Date: Wed, 3 Nov 2010 15:29:46 -0600
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: Alan Hall <ahalltoxic**At_Symbol_Here**MSN.COM>
Subject: Re: FW: Lab safety showers
In-Reply-To: <04592CA6F04ECA40A2288D2264F8F06E210C43BCF6**At_Symbol_Here**MBX5.AD.UCSD.EDU>

Another note on the emergency eyewash/shower discussion.  The ISEA (International Safety Equipment Association) Eyewash and Shower Produ ct Group will be meeting next week in the DC area to work on production of an Eyewash and Shower Equipment Use and Selection Guide to accompany the AN SI/ISEA Z358.1-2009 American National Standard for Emergency Shower and Eye wash Equipment.  The Use and Selection Guide is projec ted to be completed during the 1st Quarter of 2011.
This will not discuss the issues of berms or drains, as this came up duri ng our meetings on the Standard itself and was felt by the revision committ ee to be beyond the scope of the Standard, which is a performance standar d for the equipment itself.
However, the Use and Selection Guide will discuss such issues as recessed equipment, drench hoses, combination shower-eyewashes or eye/face wash es, drench hoses, shower testers, etc.,, and such backflow preven tion means as backflow preventers.  The primary flushing fluid for m any types of such equipment is potable water, defined as "water suitable for drinking".
I am a member of the Product Group and was a member of the revision committ ee for ANSI/ISEA Z358.1-2009.  If any of the D-CHAS group have issue s they would like to have discussed at next week's meeting, please contac t me directly at:  ahalltoxic**At_Symbol_Here**  I will attempt to get any such issues on the agenda.  
I will note that I do not represent any manufacturer of plumbed shower/eyew ash equipment in the Product Group.
Alan H. Hall, M.D.
Laramie, WY
Office Telephone:  (307) 745-0600
Cell Phone:  (307) 399-1564
> Date: Wed, 3 Nov 2010 13:10:43 -0700
> From: jpalmer**At_Symbol_Here**AD.UC SD.EDU
> Subject: Re: [DCHAS-L] FW: Lab safety showers
> To : DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
> Another sideline note (expandin g Debbie's comment mentioning that it might be related to a cross-connectio n prevention requirement) - on the subject tangent about eyewashes that "ca nnot be plumbed" which mentions project managers/engineers/code and "possib ility of contamination"...
> Sounds like an excuse... I' m sure both (eyewashes and showers) can be plumbed - if you have a source o f properly isolated 'domestic water' or 'potable water' nearby... (the supp ly pipes that serve stuff like drinking fountains, kitchen areas, restr ooms - sinks/showers etc.).
> Hence the appropriate rec ommendation you just received - that an eyewash be plumbed to the same sour ce as an emergency shower. (Also agree that, where possible, tempered w ater sources are preferred...).
> Eyewashes and emergenc y showers ('per plumbing code') would need to be plumbed to "domestic/potab le" water source - and that simply means there is some type of vacuum break er 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 separ ation "by vacuum-breaker" of supply water plumbing should be done from a po int where said domestic/potable water line(s) diverge from any being connec ted to your lab sinks/floor-sinks/shops/other locations where the possibili ty of "suck-back" contamination of the water supply line 'might' occur... < BR>>
> jp
> Dr. John Palmer
> Safety & Security Director
> Chemistry & Biochem istry
> UCSD - 9500 Gilman Dr.
> La Jolla, CA 92093-0332< BR>> (858) 534-5906
> jpalmer**At_Symbol_Here**
> < BR>> -----Original Message-----
> From: DCHAS-L Discussion Lis t [mailto:DCHAS-L**At_Symbol_Here**] On Behalf Of Eric Clark
> Sent: Wed nesday, 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
& gt; 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
> Eric Clark, MS CCHO, CHMM
> Safety & Compliance Officer
> Los Angeles County Public Health Lab oratory
> >>> "Debbie M. Decker" <d mdecker**At_Symbol_Here**UCDAVIS.EDU> 11/2/2010 4:43 PM >>>
> It may have something to do with a weird interpretation the
> cross-c onnection prevention requirements in the plumbing code.
> Just a th ought.
> 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
> W ow - no eyewashes! This project manager would have you violate OSHA
> ; 29 CFR 1910.151:
> _document?p_id=9806&p_table=STANDARDS
&g t; Don't think any private code trumps the Feds. Except where private
> codes are incorporated by reference.
> The manage r might get away with not installing plumbed eye washes or
> drench hoses, as you can use portable units that will supply the
> requ ired flow, but there is no way you can avoid plumbing a shower - 20
&g t; 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 th at 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 c ode...) 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
> c ode, 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 o pinion only, not business or legal advice, and may not
> reflec t the opinion of my employer...
> Margaret
> > ;>> "Alnajjar, Mikhail S"
> <ms.alnajjar**At_Symbol_Here**PNL.GOV <mailto:ms.alnajjar**At_Symbol_Here**PNL.GOV>> 11/2/2010
> 4:16 PM &g t;>>
> To be honest with all those who are interested i n this topic, the berm
> idea does not make any sense considering the rare events where showers
> are used. As it was mentioned, t he hazardous materials are so diluted
> that it is not logical to f lood the floor (building) for the sake of
> preventing trace amount s 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**LIS T.UVM.EDU<mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
> Subject: Re: [DC HAS-L] FW: Lab safety showers
> I might be mistaken, b ut the placement of the berm, will violate the
> life safety code (and rleated bulding codes) regarding smooth, trip free
> walkin g 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 employ ees.
> I would think that the this trumps the local wate r / sewer inspectors
> request.
> Alan
> On Mon, Nov 1, 2010 at 9:18 AM, Williams, Mark
> <Mar k.Williams**At_Symbol_Here**<mailto: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?
> Thanks
> Mark Williams
> Teledyne Energy Sy stems Inc.
> 38 Loveton Cr
> Sparks MD 21152
> 410- 472-7733
> mark.williams**At_Symbol_Here**<mailto:mark.williams**At_Symbol_Here**t>
> _______________________ _________
> From: ILPI [mailto:info**At_Symbol_Here**ILPI.COM<mailto :info**At_Symbol_Here**ILPI.COM>]
> Sent: Thursday, October 28, 2010 9:33 P M
> Subject: Re: Lab safety showers
> Excellent. With that lead from Mary, I was able to look up where
> ; shower water is apparently exempted:
> http://edocket.access.g
> Sec. 261.3 Defi nition of hazardous waste.
> (snip)
> however, the follow ing mixtures of solid wastes and hazardous wastes
> listed in subpa rt 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
> disc harge 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;
> (snip)
> (D) A discarded commercial chemical pro duct, or chemical
> intermediate listed in Sec. 261.33, arising from de minimis losses of
> these materials from manufacturing ope rations in which these materials
> are used as raw materials or are produced in the manufacturing process.
> For purposes of this para graph (a)(2)(iv)(D), ``de minimis'' losses
> include those from n ormal material handling operations (e.g., spills
> from the unloa ding or transfer of materials from bins or other
> containers, le aks from pipes, valves or other devices used to transfer
> materi als); minor leaks of process equipment, storage tanks or
> cont ainers; leaks from well maintained pump packings and seals; sample
& gt; purgings; relief device discharges;discharges from safety showers and
> rinsing and cleaning of personal safety equipment; and rin sate from
> empty containers or from containers that are rendered e mpty by that
> rinsing; or
> (E) Wastewater re sulting from laboratory operations containing
> toxic (T) wastes li sted in subpart D of this part, Provided, That the
> annualized average flow of laboratory wastewater does not exceed one
> percen t of total wastewater flow into the headworks of the facility's
> w astewater treatment or pre-treatment system or provided the wastes,
&g t; 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.....
> ; Rob
> =============== ========================= ==============
> Safety Emporium - Lab & Safety Supplies featuring brand names
> you know and trust. Visit us at
> esales**At_Symbol_Here**safetyemporium .com<mailto:esales**At_Symbol_Here**> or
> toll-free: (8 66) 326-5412
> Fax: (856) 553-6154, PO Box 1003, Blackwood, N J 08012
> On Oct 28, 2010, at 5:54 PM, Mary Cavanaugh wrote:
> I don=92t have time t o dig it up right now, but there is an EPA letter
> of interpreta tion 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 [m ailto: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**L IST.UVM.EDU<mailto: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 t ime, not just when the
> emergency shower is in use.
> > I also agree with how dilute most chemical splashes would be by th e
> time you dilute them with 15 minutes **At_Symbol_Here** 20 gallons/minute = 30 0 gallons
> of water.
> Alan
> Alan H. H all, M.D.
> Date: Thu, 28 Oct 2010 14:55:20 -0400
> From: info**At_Symbol_Here**ILPI.COM<mailto:info**At_Symbol_Here**ILPI.COM>
> Subje ct: Re: [DCHAS-L] Lab safety showers
> To: DCHAS-L**At_Symbol_Here**LIST. UVM.EDU<mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
> 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 o f 1.33 cubic feet =
> 10 gallons. Under ANSI Z358, showers must put out at least 20 gallons
> per minute. And that shower is likel y 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 no n-functional. Plugging the floor drain permanently is
> an easier s olution.
> 2. The amount of hazardous material on a vict im is going to be so
> exceedingly small and so diluted in the drai ns 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 tha t it is a hazard even that dilue, this city
> review department t hinks it's better to spread the hazmat all over the
> building and down a couple floors onto various objects and people than
> it is t o send it down the drain.
> 3. When you're blinded by so mething 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 hazar d the rest of time no matter how well it's marked with floor
> tape .
> Rob Toreki
> ====== ========================= =======================
&g t; Safety Emporium - Lab & Safety Supplies featuring brand names
> you know and trust. Visit us at
& gt; esales**At_Symbol_Here**<mailto:esales**At_Symbol_Here**> or
> toll-free: (866) 326-5412
> Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
> On Oct 2 8, 2010, at 2:31 PM, Betsy Shelton wrote:
> I am c urrently 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 Shel ton
> 512.636.1905
> retrosynthesis**At_Symbol_Here**<mailto:r etrosynthesis**At_Symbol_Here**>
> __ ____________________________________________________________________
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