Date: Wed, 3 Nov 2010 13:10:43 -0700
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: "Palmer, John" <jpalmer**At_Symbol_Here**AD.UCSD.EDU>
Subject: Re: FW: Lab safety showers
In-Reply-To: <4CD10B0C.8648.0091.0**At_Symbol_Here**>

Another sideline note (expanding Debbie's comment mentioning that it might be related to a cross-connection prevention requirement) - on the subject tangent about eyewashes that "cannot be plumbed" which mentions project managers/engineers/code and "possibility of contamination"...

Sounds like an excuse... I'm sure both (eyewashes and showers) can be plumbed - if you have a source of properly isolated 'domestic water' or 'potable water' nearby... (the supply pipes that serve stuff like drinking fountains, kitchen areas, restrooms - sinks/showers etc.). 

Hence the appropriate recommendation you just received - that an eyewash be plumbed to the same source as an emergency shower.  (Also  agree that, where possible, tempered water sources are preferred...).

Eyewashes and emergency showers ('per plumbing code') would need to be plumbed to "domestic/potable" water source - and that simply means there is some type of vacuum breaker or other appropriate isolating device installed at the right spot in the supply water line(s) for the building or floor or general area.  This separation "by vacuum-breaker" of supply water plumbing should be done from a point where said domestic/potable water line(s) diverge from any being connected to your lab sinks/floor-sinks/shops/other locations where the possibility of "suck-back" contamination of the water supply line 'might' occur...  


Dr. John Palmer
Safety & Security Director
Chemistry & Biochemistry
UCSD - 9500 Gilman Dr.
La Jolla, CA 92093-0332
(858) 534-5906 

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**] On Behalf Of Eric Clark
Sent: Wednesday, November 03, 2010 7:09 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] FW: Lab safety showers

And to continue with Rob's statement ... so if you need to install the
emergency shower plumbing, then you may as well install the eyewash
stations on that same pipe while you're at it - that's how many of those
shower/eyewash fixtures are installed anyway.  

Eric Clark, MS CCHO, CHMM 
Safety & Compliance Officer 
Los Angeles County Public Health Laboratory 

>>> "Debbie M. Decker"  11/2/2010 4:43 PM >>>
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 
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"
> 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

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

On Mon, Nov 1, 2010 at 9:18 AM, Williams, Mark
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
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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

To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
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

To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Wow, thanks for sharing.  That one is a poster child for Bad

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

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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