Date: Tue, 31 Aug 2004 21:56:31 GMT
Reply-To: "mrsafetyman**At_Symbol_Here**" <mrsafetyman**At_Symbol_Here**JUNO.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "mrsafetyman**At_Symbol_Here**" <mrsafetyman**At_Symbol_Here**JUNO.COM>
Subject: Re: Eye injuries and green lights
Comments: To: info**At_Symbol_Here**ILPI.COM

Dear Doctor, I say go for it. The concept of a green light may be a good idea. There is no standard that advises against it. The OSHA standard for marking, safety instruction signs under CFR1910.145(d(6) states that a green panel with white letters are the colors that should be utilized. A green light supporting the signage would, in my mind, make identification much easier from a distance. Remember make sure that you train your employees as to the purpose of the green lights. In fact, i would love to see an illuminated bright red light above any fire extinguisher location. It is easier to see than signage. Again training employees as to the location of these devices is imperative. I have seen light identification used in some facilities. I also see that you spell the word color, colour. Now I am assumming Canadien? If so you may wish to check the codes that regulate the area in your country. Remeber OSHA has adopted only the 1990 ANSI standard but is issuing a directive to clarify. I have attached below a directives and letter of interpretation hope it helps. Emergency eyewashes/showers Sometimes employees need to work around hazardous substances. This puts them at risk of getting the substance in their eyes or on their skin. To combat this risk, personal protective equipment (PPE) is issued. However, if the protection supplied by PPE is breached, employees need to be able to remove the contaminant as quickly as possible. Eyewashes As an employer, you must provide suitable facilities for quick drenching or flushing of the eyes and body when employees are exposed to injurious corrosive materials. For specific requirements, OSHA refers to consensus standard ANSI Z358.1-1990 through the General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health (OSH) Act. OSHA specifically requires emergency eyewash/shower stations in a number of their regulations such as those for dipping and coating operations; medical services and first aid; pulp, paper, and paperboard mills; formaldehyde, and carcinogens. However, if employees are exposed to eye hazards that require quick, appropriate eyewash facilities, the requirement is there. The type, quality, and/or frequency of use of chemicals in a facility should help to determine whether the eyewash or shower stations are appropriate. Severity of injury, time of exposure, and number of employees exposed are all considered in determining the required number of eyewash stations, shower stations, or both eyewash and shower stations. The emergency eyewash and shower equipment must meet the specifications of ANSI 358.1-1990, to be acceptable to OSHA. Any improvement of quality and/or response time for commencing the eyewash procedure should also be considered. Just having an eyewash station, present, regardless of design, in not sufficient. The emergency eyewash and shower equipment must meet the specifications of ANSI 358.1-1990, to be acceptable to OSHA Eye/face wash units and emergency deluge showers both be located within 10 seconds of unimpeded travel distance from the corrosive material hazard or, in the alternative, within the distance recommended by a physician or appropriate official the employer consulted. Letter of Interpretation March 28, 2002 Mr. Scott King Manager-Technical Services NorFalco LLC., US Operations Independence, Ohio 44131 Dear Mr. King: Thank you for your letter to the Occupational Safety and Health Administration (OSHA). You requested an interpretation of 29 CFR 1910.151, Medical Services and First Aid, specifically, section (c) regarding, “suitable facilities for quick drenching or flushing of the eyes and body.” Your question has been restated below for clarity. Please accept our apology for the delay in this response. Background: Your company, a large manufacturer and distributor of sulfuric acid, requires the services of many third party terminals and distributors to assist with the handling of your product. You have specific criteria when acquiring a new terminal that it must meet before a contract is signed. One of these requirements is the need for safety showers that meet or exceed OSHA requirements; OSHA has quoted ANSI Z358.1-1990 in several letters of interpretation. However, there is a new ANSI Z358.1-1998 standard that goes into much more detail and would require some facilities to make a significant capital expenditure to comply. Question: Which ANSI standard does OSHA enforce? ANSI standards become mandatory OSHA standards only when, and if, they are adopted by OSHA; ANSI Z358.1 was not adopted by OSHA. In comparison with the OSHA standard at 29 CFR 1910.151(c), however, ANSI Z358.1 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 recognized source of guidance for protecting employees who are exposed to injurious corrosive materials. OSHA would also take the ANSI standard into consideration when evaluating the adequacy of the protection provided by an employer. OSHA recognizes that there are differences between the 1990 and 1998 versions of ANSI Z358.1, and is planning to develop a compliance directive addressing this issue to ensure uniform and consistent enforcement of 29 CFR 1910.151(c). In the meantime, employers should assess the specific conditions in the workplace and determine whether compliance with the 1998 version of the ANSI Z358.1 will provide protection for employees that compliance with the 1990 version would not. Thank you for your interest in occupational safety and health. If you have further questions, please feel free to contact the Office of General Industry Compliance Assistance at (202) 693-1850. Sincerely, John L. Henshaw ________________________________________________________________ The best thing to hit the Internet in years - Juno SpeedBand! Surf the Web up to FIVE TIMES FASTER! Only $14.95/ month - visit to sign up today!

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