Nov 20 2017

Eyewash Stations

Category: Eyewash Stations,Questions and AnswersBKeyes @ 12:00 am

Q: I have been told several different ways that our facility didn’t have an eye wash station in our janitor’s closet. So, I was told to purchase the single-use portable squeeze bottles, and I installed one in each janitor’s closet. Now, I’m told we can’t use these as they are not ANSI approved. Not all of our janitor’s closets are near an eyewash station, and our chemicals used in these closets are not spillable, and they are located in a locked dispenser. Do I need an eyewash station in every janitor’s closet since the chemical would be diluted with water?

A: Well…Maybe yes and maybe no. It all depends on your organization conducting a risk assessment, which should determine if an eyewash station is necessary.

First, start with a review of the Safety Data Sheets (SDS) of the chemicals used in the work area (i.e. janitor’s closet). Does the SDS say to flush the eyes for 15 minutes? If so, then that is an indicator (but not necessarily a sure bet) that an eyewash station is needed. Next, evaluate the way that staff is using the chemical…. Is there a possibility that the chemical (even if it is diluted) can splash into the eyes of the individual? You make this determination assuming staff will NOT be wearing any PPE eye protection, because humans being the people that they are will eventually not wear their PPE.

If the risk assessment determines that there is a risk of splash into the eyes by chemicals that require 15 minutes of flush, then yes, you do need an eyewash station. The eyewash station needs to be ANSI Z358.1-2014 approved and while most of these are plumbed eyewash stations, there are a few that meet the ANSI standard and are self-contained and cost much less.

The portable squeeze bottles are not an acceptable substitute for an ANSI Z358.1-2014 approved eyewash station, but they are not illegal to have. They can be used as a first-aid device, but usually they are just a red-flag to surveyors that there is something going on here.

Feb 13 2017

Eyewash Station Locations

Category: Eyewash Stations,Questions and AnswersBKeyes @ 12:00 am

Q: Where are eyewash stations required in a hospital/ambulatory care facility?

A: They are required in areas where corrosive or caustic materials (i.e. chemicals) are used, stored or handled and could be splashed into the eye. A risk assessment must be made to determine where (if any) eyewash stations are necessary. The place to start is by looking at the Safety Data Sheet. If the SDS says rinse eyes for 15 minutes, then that is your first clue that an eyewash station may be required. The next step is to determine if the use, handling, or storage of the material could be splashed into the eyes. Note: When you evaluate this step you have to evaluate the process as if people are not wearing any PPE. If you conclude you need an eyewash station, then it has to meet the requirements of ANSI Z358.1-2014 which means it has to be plumbed and maintained, although there are some units that are self-contained that do qualify.

It is interesting to note that blood and body fluids are not considered corrosive or caustic.

Feb 05 2016

Non-ANSI Approved Eyewash Stations

Category: Eyewash Stations,Questions and AnswersBKeyes @ 12:00 am

Q: Is it better to have an eye wash station that doesn’t comply with ANSI standards or to remove eyewash stations from ambulatory clinics setting which may contradict Joint Commission standards on safety in the workplace?

A: To be sure, it is not a violation of a CMS, Joint Commission, or an OSHA standard to have an eye wash station that does not meet the requirements of ANSI Z358.1-2014 guidelines in areas where there are no caustic or hazardous chemicals. However, if there is a need for an eyewash station due to caustic or hazardous chemicals being used, then OSHA has issued interpretive letters that states their inspectors will use the ANSI Z358.1-2014 standard to determine compliance. [Joint Commission and most state agencies that survey on behalf of CMS will follow likewise.] This means an eyewash station that is non-compliant with ANSI Z358.1-2014 in an area where an eyewash station is required (such as a laboratory, or an Environmental Services work room) will likely be cited because the organization has not provided adequate emergency response equipment for the safety of their employees.

I have seen hospitals place eyewash stations that are non-compliant with ANSI Z358.1-2014 on faucets in every nurse station just because they thought it was a ‘good idea’; not because they were needed. Was that a violation? I don’t think so because there is usually not a chance of splashing caustic or hazardous chemicals in the eyes at the nurse stations. But, it is a red flag for surveyors and inspectors. If they observe an eyewash station that is non-compliant with ANSI Z358.1-2014 standard, they will start snooping around to see why it is there. If they find any caustic or hazardous chemicals used in the area that could be splashed into the eyes, then it is likely they will cite the organization for not having an ANSI Z358.1-2014 approved eyewash station.

I often see the hand-held squeeze bottles of sterile water mounted on the wall in certain area. I always ask the hospital why are they there. In some cases, caustic and hazardous chemicals were a splash concern and the hospital did not want to spend the $1,000 (or so) to install a ANSI Z358-1-2014 approved plumbed eyewash station, so they bought the cheaper bottles instead. That is a serious issue and likely would be cited by a surveyor. However, I have also seen the hand-held bottles placed in areas where there was no hazard, and the hospital just wanted them there for a ‘first-aid’ device. There is no standard or guideline that prevents that arrangement, but again, it is a red flag to a surveyor to start snooping around to see why the bottles are there in the first place. Also, the water in the bottles are typically only good for 2 years, and the hospital must be diligent in replacing the bottles before the water expires.

To directly answer your question: I think the hand-held bottles and the eyewash stations that are non-compliant with ANSI Z358.1-2014 in locations where there is no potential of caustic or hazardous chemicals to be splashed in the eyes is a potential source of problems during a survey, and I recommend to my clients to remove them, even though technically, they are permitted. It is a matter of opinion, and I always like to remove red-flags from the hospital before surveyors walk through. However, to not provide ANSI Z358.1-2014 approved eyewash stations where caustic or hazardous chemicals could be a potential splash problem, is definitely a safety hazard and would most likely be cited by a surveyor or an inspector. It is far better to spend the extra funds to either install the approved eyewash stations, or relocate the function and process to an area where there already is an approved eyewash station.

Jul 22 2015

Eyewash Stations in Labs

Category: Eyewash Stations,Questions and AnswersBKeyes @ 12:00 am

Q: Does an eye wash station need to be mounted over a designated “clean sink” or can it be in any sink? Some of our Labs only have one sink, so that sink is considered to be a dirty sink. Can we have a swing-out eye wash station located above that sink?

A: The OSHA and ANSI standards do not directly address this issue. But Joint Commission, CMS, CAP and the other accreditors will definitely perceive this as a risk to the health and safety of the staff that may use the eye wash station. The risk must be assessed by you, and the mitigation activities to lessen the risk are really what you will be judged on. I suggest you discuss this with the Lab safety officer and the organization’s Infection Control practitioner, and see what they think. If you wouldn’t want to put your face down into the dirty sink then I’m sure you would not expect your staff to do so as well. Do a risk assessment, run it past the Lab safety officer and the IC practitioner, then run it past the Safety Committee and see what they say. If everyone is okay with it (including your accreditation organization), then you should be able to use it for the eye wash station, as long as the eye wash station is maintained and kept clean.

Jun 01 2015

Eyewash Stations in Kitchens

Category: Eyewash Stations,Kitchens,Questions and AnswersBKeyes @ 1:00 am

Q: Are we required to have an eyewash station inside a kitchen?

A: Maybe yes and maybe no…. It all depends on whether or not there are caustic or corrosive materials that could be splashed into the eye. The organization needs to do a risk assessment of the hazardous materials in and around the kitchen to see if there are any chemicals/ materials that are considered caustic and/or corrosive, and whether or not they can be splashed into the eye when used according to the manufacturer’s recommendations. I’ll say from my experience, there probably are not many such materials in a kitchen, as that would seem to be a bit risky to have hazardous materials where food is being prepared. But you may very well find such materials in a janitor’s closet nearby, or in the dishroom. If you do have caustic or corrosive materials, the eyewash station must be located no more than 10 seconds of travel away from where the materials are used or stored. All of these requirements are found in the ANSI Z358.1 standard, available through an on-line search.