I don’t have time to dig it up right now, but there is an EPA letter of interpretation that says that runoff from an emergency drench shower is not hazardous waste. So containment is only necessary if your local POTW is requiring it.
I agree with Rob Torecki,
This is a senseless regulation that would do much more harm than good, and presents a slip-and-fall hazard full time, not just when the emergency shower is in use.
I also agree with how dilute most chemical splashes would be by the time you dilute them with 15 minutes **At_Symbol_Here** 20 gallons/minute = 300 gallons of water.
Alan H. Hall, M.D.
Thu, 28 Oct 2010 14:55:20 -0400
Subject: Re: [DCHAS-L] Lab safety showers
Wow, thanks for sharing. That one is a poster child for Bad Regulations.
1. Let's say the berm encompasses a 4' x 4' area around the shower. That's 16 square feet, one inch high, for a volume of 1.33 cubic feet = 10 gallons. Under ANSI Z358, showers must put out at least 20 gallons per minute. And that shower is likely to flow for 5, if not 15 minutes. So the berm is essentially useless.
Now, if the reg is calling for a berm that say, stretches across an entire hallway or doorway - heck, or just around the drain itself, that might work by flooding the rest of the building, as all it does is make the floor drain non-functional. Plugging the floor drain permanently is an easier solution.
2. The amount of hazardous material on a victim is going to be so exceedingly small and so diluted in the drains that it boggles the mind. Seriously - you get what, 10 mL of concentrated acid on you and that washes down the drain with 100 gallons of water? Yeesh. And if the stuff was so nasty toxic that it is a hazard even that dilue, this city review department thinks it's better to spread the hazmat all over the building and down a couple floors onto various objects and people than it is to send it down the drain.
3. When you're blinded by something and trying to find a shower on foot or on a wheelchair, even that 1" sloped bump is a barrier. And no doubt a trip hazard the rest of time no matter how well it's marked with floor tape.
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On Oct 28, 2010, at 2:31 PM, Betsy Shelton wrote:
I am currently involved in construction of two new laboratories and was instructed by the city commercial building review department to include a 1" high curb around the shower area to keep hazmat from entering the floor drain in the event of a spill. Also, the curb has to be sloped on both sides to allow accessibility.
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