Eyewash stations: Although not a regulation, ANSI Z358.1 wields influence

What is tepid water? For the purposes of eyewash safety, the American National Standards Institute (ANSI) defines it as between 60°F and 100°F. ANSI’s threshold—noted under its standard, ANSI Z358.1, Emergency Eyewash and Shower Equipment—is important because OSHA inspectors and Joint Commission (formerly JCAHO) surveyors rely on it to guide enforcement of eyewash station and emergency shower provisions.

According to several hospital safety professionals who shared information about their Joint Commission surveys with Briefings on Hospital Safety, achieving tepid water isn’t always easy, and their eyewash stations didn’t pass muster with surveyors.

Steven MacArthur, safety consultant at The Greeley Company, a division of HCPro, Inc., in Marblehead, MA, says other typical eyewash compliance issues include the following:

• Inadequate or not fully accessible eyewash and emergency shower facilities in areas where there are chemical exposure risks
• Inadequate testing frequency (ANSI Z358.1 recommends weekly testing)
• Failure to understand what level of eyewash and emergency shower services are required, which is dictated by information on material safety data sheets (MSDS)

(For a rundown of ANSI Z358.1’s provisions, see “How ANSI eyewash requirements tie into OSHA” on p. 6.)

Let chemical risks guide you

The process for managing eyewash stations doesn’t start with an MSDS, MacArthur says. Determining chemical exposure risks in any area with eyewash stations is the first step, and once you know that risk, review the corresponding first aid information on the MSDS, he says.

At this point, you may be able to forego an eyewash station in a given area completely unless the first aid information indicates a flushing time of 15–20 minutes for eye exposures, MacArthur says.

OSHA requires the use of eyewash stations only for certain types of materials, generally corrosive or caustic substances. That 15–20 minute time frame is a good indicator of whether you need eyewash equipment.

“Remember, from a Joint Commission perspective, if you have an eyewash station, there is an expectation that you will appropriately maintain it,” MacArthur says. “There is no point in leaving yourself open to a citation for a piece of equipment that is not necessary.”

If you decide that you need an eyewash station, you must determine how to care for and maintain the equipment. There are many factors to consider—a Google search of “ANSI eyewash standard” yields links to several checklists and guidance documents, some of which indicate the specifics of the ANSI standard, MacArthur says.

Back up your eyewash decisions

Things can get tricky from a regulatory compliance standpoint. ANSI Z358.1 is considered a consensus document and thus nonbinding, but it can be cited as a best practice. “That’s where trouble can start if you do not toe the ANSI line and haven’t conducted a risk assessment,” MacArthur says.

The risk assessment is key because it gives a hospital a means to defend itself when confronted by a surveyor if, for example, the facility performs less frequent testing than the standard recommends, he says.

“This all comes down to the elimination or reduction of risk to the lowest potential,” MacArthur says. “If you have adopted a lesser strategy than what is a nationally recognized best practice, then you’d better have a good reason for having done so.”

Such a determination cannot be subjective. “[It needs to be] backed up by occurrence data,” MacArthur says. “These choices should be based on science and nothing else.”

An online Joint Commission FAQ about eyewash testing mirrors this approach. “If the organization has defined a frequency substantially less than is generally observed, then documentation should be available to support the rationale,” the FAQ states (go to www. jointcommission.org/Standards/FAQs for the full version).

One more note on tepid water: Some hospitals that received citations from The Joint Commission for eyewash water temperature—specifically, eyewashes connected to the plumbing and not stand-alone stations—tell us they have satisfied surveyors by simply disconnecting the hot water and running only cold water through the eyewash.

Although that might prevent water from getting too hot, it might not necessarily make it tepid or safer, especially in colder climes where water comes out of the pipes cold year-round, MacArthur says. Test your systems and plug those data into your risk assessment before implementing this fix.

Note the flexibility offered by ANSI

ANSI Z358.1 isn’t actually written by ANSI, says spokesperson Elizabeth Neiman. That job belongs to the International Safety Equipment Association (ISEA), a consortium of personal protective equipment manufacturers. An ISEA product group develops the eyewash standard and updates it every five years after debating proposed changes and taking into account pub- lic input.

OSHA, The Joint Commission, and other organizations latched onto ANSI Z358.1 because it is the only existing eyewash standard, says Cristine Z. Fargo, ISEA’s manager of standards programs.

“The standard is pretty straightforward,” Fargo says. Reading the standard might be overwhelming because of its flexibility, but a hospital’s risk assessment narrows the choices. “There’s a lot of latitude in there for configurations of what people [can] put in their facility,” she says.

Watch for an updated standard

ANSI Z358.1 is due for a revision this year, and ISEA is in the process of considering input collected earlier this year from industries, the public, and end-users.

A new version of the eyewash standard could be out later this year, possibly in the third quarter, Fargo says. That timetable could change if ISEA determines that changes are substantive enough to call for another round of public comment and review.

New items under consideration include:

• Certification criteria for self-contained eyewash and facewash equipment
• Changes to water pattern requirements for ANSI-compliant eyewashes, which would update them to accommodate new systems (e.g., models that run at lower water pressure) introduced since the last revision of the standard
• Updating generic illustrations for eyewashes to more accurately reflect the range of equipment on the market

“It’s not a completely radical change in criteria from what was in 2004,” Fargo says, stressing that these items may not make it into the final version.

Test and regulate water temperature

Fargo echoes MacArthur’s concerns about disconnecting hot water pipes to eyewashes as a general best practice.

At the low end of the temperature spectrum, employees probably aren’t going to stand for a 15-minute flush—especially in an emergency shower—when the water’s only 60°F, Fargo says.

Moreover, there is evidence that water hotter than 100°F can worsen damage from chemical exposures, she explains.

Hospitals can avoid Joint Commission survey issues by doing their homework, says MacArthur. That includes first reading ANSI Z358.1, understanding its principles, and then following it up with a detailed risk assessment that takes into account MSDS information.

Fargo says hospitals can obtain good, specific advice on their eyewashes from the manufacturers, who can offer recommendations for setting up and maintaining eyewash systems.

“They are the best people who know what their equipment is capable of doing,” Fargo says. “They have experience in user mentality, experience with the equipment, and experience … with the exposures for which this equipment may be needed. They are an extremely helpful resource.”

Some manufacturers of eyewash and emergency shower equipment offer online checklists that will help you meet the provisions of ANSI Z358.1.

How ANSI eyewash requirements tie into OSHA

It might be confusing that American National Standards Institute (ANSI) standard Z358.1, Emergency Eyewash and Shower Equipment, is a nonbinding standard that doesn’t apply specifically to hospitals—yet it’s a pivotal document for your safety program.

That’s because OSHA’s medical services and first aid standard (1910.151) calls for “suitable facilities for quick drenching or flushing of the eyes” where workers might be exposed to corrosives.

Further, a 2002 OSHA interpretation letter states that OSHA inspectors may use the ANSI standard as a determinant as to whether eyewash facilities are deemed “suitable” under 1910.151. The agency also left the door open to “other recognized medical, technical, and industrial hygiene sources” beyond ANSI.

The ANSI standard calls for, among other things:

Weekly testing and activation

Annual inspection for compliance with Z358.1

Employee training on location and proper use

Developing a response plan for accidents

Tepid water temperature (between 60°F and 100° F)

Installation of the eyewash within 10 seconds of the identified hazard

Editor’s note: To read the full version of the OSHA first aid standard, go to www.osha.gov and search for “1910.151.” To read the above-referenced OSHA interpretation letter, search for “interpretation Z358.1” and look for the November 1, 2002, letter.

Sources: OSHA, ANSI, and Guardian Equipment in Chicago.