Parts I and II of this series covered emergency fixture requirements in the OSHA regulations for worker safety, as well as equipment design, including the selection process, temperature concerns, and important components. In this final installment, I will cover a few of the OSHA interpretation letter responses related to questions asked to OSHA about emergency fixtures.
The OSHA requirements are set by statute, industry standards and regulations. Under the
Code of Federal Regulations, e-CFR, a standard that covers occupation health and safety of employees is 1910: Occupational Safety and Health Standards. Under sub-Part “K”: Medical and First Aid, standard number: 1910.151: Medical Services and First Aid, paragraphs “A” through “C” read as follows:
CFR 1910, K, Medical Services and First Aid
The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.
In the absence of an infirmary, clinic, or hospital in near proximity to the workplace, which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.
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.
[63 FR 33450, June 18, 1998]
OSHA emergency fixture interpretation letters
OSHA interpretation letters provide a further explanation of the requirements based upon OSHA’s response to formal requests. The letters cannot create additional employer obligations, but the interpretation responses do provide additional guidance based on specific situations. The following responses are a few interpretations that help clarify the OSHA requirements for emergency fixtures. From time to time, OSHA updates their guidance for Occupational Safety & Health in response to new or updated information. To keep apprised of such developments, you can consult OSHA’s website at www.osha.gov.
The interpretations below have the names of the parties involved left out for brevity. However, it is clear from these interpretations that the latest version of the industry standards will be used when enforcing the requirements for suitable flushing facilities. The complete interpretations are available on the OSHA website.
OSHA interpretation letter, dated: August 6, 1982
Interpretation letter, dated: March 8, 2002
Interpretation letter, dated: March 28, 2002
Interpretation letter, dated: April 18, 2002
Ron George’s Comments for the above interpretation: The reason for the change in the 1998 ISEA/ANSI Standard Z358.1 was because the requirement was for tepid water for the flushing fluid, which therefore requires a temperature actuated mixing valve for controlling the water temperature supplied to emergency fixtures. Since then, the American Society of Sanitary Engineering developed a new standard titled ASSE 1071: Performance Requirements for Temperature Actuated Mixing Valves for Plumbed Emergency Equipment, which has now been adopted in model plumbing codes for controlling the water temperature to emergency fixtures.
Using any other type of mixing valve would be inappropriate, because the ASSE 1071 mixing valve has a temperature sensing element, and if for any reason the temperature exceeds the set point, the valve will bypass cold water in the event of a temperature increase. The scope of the ASSE 1071 standard states these devices shall consist of a hot-water inlet connection, a cold water inlet connection, a mixed water outlet connection, a temperature controlling element and a means for adjusting the mixed water outlet temperature while in service. The device shall also have a means to limit the maximum outlet temperature under normal operating conditions. Provisions shall be made so that the temperature cannot be inadvertently adjusted.
What makes the device unique from all other mixing valves is that it has a hot water failure test where the cold water shall continue to flow at the minimum flow rate for the application, at a 30 psi differential pressure. The mixing valve’s hot water inlet temperature range is 120 F to 180 F, and the cold water inlet temperature range 40 F to 70 F. The cold water supply shall be at least 10 F lower than the outlet water temperature setting. The outlet water temperature range is an adjustable range, a portion of which falls within 65 F to 95 F. The outlet temperature shall not exceed 100 F under normal operating conditions. The valve must also be designed with cold water bypasses in the event of a cold water or hot water failure. The valves are also tested for cross flow to prevent hot water from crossing over into the cold water piping or cold water crossing into the hot water piping.
Interpretation letter, dated: Nov. 1, 2002
Interpretation letter, date: Feb. 27, 2007
Interpretation letter, dated: June 1, 2009