From: Eric Clark <erclark**At_Symbol_Here**>
Subject: Re: [DCHAS-L] Safety Shower Installation
Date: Wed, 11 Mar 2015 18:03:56 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 17A66C0B22391144A0BEE1CA471703EA77C0097E**At_Symbol_Here**ITSSDOWEXMB11.HOSTED.LAC.COM
In-Reply-To <4F21A5F3A002444D8B4F5E4B767431E572042C56**At_Symbol_Here**EXMBX2010-7.campus.MCGILL.CA>

There are a few reasons why many emergency safety showers do not have drains:

1.      OSHA says you must install a safety shower, but it doesn’t say anything about installing the drain (not within their purview).

2.      It saves money not to install a drain. 

3.      People who bid on construction jobs generally leave the safety shower drain out because it’s “not required”.  

4.      The people who decide whether or not to actually install the drain are generally not the same people who must clean up a huge mess after the shower is used – or hold up a bucket when testing the shower.    

5.      There’s a persistent myth out there that using an emergency shower will somehow violate hazardous waste disposal regulations. 


40 CFR § 268.2 (e)

(4) De minimis losses of characteristic wastes to wastewaters are not considered to be prohibited wastes and are defined as losses from normal material handling operations (e.g. …discharges from safety showers and rinsing and cleaning of personal safety equipment … ).



Eric Clark, MS, CHMM, CCHO

Safety Officer, Public Health Scientist III

Los Angeles County Public Health Laboratory




From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU]On Behalf Of Wayne Wood
Sent: Wednesday, March 11, 2015 10:42 AM
Subject: Re: [DCHAS-L] Safety Shower Installation


I agree with Linda.


In my years in EHS there were about a dozen incidents where people should have activated the emergency shower but in only 2 cases did they actually use it. When queried as to why they didn’t use the showers most people said they were afraid they would make a mess. 


So if you really want to increase the chances that people will actually use the shower they need to know there is a drain and, better still, they need to see it used (during testing) to have the confidence that it works. 




Wayne Wood | Associate Director, University Safety (EHS), University Services –Directeur Adjoint, Direction de la prévention (SSE), Services universitaires |McGill University | 3610 rue McTavish Street, 4th floor | Montreal, Quebec, Canada, H3A 1Y2 | Tel: (514) 398-2391






From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU]On Behalf Of Linda E Vadura
Sent: Wednesday, March 11, 2015 12:56 PM
Subject: Re: [DCHAS-L] Safety Shower Installation


Good morning,


Many of our newer showers/eye wash stations are without drains because of the cost. While this is considered acceptable, if not ideal, there are some behavioral repercussions.


People are less willing to use an emergency eye wash or shower is there is no drain. A person can think, “Is this really an emergency” - this happened in one of our teaching labs about 12 years ago. Also, lab personnel are less likely to do a routine check of an eye wash if there is no drain.


I recommend that if you can get drains installed, you should do so. It might save headaches in the future.




Linda Vadura

COSE Health and Safety Specialist

Campus Radiation Safety Officer

San Francisco State University

College of Science and Engineering







On Mar 11, 2015, at 9:06 AM, Reuter,Mike - Dairy One <Mike.Reuter**At_Symbol_Here**DAIRYONE.ONMICROSOFT.COM> wrote:


Good afternoon,


Quick query.  We have a new building with labs under construction and near the final phases.  Ammonium Hydroxide (corrosive) will be used in a ventilation hood in one of the lab rooms.  There is a sink mounted eyewash planned but I just found out that no provisions were made for a safety shower.  This has now been brought to the attention of the construction group but unfortunately there is no floor drain in that lab room and it’s beyond the point where one could be installed.  The group is suggesting a location for the shower that is accessible within 5 seconds of where the chemical will be used but the individual would have to proceed through a swinging door.  Under ANSI Z358.1 a door is considered an obstruction for corrosive hazards.  Would a swinging door still be considered an obstruction?  Any advice would be great.






Michael J. Reuter

Forage Lab Chemist

Health and Safety Director


Dairy One

730 Warren Road

Ithaca, NY 14850

Phone: 1-607-257-1272, ext. 2166

Fax: 1-607-257-1350


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