From: David H Silberman <davidhs**At_Symbol_Here**STANFORD.EDU>
Subject: Re: [DCHAS-L] Safety Shower Installation
Date: Wed, 11 Mar 2015 11:35:40 -0700
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 579190672.8591492.1426098940361.JavaMail.zimbra**At_Symbol_Here**
In-Reply-To <17A66C0B22391144A0BEE1CA471703EA77C0097E**At_Symbol_Here**ITSSDOWEXMB11.HOSTED.LAC.COM>

After decades of not suggesting drains under safety showers and eye washes, Stanford changed this policy so that:
  1. Where feasible, floor drains should be installed below or near safety showers [and eye washes], with the floor sloped sufficiently to direct water from the shower into the sanitary sewer drain.  

Per:  See pages 6 and 7.

From personal experience: Over my 26 year tenure at Stanford, we experienced about one or two safety shower "pulls" per year in the School of Medicine alone.  How many pulls did not occur because of perceptions described in earlier emails is not specifically known, but anecdotally there have been numerous instances reported to Health and Safety.  These included putting certain exposed body parts in the sink and using the faucet as a safety shower!  This convinces me that users want drains under showers and eyewashes and did not choose to do so because of other fears (slip, trip, damage to floors below).  Training MUST include emphasis on shower/eye wash use if needed; the issue of embarrassment  needs to be addressed as well. 

If drains are to be installed, they should have self priming systems for traps so they do not go dry and cause odor issues.

The expense of installation is more than off-set, in my opinion, by the cost of damaged equipment, non-use when use is indicated, potential injury to responders who need to deal with 300 gallons (or more) of water.

About 15 years ago, we recommended the installation of floor drains and self-priming traps for a new building.  We called every conceivable regulatory agency (in California, yet) that might object to drain disposal and none had any objection.  I'm confident the same view exists today, but it's worth exploring locally as these agencies might subscribe to the drain disposal myth without revisiting the "WHY" of implementation.  The dilution factor alone would take care of just about all typical spills and if a highly corrosive or other dangerous component has a risk of going down the drain, a holding tank of sufficient volume should be programmed into the project.

For older buildings that do not have coved base flooring, coving should be considered either as an add on or replacement of tiles that abut the wall.



David H. Silberman
Director, Emeritus
Health and Safety Programs
Stanford University School of Medicine

Health and Safety.... It's more than just compliance.

From: "Eric Clark" <erclark**At_Symbol_Here**PH.LACOUNTY.GOV>
Sent: Wednesday, March 11, 2015 11:03:56 AM
Subject: Re: [DCHAS-L] Safety Shower Installation

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 =A7 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 pr=C3=A9vention (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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