Date: Tue, 2 Nov 2010 19:27:54 -0400
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: ILPI <info**At_Symbol_Here**ILPI.COM>
Subject: Re: FW: Lab safety showers
In-Reply-To: <SNT112-W28C8E15EE600DDBD12FCEE85490**At_Symbol_Here**phx.gbl>

In general, showers are plumbed from the cold water supply.  In ideal cases, they are plumbed from both hot and cold water with a mixing valve that delivers lukewarm/temperate water.  Again, generally, the only situations where you would have a holding tank is at a facility that has no plumbed/potable water supply.  In those cases, you'll shower stalls with a large overhead tank to meet requirements.

As to the waste water, the ideal case would have a floor drain which goes to a several thousand gallon holding tank/cistern in-line before the sewer discharge.  This would permit one to treat the discharge as HazMat if necessary/required.   In practice, such systems are rarely, if ever, installed in a building retrofit.  And even in new construction, the cost can lead to folks omitting floor drains rather than deal with the added expense and regulatory hurdles (both real and imagined).

As to the storage under showers, the most effective prevention method is to use heavy-duty floor tape to mark out a "keep clear" zone.  Firms like mine sell floor decals of this nature: m/?05221   For the most effective reinforcement, I would put one of those under the shower and then mark the excluded area with a floor tape.  At the risk of overtly soliciting, we can custom print antislip floor tapes that say "SAFETY SHOWER DO NOT OBSTRUCT" or other wording of your choosing which would make the excluded zone intent much more clear than simple yellow/black striped tape. Anyone interested in that sort of thing or who has related product suggestions can contact me off-list.

Rob Toreki
Safety Emporium - Lab & Safety Supplies featuring brand names
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On Nov 2, 2010, at 6:20 PM, Amber Potts wrote:

Is the water that comes out of the safety showers held in a tank or does it come directly from the main water supply? I know nothing about safety showers but I heard once that the water comes from a holding tank. If this is the case then couldn't the water be redirected back into the tank for proper disposal if there is concern of contamination? I agree that the berm would be a tripping hazard but it would also prevent chairs, tables, and desks from being stored under the safety shower also. I can't tell you how many times I have walked into the lab and seen various things stored under the safety shower or directly blocking access to it. 

Amber Potts

Date: Tue, 2 Nov 2010 13:16:24 -0700
From: ms.alnajjar**At_Symbol_Here**PNL.GOV< br>Subject: Re: [DCHAS-L] FW: Lab safety showers
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU

To be honest with all those who are interested in this topic, the berm idea does not make any sense considering the rare events where showers are used.  As it was mentioned, the hazardous materials are so diluted that it is not logical to flood the floor (building) for the sake of preventing trace amounts of hazardous materials from going down the drain.   


Thanks =85 M.A


From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**] On Behalf Of Alan McCartney
Sent: Tuesday, November 02, 2010 10:50 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subjec t: Re: [DCHAS-L] FW: Lab safety showers


I might be mistaken, but the placement of the berm, will violate the life safety code (and rleated bulding codes) regarding smooth, trip free walking surfaces. I believe this limitation is 1/8".  

On top of this, this triping hazard will directly compound & negatively affect the worker's compensation exposure for the associated employees.

I would think that the this trumps the local water / sewer inspectors request.


On Mon, Nov 1, 2010 at 9:18 AM, Williams, Mark <Mark.Williams**At_Symbol_Here**< /a>> wrote:

Thank you for the citation, Rob!

Mary, if you run across the letter of interpretation sometime in the future, would you post it here for us?


From: ILPI [mailto:info**At_Symbol_Here**ILPI.COM] 
Sent: Thursday, October 28, 2010 9:33 PM

Subject: Re: Lab safety showers


Excellent.  With that lead from Mary, I was able to look up where shower water is apparently exempted: .htm


Sec. 261.3  Definition of hazardous waste.


however, the following mixtures of solid wastes and hazardous wastes listed in subpart D of this part are not hazardous wastes (except by application of paragraph (a)(2)(i) or (ii) of this section) if the generator can demonstrate that the mixture consists of wastewater the discharge of which is subject to regulation under either section 402 or section 307(b) of the Clean Water Act (including wastewater at facilities which have eliminated the discharge of wastewater) and;



   (D) A discarded commercial chemical product, or chemical intermediate listed in Sec. 261.33, arising from de minimis losses of these materials from manufacturing operations in which these materials are used as raw materials or are produced in the manufacturing process. 

For purposes of this paragraph (a)(2)(iv)(D), ``de minimis'' losses include those from normal material handling operations (e.g., spills from the unloading or transfer of materials from bins or other containers, leaks from pipes, valves or other devices used to transfer materials); minor leaks of process equipment, storage tanks or containers; leaks from well maintained pump packings and seals; sample purgings; relief device discharges; discharges from safety showers and rinsing and cleaning of personal safety equipment; and rinsate from empty containers or from containers that are rendered empty by that rinsing; or


    (E) Wastewater resulting from laboratory operations containing toxic (T) wastes listed in subpart D of this part, Provided, That the annualized average flow of laboratory wastewater does not exceed one percent of total wastewater flow into the headworks of the facility's 

wastewater treatment or pre-treatment system or provided the wastes, combined annualized average concentration does not exceed one part per million in the headworks of the facility's wastewater treatment or pre-treatment facility. Toxic (T) wastes used in laboratories that are 

demonstrated not to be discharged to wastewater are not to be included in this calculation; or.....




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you know and trust.  Visit us at

< p class="ecxMsoNormal">esales**At_Symbol_Here**  or toll-free: (866) 326-5412

Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012


On Oct 28, 2010, at 5:54 PM, Mary Cavanaugh wrote:


I don=92t 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. 


From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU]  ;On Behalf Of Alan Hall
Sent: Thursday, October 28, 2010 3:15 PM

Subject: Re: [DCHAS-L] Lab safety showers


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.

Date: Thu, 28 Oct 2010 14:55:20 -0400
From: info**At_Symbol_Here**ILPI.COM
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..


Rob Toreki

< div>

  ============= ========================= ================

Safety Emporium - Lab & Safety Supplies featuring brand names

you know and trust.  Visit us at

esales**At_Symbol_Here**  or toll-free: (866) 326-5412

Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012


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.


Best regards,

Betsy Shelton

< /div>

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