As usual, I'm going to ask more questions than provide answers. However, many people look for regulations to provide an answer before they define all the questions. The regulation will depend on whose jurisdiction you fall under. OSHA? State OSHA? JCAHO? Others? Are drains a requirement or a recommendation? What is the authority of the survey team that made the citation? What specific regulation did they cite, or was it "you really ought to have these"? Is there a dispute mechanism? What would happen if you disregarded their citation? Of the contending forces, whom can you afford to make unhappy? Why do you have showers? They do require maintenance, testing, and provide opportunities for vandalism, and accordingly should not necessarily be installed automatically unless there is a hazard for which they are needed. In what scenario would you use them? Do you work with corrosives? (The key issue for OSHA.) Are they needed for a biosafety issue? If there is a hazard present in the workplace that would require their use, OSHA at least would require you to keep them (see 29 CFR 1910.151(c)). Do you have a Lab Chemical Hygiene Plan (29 CFR 1910.1450), and if so, what does it say on the subject? In locations that handle large amounts of chemicals, drains are sometimes prohibited by environmental agencies because a nearby chemical spill could go into the drain. That doesn't sound like your operation, though, and you say the showers are in the halls. I'm not expert in JCAHO, but I'd bet they have something to say on the subject. Warren C. Pinches, CSP, CHMM Purely personal, probably misguided, and possibly deranged opinions. "Donald A. Wiebe"
Sent by: DCHAS-L Discussion List 08/08/2003 11:56 AM Please respond to "Donald A. Wiebe" To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU cc: Subject: Safety Shower Requirement I'm looking for input on safety regulations with regards to laboratory showers. We have several showers located in the hallways around our clinical laboratories at the University of Wisconsin Hospital and Clinics. A State of Wisconsin survey team have sited us for having these showers and not providing drains below the showers. Their recommendation is to put in drains or remove the showers. The UW hospital safety officer in formed me they plan to remove the showers - unless I can find a regulation that would argue in favor of these safety devices. Can anyone point me in the right direction? Seems like we make strides in the right direction and then can quickly retreat! Thanks for any input! Donald A. Wiebe, PhD Madison, WI
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