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Emergency showers and eyewashes are safety equipment common in an industrial setting or required by federal law where workers can be exposed to hazardous materials in the workplace. The federal law is the U.S. Department of Labor, Occupational Safety & Health Administration (OSHA) Code of Federal Regulations OSHA 29 CFR 1910.151(c), requiring emergency fixtures in facilities with hazardous locations.
OSHA Requirements
Section 29 CFR 1910.151(c) of the OSHA Code of Federal Regulations includes the following language:
“29 CFR 1910.151(c) — Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.”
OSHA requires suitable facilities for quick drenching and flushing of the eyes and body for emergency use in compliance with OSHA 29 CFR 1910.151(c). The industry standard, which is recognized by the international consensus standard ANSI Z358.1-2004, provides design, performance, installation and maintenance details and guidance for emergency eyewash and shower equipment installations.
The ANSI Z358.1 standard is often the document used by OSHA compliance personnel when assessing safety and health conditions in workplaces and to determine compliance with the requirement for suitable facilities for quick drenching or flushing of the eyes and body.
The industry standard for emergency shower and eyewash fixtures is produced by the International Safety Equipment Association (ISEA) in accordance with the standards development requirements of the American National Standards Institute (ANSI) for ANSI/ISEA Z358.1-2014 — Emergency Eyewash and Shower Standard.
The ANSI/ISEA Z358.1 standard establishes testing, installation, performance, maintenance (flushing) and training criteria for equipment used for emergency treatment or flushing of the eyes and body.
The application of the emergency eyewash and shower standard assists users with meeting OSHA 29 CFR 1910.151 requirements for emergency facilities.
• OSHA workplace inspections. Occupational safety inspections are typically scheduled to inspect workplaces on a regular basis by OSHA inspectors. The inspections may occur randomly without prior notice. Inspections may occur due to a complaint and they almost always occur due to a workplace injury accident.
• OSHA penalties. The penalties can be as little as a warning if they happen to notice an unsafe condition during a routine inspection. The penalties can include a monetary fine or even a facility shut-down if the violation is a repeat violation or if someone is injured and the facility is deemed unsafe. Employers, design professionals, contractors and owners can share in the liability and can be affected by fines and possible litigation for not complying with the OSHA requirements for emergency fixtures.
The Emergency Shower and Eyewash Standard
The ANSI/ISEA Z-358.1-2004 American National Standard for Emergency Eyewash and Shower Equipment is an industry standard and not a regulation. The document gives the minimum requirements for emergency fixtures when they are required by OSHA. It is not specifically referenced in the OSHA 29 CFR 1910.151 document, but that does not mean it cannot be enforced as it is the industry standard for the required emergency fixtures.
The OSHA document is older than the ANSI Z358.1 standard, so there was no document to reference at the time the OSHA requirements were published. Many state and local OSHA offices have recognized the Z-358.1 standard. It provides industry-recognized guidelines for OSHA inspections and it is the only industry guide to determine if suitable facilities are provided by an employer.
If there is an incident dealing with hazardous materials exposure, Z-358.1 will be what everyone will point to as the acceptable industry standard. Manufacturers recognize the importance and the impact of the Z-358.1 standard and many owners voluntarily comply with it. Others may roll the dice and not install emergency fixtures, hoping they will not have an accident that requires emergency fixtures. If they do not comply, I would not want to be in their shoes.
1. ANSI Z-358.1 Standard, Performance Requirements for Plumbed Emergency Showers
a. Minimum flow of 20 gallons/minute (gpm) at 30 psi for
15 minutes to drench the user and wash away any
chemical hazard. (The standard requires a 15-minute
continuous flushing due to research showing residual
chemicals on the body require extended flushing of at
least 15 minutes to ensure chemical removal and prevent
chemical burns.)
b. Verify even distribution of flow through the shower
head.
c. The eyewash not considered an obstruction.
2. ANSI Z-358.1 Standard, Performance Requirements for Plumbed Eyewashes
a. Minimum 0.4 gpm at 30 psi for 15 minutes. (The
proposed ASSE Standard 1071 language does not
currently correlate with this requirement. ASSE 1071
currently has a much higher minimum flow rate. This
should be addressed.)
b. Controlled flow to simultaneously flush both eyes.
c. Eyewash nozzles protected from airborne contaminants
with dust caps.
3. ANSI Z-358.1 Standard, Performance Requirements for Plumbed Eye/Facewashes
a. Minimum 3.0 gpm for 15 minutes.
b. Controlled flow to simultaneously flush both eyes.
c. Face ring/eyewash nozzles protected from airborne
contaminants with dust cover/cap.
4. ANSI Z-358.1 Standard, Performance Requirements for Plumbed Hand-Held Drench Hoses
a. Minimum 3.0 gpm for 15 minutes.
Hand-held devices provide support for emergency shower
and eyewash units but do not replace them.
5. ANSI Z-358.1 Standard, Performance Requirements for Plumbed Combination Units
a. Combines a shower, eyewash, eye/face wash or hand-
held drench hose.
Each unit must meet individual performance requirements when all components (on a unit) are operated simultaneously.
6. ANSI Z-358.1 Standard, Simultaneous Operation
The ANSI/ISEA Z-358.1 standard has the following language:
“The unit shall be … capable of supplying adequate flushing fluid to meet the requirements … when all components are operated simultaneously … and shall be positioned so that components may be used simultaneously by the same user.”
The flow requirements for drench hoses were removed since drench hoses are supplemental to the required fixtures.
The Basics of Emergency Showers and Eyewashes
When an emergency fixture is used, the fixture’s purpose is to provide flushing fluid to cool the skin, dilute any hazardous chemicals and flush the hazard from the skin.
The emergency fixture valve operation should be simple to operate in one second or less.
The velocity/pressure is important and should be low enough to be noninjurious to the eyes or skin. If the pressure is too high, water will emit from the fixture at a high velocity and be uncomfortable on burned skin or in the eyes.
Flow regulators and verification of proper shower patterns and eyewash streams is important. Emergency fixtures should be located within 10-second walking distance of a hazard and on the same floor level. (The average brisk walking pace is 5.5 feet/second which would equate to about 55 feet in 10 seconds.)
I was told the Z-358.1 emergency fixture working group decided to use 10 seconds as a recommendation in the appendix in lieu of a specific distance to allow some flexibility for fixture locations.
The path of travel from the hazardous area to the emergency fixture should be free of obstructions.
The area around an emergency fixture should also be well lit so the user can clearly see the emergency fixture. Emergency fixtures should be identified with a highly visible safety green or yellow sign.
The delivered flushing fluid temperature shall be tepid, not tempered.
• Tepid vs. tempered. I often hear people misuse the term “tempered water” when referring to emergency fixture water temperatures. When I served on the emergency fixture working group for a standards writing organization, members were also using the term “tempered.”
It was pointed out that tempered water was defined in the plumbing codes as follows: “Tempered Water — Water having a temperature range between [85 F and 110 F.]” Since tempered water was defined in the plumbing codes with a specific temperature range too hot for use in emergency fixtures, the term could not be referenced in the emergency fixture standard. With a little help from a thesaurus, the term “tepid” surfaced with the following definition:
“Tepid — Moderately or slightly warm; lukewarm.”
This definition was more appropriate and this term was used to define the emergency fixture water temperature.
• Why tepid water? Tepid water helps prevent hypothermia, cool chemical burns, prevent chemical absorption and encourages safety equipment use, full 15-minute drench time and removal of contaminated clothing.
TMVs for Plumbed Emergency Equipment: Safety Features
Every emergency fixture thermostatic actuated mixing valve should include the following redundant safety features:
1. Stay-open cold water supply upon hot water failure;
2. Valve should provide accurate control of the hot water
(when only eye wash is in use);
3. Full-flow cold water bypass in the event of blocked
flows.
The American Society of Sanitary Engineering (ASSE) is in the process of developing a standard for emergency fixture mixing valves: ASSE 1071, Temperature Actuated Mixing Valves For Plumbed Emergency Equipment. It is still in the development process and should include these safety features.
• Other water supply temperature concerns. Water supplies can get very hot or very cold if the emergency fixture water lines are exposed to extreme temperatures outdoors or high temperature systems or equipment indoors. Extreme temperatures can create a condition where the water temperature flowing from the emergency fixture could be too hot or too cold to encourage proper use of the fixture.
Heat sources can be from direct sunlight, boilers, space heaters, steam mains and heating hot water mains, to name a few. These heat sources can cause high temperatures in cold water pipe. Cold weather or pipe routed through cold spaces or near outside air inlets can cause extremely low temperatures and lead to hypothermia if an adequate supply of hot water is not available to mix with cold water.
• Emergency equipment design. Owners should have the facility design engineer work with the facility personnel to review each application and select the proper emergency shower and eyewash equipment: location, size of water heating equipment, and type of emergency fixture thermostatic mixing valve with a cold water bypass.
The outlet temperature of the mixing valve should ideally be set at about 80 F. The adjustment on the mixing valve allows the facility owner’s safety personnel to adjust the outlet temperature to the desired temperature based on the requirements of the site safety or medical personnel.
• Tepid water system components.
1. Heat source (water heater);
2. A blending unit (tempering valve with safety features);
3. Distribution system (piping, heat-traced lines,
recirculating lines);
4. Emergency fixtures (shower, eyewash);
5. Chiller units if required for hot environments.
• Flushing of emergency fixtures. It is recommended to perform weekly tests to verify proper operation of plumbed emergency equipment and to flush lines of rust and stagnant water. These weekly tests should be recorded on a testing and flushing tag located on each emergency fixture.
Emergency fixture water is often in a dedicated piping system and can sit in the piping for long periods of time. If the piping system or the emergency fixture piping is galvanized piping, it can become stagnant and rusty after a period.
Most manufacturers offer stainless emergency fixture models that include stainless-steel piping. These can help reduce the rust and iron oxide common in galvanized models. Copper distribution piping can eliminate or significantly reduce the amount of rust and bacteria common in galvanized pipe.
Weekly testing and flushing will clear the stagnant water, bacteria and rust that can develop in the emergency fixture piping. Weekly testing will flush the piping system and make sure stagnant water does not greet someone who may need to use the fixture with a chemical burn.
• Testing of emergency fixtures. The appendix in the Z-358.1 standard recommends annual flow tests to test for full flow and tepid temperature for the full 15-minute duration. This test ensures the water supply is properly sized for pressure and provides tepid water for the full 15-minute duration to encourage proper use of the emergency equipment.
• Plumbed emergency equipment categories.
1. Emergency showers.
2. Eyewash and eye/face wash equipment (supplemental
to required plumbed equipment).
3. Hand-held drench hoses (supplemental to required
plumbed equipment).
4. Combination units (emergency shower and eye wash or
eye/face wash).
5. Personal eyewash equipment (supplemental to required
plumbed equipment).
Americans with Disabilities Act
ANSI Z358.1 does not specifically address the Americans with Disabilities Act (ADA) and the ADA does not specifically address emergency fixtures. However, the ADA/ABNSI A117.1 is a federal law. Employers should provide emergency fixtures suitable for employees in a wheelchair if they have handicapped employees who work in an area subject to a chemical hazard.
Barrier-free emergency fixtures should include the following ANSI A117.1 requirements:
1. Minimum knee clearance requirement;
2. Extension from the wall;
3. Maximum forward and side reach limit;
4. Less than five pounds of force for activation;
5. Maximum height of the eyewash.
Designers should review provisions of ADA’s Accessibility Guidelines (ADAAG) for Buildings and Facilities and local accessibility regulations. Several manufacturers make units with under-fixture clearance and emergency shower pull rods designed to meet ADAAG and ANSI A117.1 height and opening force requirements.
• Determining emergency fixture locations.
1. Emergency fixture is in an accessible location within 10
seconds of hazard (about 55 feet +);
2. Emergency fixture is located on the same level as the
hazard;
3. The path of travel is free of obstructions: doors, steps,
curbs, racks, barrels, material pallets, etc.;
4. The emergency fixture has a highly visible sign;
5. The emergency fixture has a well-lit area.
Appendix A: Waste Disposal
The appendices of the standard are for reference only. The information in the appendix cannot be enforced by the code officials. However, the information is in the standard and it can be contested in court if an owner feels a design professional or contractor did not comply with standard design or maintenance criteria given in the appendices.
The following items should be addressed in the system design:
1. Exposure to freezing;
2. Drainage of flushing fluid when required;
3. Access to showers;
4. Simultaneous use of shower and eye/face wash;
5. Proper placement of supplemental emergency
equipment (hand-held sprays, portable equipment);
6. Exposure to heat sources;
7. Pollutants (pipe material, lead leachates, rust, iron oxide
and heavy metals);
8. Microorganisms (bacteria).
I have performed emergency fixture facility assessments at industrial facilities in northern climates where they had outside emergency showers protruding from the wall, with an operating handle to the valve behind the wall. This was located near an acid and caustic truck chemical transfer/unloading area.
The day I inspected the facility, the temperature was about -22 F. If someone had to use the emergency shower fixture, it would likely have looked like a snow-making machine and certainly would not have been comfortable to use. In cold weather, users would be coated with snow and ice. It was too cold to use as an outdoor emergency shower in that location.
Ideally, they should have had a heated enclosure for the emergency shower/eyewash that could have provided a heated place to encourage use of the shower.
When large quantities of acids or chemicals are present, drainage collection or containment of the volume required for the flushing period should be considered. For example, if a combination shower and eye/face wash uses a minimum of 24 gpm, and is supposed to flush for 15 minutes, the 15 minutes x 24 gallons = a minimum of 360 gallons of flushing fluid and hazardous or caustic chemicals will be discharged on the floor.
Consider:
1. A drainage area with the floor sloped to a drain with a
trap primer;
2. When no floor drain is desired and the floor can be
sloped;
3. The waste can be directed to an area where flooding
and chemical dispersal will not be an issue;
4. A containment curb around the chemical exposure area
to capture the chemical spills;
5. The anticipated emergency flushing fluid volume to
contain contaminants when hazardous chemicals cannot
drain to sanitary or leave the area.
Waste should be disposed of according to local codes.
• Alarm device considerations. Alarms are a good idea when emergency fixtures are in a remote area to alert others of an activation and summon help.
1. Local or remote alarms;
2. Flow switch or proximity switch activation;
3. Exterior light to flash or an audible alarm to sound to
notify others when an emergency fixture is activated.
a. Remote annunciation hard wired;
b. Remote annunciation via radio signal with transmitter
and receiver powered;
c. Other options.
• Water temperature blending systems. The ASSE 1071 standard is the industry standard for mixing valves for blending of hot and cold water to produce a tepid water temperature for use in emergency flushing fixtures. Tepid water has been defined in the industry standard as temperatures between 60 F and 90 F for tepid water (flushing fluid) for emergency fixtures.
I have seen water heaters for remote emergency fixtures that are instantaneous and require a large electrical or gas service to produce hot water instantaneously. Another solution has a manufacturer using a large storage tank with a low wattage, 120V electric input to heat a volume of water up to a temperature that will kill Legionella bacteria, then mix it down to a safe temperature with a mixing valve conforming to ASSE 1071 with a cold water bypass if the temperature gets above a safe temperature.
These systems need to be located within 50 feet of the emergency fixture; recirculation is not necessary. It is important to have some mixing baffles and a large section of pipe on the mixing valve outlet to serve as a buffer tank. This allows the mixing valve to adjust temperature for the first few seconds of flow, especially if the unit is close to an emergency fixture.
The unit stores hot water in a storage tank sized to deliver tepid water for the full 15-minute flushing period required in the standard for one combination emergency shower/eyewash fixture usage period. A unit like that should be popular for schools and factories on a tight budget when the utilities are not present for a tankless or instantaneous water heater conforming to heat cold water up to a tepid water temperature.
Check your local code to see if they allow the ASSE 1085 in lieu of the ASSE 1071 valve; some areas of the country may not have adopted codes allowing these devices yet. Where instantaneous heaters are used, the piping to and from the heater must be in a conditioned space to avoid freezing, exposure to sunlight or steam/hot water systems that can cause excessive temperatures. The ANSI Z358.1 standard defines tepid water as 60 F to 90 F for flushing.
• Tepid water heating systems. ASSE has developed a new standard: ASSE Standard No. 1085-2018 (reaffirmed 2023), Performance Requirements for Water Heaters for Emergency Equipment. It was ANSI-approved in March 2023. This standard covers water heaters with precise setpoint controls under varying flow conditions. It is for water heaters supplying tepid water to emergency equipment, including eyewash, eye/face wash, emergency showers and combination units.
These water heaters heat the cold water supply to an acceptable tepid temperature within the intended range listed in ISEA Z358.1.
The ASSE 1085 water heaters shall consist of a cold water inlet connection, a means of heating the water and controlling the discharge temperature, and an outlet connection to supply tepid water to the emergency equipment.
The ASSE 1085 water heater shall also include a means to limit the maximum outlet temperature under normal operating conditions. Provisions shall be made so that the temperature setting of the water heater cannot be inadvertently adjusted.
Tankless or instantaneous heaters and piping should be installed in a heated secure space to provide a continuous flushing fluid temperature in the tepid water range for emergency fixtures to operate. The heater should be able to control the temperature to temperatures recommended in the standard (between 60 F to 90 F) as being tepid water for flushing emergency fixtures.
Ideally, the temperature should be about 80 F +/- 10 degrees. I find that temperatures below 70 F, although mentioned in the standard, are uncomfortable to promote a victim staying in the flushing fluid to wash off hazardous chemicals for the full 15-minute flushing period recommended. Temperatures above 90 F are hard to maintain.
• Design and maintenance considerations.
1. Alarms (status indicators for any pumps, valves and
excessive flushing fluid temperatures);
2. Design to prevent cold or hot water temperatures, rust
from nonpotable water pipe materials. (Avoid steel pipe,
galvanized pipe, dead legs and tepid recirculation);
3. Pressure drops (booster pumps, pipe sizes).
4. Maintenance:
a. Full compliance testing should be performed annually.
b. Isolation valves should be checked and locked open to
prevent inadvertent or intentional closing.
c. Full-flow cold water bypass loops for mixing valve
should be tested for excessive temperatures.
d. Temperatures should be monitored during tests to
ensure that supply water is not exposed to cold or
freezing areas, hot pipe, hot equipment or sunlight that
can cause the flushing fluid temperature to be out of
the tepid water temperature range.
• Maintenance and training.
1. Manufacturers should provide operation, inspection and maintenance instructions with shower and eye wash equipment.
2. All emergency equipment should be tested for the full 15-minute flushing period annually.
3. Instructions should be readily accessible to maintenance and training personnel.
4. Weekly inspection and flushing should be performed on all plumbed units to eliminate stagnant water and avoid bacterial growth that will occur after the chlorine dissipates in a week to 10 days, depending on the pipe material, temperature and water quality.
Inspection and testing tags are recommended to document flushing date, temperature and noted issues during the weekly inspection and flushing; also to document the annual full-performance testing. This should also be part of the building’s water management program documentation.
When emergency fixtures are flushed, they should be flushed with a volume that will evacuate the stagnant water in the supply line to the emergency fixture beyond the last pipe tee serving a regularly used fixture.
5. Eye/face wash units should be located so they can be used simultaneously with the emergency shower unit and not offset to the side. They must be used simultaneously and they should be flushed weekly and recorded as noted above.
Eye/face wash units should provide flushing fluid to both eyes simultaneously. A test gauge should be used to determine if a suitable eye wash pattern is present.
6. Supplemental equipment that is handheld or countertop-, deck- or faucet-mounted is in addition to the required combination unit. Activation shall ensure flow of water to the head(s) of the device.
Duration of the activation shall be sufficient to ensure all stagnant water is flushed from the unit itself and all sections of piping that do not form part of a constant circulation system (also known as “dead leg” portions). Check all eyewashes with an eye test gauge to assure proper flow and performance.
7. Self-contained/portable equipment should be visually checked to determine if flushing fluid needs to be changed.