Date: Fri, 8 Aug 2003 16:08:11 -0400
Reply-To: Warren_Pinches**At_Symbol_Here**PRAXAIR.COM
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Warren Pinches <Warren_Pinches**At_Symbol_Here**PRAXAIR.COM>
Subject: Re: Safety Shower Requirement
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

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

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
        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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