Date: Tue, 2 Nov 2010 23:43:08 +0000
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: "Debbie M. Decker" <dmdecker**At_Symbol_Here**UCDAVIS.EDU>
Subject: Re: FW: Lab safety showers
In-Reply-To: <4D8BD439-0117-4FBF-8DC9-D23A912F267C**At_Symbol_Here**>

It may have something to do with a weird interpretation the cross-connection prevention requirements in the plumbing code.
Just a thought.
Sent from my Blackberry.


From: ILPI [mailto:info**At_Symbol_Here**ILPI.COM]
Sent: Tuesday, November 02, 2010 02:31 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Subject: Re: [DCHAS-L] FW: Lab safety showers
Wow - no eyewashes!  This project manager would have you violate OSHA 29 CFR 1910.151:

Don't think any private code trumps the Feds.  Except where private codes are incorporated by reference.

The manager might get away with not installing plumbed eye washes or drench hoses, as you can use portable units that will supply the required flow, but there is no way you can avoid plumbing a shower - 20 gallons per minute for 15 minutes would require a huge tank.

Rob Toreki

On Nov 2, 2010, at 4:56 PM, Margaret Rakas wrote:

Of course you are correct that it doesn't make sense.  But I just left a meeting where a very upset project manager INSISTED eyewashes cannot be plumbed due to the possibility of contamination (the engineer told him it was code...)  This makes even less sense, but as I will spend a good amount of time in the next day or two trying to determine WHICH code, and whether it is superseded by another, etc etc I would like to suggest that CHAS find some way to officially work with the code-setters, at least on lab-related issues.  
My personal opinion only, not business or legal advice, and may not reflect the opinion of my employer...

>>> "Alnajjar, Mikhail S" <ms.alnajjar**At_Symbol_Here**PNL.GOV> 11/2/2010 4:16 PM >>>
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 É 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
Subject: 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**> 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?
Mark Williams
Teledyne Energy Systems Inc.
38 Loveton Cr
Sparks MD 21152

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:
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.....
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 5:54 PM, Mary Cavanaugh wrote:
I donŐt 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
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

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