, because it signals a potential problem without resulting in injury or loss.
If your current safety program doesn’t include the mandatory reporting of near misses, perhaps it should. Consider implementing near miss reporting the next time you review your safety program, which you should do annually. This commitment to continuous improvement will demonstrate the importance of safety to your company to all employees.
Life doesn’t always give us warning signs, but when it does, we should heed them. Having an internal near miss reporting and investigation procedure as part of your safety program is heeding one of those signs. Being able to anticipate and avoid incidents is far less costly than reacting to one. An ounce of prevention could be worth someone’s life.
Unless you live in Arizona, Hawaii, American Samoa, Guam, Puerto Rico, or the Virgin Islands you will probably be changing your clocks this weekend as Daylight Savings Time (DST) begins this Sunday March 8th at 2 A.M.
The larger question these days is “Why do we even have daylight savings time?” DST was started during WW I as a way to conserve energy. The use of daylight savings time was unpopular and was halted after the war. It was re-instituted during WW II. Because there was no U.S. federal law requiring the use of DST following WW II, the states were free to implement DST on their own.
This created interstate commerce and transportation scheduling problems, and resulted in the passage of the Uniform Time Act in 1966. The act mandated time changes in April and October (spring ahead and fall back), but also allowed states to opt out of using DST.
Enforcing DST is the responsibility of the Department of Transportation (DOT)
Although created to conserve energy, recent DOT studies have shown that in today’s world, any potential energy savings is lost to the use of computers, TV’s, and other electronic devices. Not only does DST not save energy it can also negatively affect your health.
Researchers in Stockholm found that the number of heart attacks rose about 5 percent during the first week of daylight saving time. The New England Journal of Medicine suggest that this rise may result from the disruption of sleep patterns and biological rhythms.
Today most of the U.S., Canada, and Europe observe DST, and if you live where it’s observed, here are some tips to help you adjust to it.
Start going to bed 15 minutes earlier several days before the start of DST, and move your bedtime up by 15 minutes every couple of nights
If you feel sleepy the Sunday after the change to DST, take a short nap (15 to 20 minutes) in the early afternoon. For some, napping can make nighttime sleeping harder, while for others, a short nap can be refreshing without ruining their night’s sleep
Avoid sleeping in longer in the morning
Try to go to bed and waking up at the same time each day, as this will help regulate your sleep. If possible, get up at the same time on weekends, too, this makes getting up on Monday mornings easier
With the change in daylight, try to incorporate a little more exercise and a little more sleep each day
There are currently renewed efforts underway to abolish DST because of the lack of any evidence that it’s beneficial. It may well be that the only positive about the beginning and end of DST is that it serves as a reminder to check and or replace your smoke detector batteries. If you have any questions about topics for safety meetings contact us today.
Planning for an OSHA inspection with the proper safety meeting topics is good business. Take these 5 steps to prepare for a surprise worksite inspection and you’ll also have a solid foundation of safe work practices.
When you apply to have OSHA’s safety and health professionals evaluate the worksite, anything they find that needs to be fixed won’t result in a compliance citation as long as it is put right.
2. Make sure you and every other employer understands their responsibilities when it comes to the hazards at each worksite.
Known as the “three Cs”, OSHA can cite employers if they: create the hazard, have control of the worksite, or are responsible to correct the hazard. This means different employers can be cited for the same hazard based on their responsibility for it.
3. Establish your rights.
Ask why the OSHA inspector is at your worksite because they need a legitimate reason. This probable cause can be: reported cases, complaints, targeted inspections or expressed points of emphasis, planned inspections, and even a compliance officer seeing a violation from the street.
Ask for a copy of the complaint/reason before they begin the inspection.
You have the right to restrict an inspection to the scope of the reason they are there. This could be a fatality, reported incident, or complaint. But be aware that anything the inspector sees during that inspection is fair game.
4. Know that OSHA can ask any employees questions in a private interview.
So the employer should make sure every employee can explain they know how to be safe at the worksite.
This also means they don’t have to answer any questions. If it’s the end of a long work day, and they have arranged a carpool, or if they are just shy they don’t have to answer any questions. Just don’t tell the workers you don’t want them to answer any questions, it’s their right to decide if they want to or not.
5. Managers will receive extra scrutiny, so train them up.
Whoever is responsible for the safety of others must know how to ensure it, including being aware of the hazards and the safe ways to mitigate them. The threshold for what OSHA considers a manager is low and includes: working lead, acting foreman, and competent person.
Other Safety School articles that examine the more academic concepts of occupational safety:
Every year workers are killed or seriously injured while performing snow or ice removal from the rooftops of commercial, residential, and other building structures. Snow removal operations are often performed under extreme weather conditions by workers who may have little experience or training on the hazards of the job which is why having a safety manual can become very important.
Snow removal may be necessary to prevent overloading and collapse or for construction or repair of decking or roofs. Workers often climb directly onto the roofs or structures and use shovels, snow rakes, or snow blowers to remove ice and snow. Other times these operations are done from aerial lifts used to access roofs and apply de-icing materials, or from ground level using ladders and snow rakes.
Falls are the most common cause of worker fatalities and injuries during rooftop snow removal. Workers can fall off roofs, through skylights, or from ladders and aerial lifts.
In addition to falls, workers removing snow, face other significant hazards including:
Injuries from using snow blowers and other mechanized equipment
Collapses or tip-overs of aerial lifts
Becoming engulfed by falling snow
Being shocked/electrocuted from contacting power lines or using damaged extension cords
Frostbite or hypothermia
OSHA requires that employers plan and use the safe work practices to protect workers during snow removal activities. Before snow starts to accumulate, think about what will be needed to remove snow from roofs or other elevated surfaces safely:
Can the snow be removed without workers going onto the roof?
Are there any hazards on the roof that could become hidden by the snow and will need to be marked so that workers can see them (skylights, roof drains, vents, etc.)?
How to remove snow based on the building’s layout to prevent unbalanced loading?
Determine the maximum load limit the roof can handle, and compare that to the estimated combined weight of the snow, the removal equipment, and workers on the roof
What tools, equipment, PPE, clothing, and footwear will workers need?
What training will workers need?
How will snow removal equipment be moved to the roof?
How will you protect workers and others on the ground from the snow and ice being removed?
Remove Snow Without Going on the Roof
Whenever possible, use methods to clear ice and snow that don’t require workers to go on the roof, such as using ladders to apply de-icing materials or using snow rakes or draglines from the ground.
Use Required Fall Protection
Falls cause most of the deaths and severe injuries that occur during snow removal operations. OSHA requires employers to evaluate and protect workers from fall hazards when working at heights of 4 feet or more above a lower level (1910.23), 6 feet, or more for construction work (1926.501).
If workers must access roofs and other elevated surfaces to clear snow:
Train them on fall hazards and the proper use of fall protection equipment,
Ensure all workers use their fall protection equipment when removing snow in areas that are not adequately guarded
Have workers put on their fall protection equipment before accessing the roof
Have a written rescue plan in case a fallen worker becomes caught by a fall protection system
Remove or mark rooftop or landscaping features that could present trip or fall hazards
Workers at ground level removing snow from the roof, and bystanders, can become trapped under snow falling from roofs and suffocate. Snow being removed for a roof can be dangerous. One cubic foot of dry snow weighs about seven pounds, while a cubic foot of wet snow weighs anywhere from 12 to 18 pounds. To protect personnel from removed snow:
Identify a safe work zone in the area where snow is being removed to keep the public back 10 feet from where snow is expected to fall
Instruct workers to wear eye and head protection when removing snow and ice.
Instruct workers using snow rakes and draglines to remove only small amounts of snow at a time.
Effective planning and preparation can protect workers and the public from injuries during snow removal work.
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?
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.