Medical Environment Update
September 1, 2016
SECTION: Vol. 26 No. 9 ISSN: 1520-8222
Editor’s note: In this story, which originally appeared in Facility Care, consultant Brad Keyes, CHSP, explains the complex world of eyewash stations.
When and where are eyewash stations required in a healthcare facility? This is one of the more frequent issues with which healthcare professionals struggle. There is a tendency to place these stations nearly everywhere, but in reality there aren’t as many locations that require eyewash stations as one may think.
Eyewash stations are required wherever there is a possibility that caustic or corrosive chemicals could splash into an individual’s eye. It is important to note that blood and body fluids are not considered to be caustic or corrosive. It is also important to note that the use of PPE such as face shields, glasses, or goggles does not exempt a facility from needing an eyewash station.
Where to place a station
Most accreditation organizations base their positions on whether an eyewash station (or an emergency shower) is required on the healthcare organization’s decision to conduct a risk assessment, and on the findings of that assessment. Areas where work is done with corrosive and caustic chemicals do not necessarily require an eyewash station or emergency shower unless chemicals could be splashed into the eyes or onto the skin. An exception is if an eyewash station is part of regulation or accreditation requirements.
For example, if an environmental services worker opens a 1-gallon container of a liquid cleaner that is considered caustic or corrosive, and inserts a suction tube for a mixer, that may not present much of a splash hazard, and a risk assessment could state that an eyewash station is not warranted.
On the other hand, if the risk assessment determines the removal of the suction tube constitutes a splash hazard, then an eyewash station would be required. Similarly, if the employee pours this chemical from its original container into another container, now the risk of a splash is much greater, and a risk assessment would likely require an eyewash station. All risk assessments are conducted with the presumption that staff will not be wearing any PPE, although eye protection, face shields, and gloves and aprons must be worn during the use of caustic or corrosive materials.
If there are no corrosive or caustic chemicals present, there is no need to conduct a risk assessment and therefore no need for an eyewash station. Whether the term “corrosive” or the term “injurious corrosive” is used to describe a chemical, it’s all the same. Either would cause an injury.
If there is a possibility that a corrosive or caustic material can be splashed onto the skin, then an emergency shower is required. But if a risk assessment determines there is no possibility of the chemicals splashing onto the skin through normal use, there would not be a requirement for an emergency shower. The risk assessment should also consider emergency spills as well. Just like eyewash stations, if regulation or accreditation standards require the presence of emergency showers, you would need to install one regardless of whether corrosive or caustic materials are present.
No fair substitute
While portable squeeze bottles are not prohibited, they are not a substitute for an approved ANSI Z358.1-2014 eyewash station because they don’t provide hands-free use and do not flow water continuously for 15 minutes. In fact, portable squeeze bottles are a potential problem for healthcare organizations since they are usually placed around an area where a potential hazard may occur. In other words, they are placed in locations where somebody decided that there is some sort of splash risk present and that a portable bottle would be of some use. This can lead to the incorrect assumption that portable bottles are an approved eyewash station.
In addition, portable squeeze bottles need to have their water changed every two years or so, and that can be overlooked at times, leading to a citation. Also, these bottles are a huge red flag to a surveyor-once he or she sees the portable bottle, a tracer is likely to follow.
A mandatory guidance?
The ANSI Z358.1-2014 standard for eyewash stations is based on recommendations from OSHA letters of interpretation. OSHA requires an employer to provide suitable facilities for quick drenching or flushing of the eyes and body when employees may be exposed to injurious corrosive materials. ANSI standards become mandatory OSHA standards only when they are adopted by OSHA. ANSI Z358.1 has not; however, it provides detailed information regarding the installation and operation of emergency eyewash and shower equipment. OSHA, therefore, has often referred employers to ANSI Z358.1 as a source of guidance for protecting employees who may be exposed to injurious corrosive materials. Accreditation organizations seem to have latched on to ANSI Z358.1 as the standard with which to comply.
A proper assessment
The organization is expected to conduct a risk assessment (or survey) of its facility’s operation and process areas to determine if and where eyewash stations are needed. If the facility has determined that an eyewash station is needed, that station needs to conform to ANSI Z358.1-2014, which has the following specifications:
* Only eyewash stations that are capable of providing a flow of clean, potable water at a rate of 0.4 gallons per minute at 30 psi for 15 minutes are permitted. Some self-contained eyewash stations provide this flow requirement, but normally plumbed eyewash stations are installed.
* The flow nozzles of the eyewash station must be mounted a minimum of 33 inches and a maximum of 45 inches above the floor, and a minimum of 6 inches from any wall, post, or other barrier.
* Activation of the eyewash station must occur within one second or less of operating the control valve, so this typically eliminates the faucet-mounted eyewash stations that require the operation of three -levers to obtain a balanced flow of water. The control valve must remain open on its own until it is intentionally turned off.
* Approved eyewash stations are required to be located within 10 seconds’ travel time (or 55 feet) of the hazard, and the path to an eyewash station must not be hindered or obstructed. The ANSI Z358.1-2014 standard has changed (for chemicals NOT considered to be corrosive) to allow one door in the path to an eyewash station, provided the door cannot be locked and the door swings toward the eyewash station.
* While there is no standard that prohibits small, supplemental personal wash bottles, they cannot meet the flow rate requirements for a 15-minute flush, and therefore are not a substitute for a plumbed eyewash station. They can serve as a supplemental aid, but the plumbed eyewash station still needs to be located within 10 seconds’ travel time (or 55 feet) of the hazard. The presence of personal wash bottles may indicate a need for a plumbed eyewash station.
* The temperature of the water must be tepid. The ANSI standard defines tepid water as being between 60 and 100 degrees Fahrenheit. To achieve this temperature range, the organization may have to install mixing valves. Some accreditation organizations allow water temperatures outside of this range, provided a risk assessment is conducted by qualified individuals who analyze the hazard and the temperature of the water to flush the hazard. Qualifying individuals must include an individual with clinical or medical training.
* Weekly activation of the plumbed eyewash stations is required to clear any sediment or bacteria. There is no specified time that the water must flow. An annual inspection of the eyewash station is required to determine conformances with the installation requirements are maintained.
Tips for evaluating compliance
Here are some recommendations on evaluating your existing eyewash stations for compliance:
* In a healthcare setting, eyewash stations are typically found where cleaning chemicals are mixed (such as housekeeping areas); where plant operations take place; and in kitchens, generator rooms, boiler rooms, environmental services storage rooms for battery-powered floor scrubbers, in-house laundries, dialysis mixing rooms, and laboratories. Find out whether a risk assessment has been conducted to determine the need for eyewash stations.
* All required eyewash stations must be operated in one second or less. This means the faucet-mounted type that requires turning aa hot water lever and a cold water lever, and then pulling a center lever, is not permitted.
* Access to the eyewash station must be within 10 seconds (or 55 feet) of the hazard. The individual seeking an eyewash station may travel through one door to get to an eyewash station, provided the chemical is NOT corrosive and the door is unlockable and swings toward the eyewash station.
* If an eyewash station is observed outside of an area where one is typically needed, ask the staff who work in the area why it is there. See if they have conducted a risk assessment that requires it to be there. Advise them that if there is no valid reason for the eyewash station to be there, it can be removed, which may save them the time and resources spent in maintaining it.
* Eyewash stations may need to have a mixing valve to maintain a flow of water in the 60- to 100-degree Fahrenheit range. Ask to see the risk assessment to determine whether a mixing valve is required.
* Every plumbed eyewash station needs to be tested weekly by flowing water to clear any sediment and bacteria. There is no requirement regarding how long the water must flow. Every eyewash station must be inspected annually to determine whether the eyewash station still conforms to the installation parameters. The weekly test and annual inspections must be documented.
* The presence of eyewash bottles indicates someone in the organization decided the bottles were needed. Investigate and ask why the bottles are there. Determine whether there is a need for a plumbed eyewash station within 10 seconds’ travel time (or 55 feet) of the perceived hazard. Check the expiration date on the bottles.
* Finally, always check with your state and local authorities to determine whether they have any additional requirements.