Date: Thu, 10 Nov 2005 10:23:11 -0800
Reply-To: "Larry D. McLouth" <LDMcLouth**At_Symbol_Here**LBL.GOV>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Larry D. McLouth" <LDMcLouth**At_Symbol_Here**LBL.GOV>
Organization: Lawrence Berkeley National Laboratory
Subject: Re: More Safety Eyewash and Shower Question
Comments: To: Gordon Miller
In-Reply-To: <p06110403bf991cb0bf6f**At_Symbol_Here**[]>

You're right least in the more moderate climes this is largely 
ignored.  Pipe insulation and both anti-freezing and anti-scalding 
valves are often used to deal with temperature extremes associated with 
units located outdoors. Tempered water can be provided with hot and cold 
water mixing valves or with heat exchanger units. You should check out 
the Haws website - they have a bunch of info

OSHA doesn't have much to say about eyewashes and safety showers. 
29CFR1910.151(c) states:
/"Where the eyes or body of any person may be exposed to injurious 
corrosive materials, suitable facilities for quick drenching or flushing 
of the eyes and body shall be provided within the work area for 
immediate emergency use."/ requires "adequate flushing facilities"

The non-mandatory  Appendix A to the Lab Standard gives additional details.

In case you're wondering - OSHA does not have the authority to cite ANSI 
Z358.1, or any other standard which hasn't been adopted through the rule 
making process.  Here are a couple references that may be of interest.

In a letter of interpretation entitled "ANSI Z358.1 Guidance for 
Complying with 1910.151(c) Citation Policy for Eyewashes and Showers"  
(04/18/2002), OSHA concedes they do not have the authority to cite 
employers on ANSI standards that have not gone through the official rule 
making process.  This interpretation states:  /"ANSI standards become 
mandatory OSHA standards only when, and if, they are adopted by OSHA; 
ANSI Z358.1 was not adopted by OSHA."/

In a second letter of interpretation entitled: "Additional Clarification 
of Using ANSI Z358.1 as Guidance to Comply with 1910.151(c)" 
(11/01/2002), OSHA expands on this: /"ANSI standards become mandatory 
OSHA standards only if, and when, OSHA adopts them. Since OSHA has 
adopted neither the 1990 nor 1998 version of ANSI Z358.1 standard, OSHA 
does not enforce either standard."

/Hope this helps.


Gordon Miller wrote:

> How are people dealing with the tepid water requirement of ANSI Z358.1?
> Looking on the Web, it looks like its not really being honored.
> The temperature range for 'tepid" is defined in Section B6 of Appendix 
> B as being from 60 to 100 degrees F.
> So some more questions:
> *  How do people who have tepid water units verify temperatures? By 
> feel? By measurement? If measurements are used, please describe the 
> procedure used.
> *  Let's say the shower is indoors. Does someone have an idea of how 
> long the tepid water lasts before the temperature drops to water main 
> or ground temperature?
> *  Let's say the shower is outdoors. Are there ways of avoiding water 
> temperature extremes without a tepid water unit? Pipe insulation? More 
> deeply buried supply lines?
> *  Finally, tepid water units are mechanical devices with potential 
> reliability issues of their own. Are they reliable? What sort of 
> inspection and maintenance procedures do people have for them?
> "Inquiring minds want to know."
> Gordon Miller
> Lawrence Livermore National Laboratory
> P.O. Box 808  (L-379)
> Livermore, California 94550
> (925) 423-8036
> Fax (925) 422-5176
> miller22**At_Symbol_Here**

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