Apr 21 2017

Eyewash Stations

Category: BlogBKeyes @ 12:00 am
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When and where are eyewash stations required in a healthcare facility? That is one of the more frequent issues that healthcare professionals struggle with. There is a tendency to place them nearly everywhere, but in reality there aren’t as many locations that require eyewash stations than one may think.

Eyewash stations are required wherever there is a possibility that caustic or corrosive chemicals could splash into the eye of an individual. It is important to note that blood and body fluids are not considered to be caustic or corrosive. It is also important to note that the use of Personal Protective Equipment (face shields, glasses, goggles) does not exempt the need for an eyewash station.

Most accreditation organization’s position on whether or not an eyewash station (or an emergency shower) is required is based on the healthcare organization conducting a risk assessment of the situation. Working with corrosive and caustic chemicals does not necessarily require an eyewash station (or emergency shower) unless the possibility is present that the chemicals could be splashed into the eyes (or onto the skin).

For example: If an environmental services worker opens a 1 gallon container of a liquid cleaner that is considered caustic or corrosive, and inserts a suction tube for a mixer, that doesn’t really present much of a splash hazard and a risk assessment could state an eyewash station is not warranted. However, if the employee pours the same chemical from its original container to another container, now the risk of splash is much greater and a risk assessment would likely require an eyewash station. All risk assessments are conducted with the presumption that staff will not be wearing any personal protective equipment.

If there are no corrosive or caustic chemicals present, then there is no need to conduct a risk assessment and there is no need for an eyewash station. Whether the term “corrosive” or the term “injurious corrosive” is used to describe a chemical, it’s all the same. Both would cause an injury.

A portable squeeze bottle is not prohibited, but it is not a substitute for a plumbed ANSI Z358.1-2014 approved eyewash station. Portable squeeze bottles are a potential problem for healthcare organizations, since they are usually placed around an area where a potential hazard can or may occur. In other words, somebody decided there is some sort of risk of splash present, that a portable bottle would be of some use.

That can lead to an incorrect assumption that the portable bottles are an approved eyewash station. Also, they need to have their water changed every two years (or so) and that can also be overlooked at times which can lead to a citation. Also, be aware that they are a huge flag to a surveyor who would likely conduct a tracer once he/she sees the portable bottle.

If the possibility of a corrosive or caustic material can be splashed onto the skin then an emergency shower would be required. But if a risk assessment determines there is no possibility of the chemicals splashing onto the skin through normal use, then there would not be a requirement for an emergency shower. The risk assessment should also consider emergency spills as well.

In regards to the ANSI Z358.1-2014 standard for eyewash stations, this standard is based on recommendations from OSHA letters of interpretation. OSHA requires the employer to provide suitable facilities for quick drenching or flushing of the eyes and body when employees may be exposed to injurious corrosive materials. ANSI standards become mandatory OSHA standards only when, and if, they are adopted by OSHA. ANSI Z358.1 has not been adopted by OSHA; however, ANSI Z358.1 provides detailed information regarding the installation and operation of emergency eyewash and shower equipment. OSHA, therefore, has often referred employers to ANSI Z358.1 as a source of guidance for protecting employees who may be exposed to injurious corrosive materials. Accreditation organizations seem to have latched onto the ANSI Z358.1 standard as the standard to comply with.

The organization is expected to conduct a risk assessment (or survey) of their facility’s operation and process areas to determine if and where eye wash stations are needed. If the facility has determined that an eye wash station is needed, then it needs to conform to the ANSI standard Z358.1-2014, which has the following specifications:

  • Only eye wash stations that are capable of providing a flow of clean potable water at a rate of 0.4 gallons per minute at 30 psi for 15 minutes are permitted. It is possible that some self-contained eye was stations may provide this flow requirement, but normally only plumbed eye wash stations do.
  • The flow nozzles of the eye wash station must be mounted a minimum of 33 inches and a maximum of 45 inches above the floor, and a minimum of 6 inches from any wall, post or other barrier.
  • Activation of the eye wash station must occur in one (1) second or less of operating the control valve, so this typically eliminates the faucet mounted eye wash stations that require the operation of three (3) levers to obtain a balanced flow of water. The control valve must remain open on its own until it is intentionally turned off.
  • Approved eye wash stations are required to be located within 10 seconds travel time (or 55 feet) of the hazard and the path to get to an eye wash station must not be hindered or obstructed. The ANSI Z358.1-2014 standard has changed to allow one (1) door in the path to get to an eye wash station, provided the door cannot be locked and the door swings in the direction to the eye wash station.
  • While there is no standard that prohibits the small supplemental personal squeeze bottles, they cannot meet the flow rate requirements for a 15-minute flush, and therefore are not a substitute for a plumbed eye wash station. They can serve as a supplemental aid but the plumbed eye wash station needs to be located within 10 seconds travel time (or 55 feet) of the hazard. The presence of the small supplemental personal wash bottles may indicate a need for a plumbed eye wash station.
  • The temperature of the water is required to be tepid. The ANSI standard defines tepid water as being between 60°F and 100°F. In order to achieve this temperature range, the organization may have to install mixing valves. Water temperatures outside of the 60°F and 100°F range may be permitted provide a risk assessment is conducted by qualified individuals which analyzes the hazard and the temperature of the water to flush the hazard. Qualifying individuals must include an individual with clinical or medical training.
  • Weekly activation of the eye wash stations is required to clear any sediment or bacteria. There is no specified time that the water must flow. An annual inspection of the eye wash station is required to determine conformances with the installation requirements are maintained.

Here are some recommendations on evaluating your existing eyewash stations for compliance:

  1. In a healthcare setting, eye wash stations are typically found where cleaning chemicals are mixed (such as housekeeping areas), plant operations, kitchens, generator rooms, environmental services storage room for battery powered floor scrubbers, in-house laundries, dialysis mixing rooms and laboratories. Determine if a risk assessment has been conducted to conclude the need for eye wash stations.
  2. All required eye wash stations must be the plumbed type, which can operate in one (1) second or less. This means the faucet mounted type that requires turning the hot water lever and the cold water lever and then pulling a center lever is not permitted.
  3. Access to the eye wash station must be within 10 seconds (or 55 feet) of the hazard. The individual seeking an eye wash station may travel through one (1) door to get to an eye wash station, provided the door does not have a lock on it, and swings in the direction to the eye wash station.
  4. If an eye wash station is observed outside of an area where they are typically needed, ask the staff who works in the area why it is there. See if they have a risk assessment that requires it to be there. Advise them if there is no valid reason for the eye wash station to be there, it can be removed and may save them time and resources in maintaining it.
  5. Eye wash stations may need to have a mixing valve to maintain a flow of water in the 60°F and 100°F range. Ask to see the risk assessment to determine if a mixing valve is required.
  6. Every eye wash station needs to be tested weekly by flowing water to clear any sediment and bacteria. There is no requirement how long the water must flow. Every eye wash station must be inspected annually to determine the eye wash station still conforms to the installation parameters. The weekly test and annual inspections must be documented.
  7. The presence of eye wash bottles indicates someone in the organization decided it was needed. Investigate and ask why the bottles are located there. Determine if they need a plumbed eye wash station within 10 seconds travel time (or 55 feet) of the perceived hazard. Check the expiration date on the bottles.

Always check with your state and local authorities to determine if they have any additional requirements.

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Jun 26 2014

Emergency Showers

Category: BlogBKeyes @ 5:00 am
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imagesRFIMRIFGEmergency showers are often found in hospital laboratories and at times, in plant operation areas. There seems to be some confusion about emergency showers and eyewash stations, and what is acceptable to the accreditation organizations. To be sure, there are no standards that are being enforced by a national authority over hospitals that are specific to emergency showers and eyewash stations. Even OSHA does not rigidly enforce a specific set of rules concerning these emergency first-aid devices, although they do refer to ANSI Z358.1-2009 as a guide.

George Mills, director of engineering for The Joint Commission recently commented during a meeting of hospital engineers that they (Joint Commission) do not rigidly enforce the guidelines in ANSI Z358.1-2009. Joint Commission only requires a monthly water-flow test for an unspecified amount of time, and then it appeared to only apply to eyewash stations.

A lot has been written about eyewash stations (search: eyewash), but not so much for emergency showers. What should a hospital do in regards to testing and inspecting an emergency shower? In order to be prepared for any inspection by an authority who may enforce the full requirements of ANSI Z358.1-2009, here are the basics concerning emergency showers:

There are two types of Emergency Showers:

  • Plumbed Shower:      An emergency shower permanently connected to a source of potable water
  • Self-Contained Shower:      A shower that contains its own flushing fluid, and must be refilled or      replaced after use

 The specifications below are for plumbed showers only.

  • Heads
    • Positioned 82″-96″ from floor
    • Spray pattern will have a minimum diameter of 20″ at 60″ above the floor
    • Flow Rate equals 20 gallons per minute (GPM) at 30 pounds per square inch (PSI)
    • The center of the spray pattern shall be located at least 16 inches from any obstruction
  • Valves
    • Activate in one second or less
    • Stay-open valve (no use of hands)
    • Valve remains on until the user shuts it off
  • Installation
    • Emergency Shower shall be located in an area that requires no more than ten seconds to reach.
    • Shower location shall be in a well-lit area and identified with a sign
    • Shower shall be located on the same level as the hazard
  • Maintenance and Training
    • Plumbed emergency showers will be activated weekly to verify correct operation
    • All employees who might be exposed to a chemical splash shall be trained in the use of the equipment
    • All showers shall be inspected annually to make sure they meet with ANSI Z358.1 requirements

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May 09 2013

More on Eye Wash Stations

Category: BlogBKeyes @ 6:00 am
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imagesCASBGE8PEye wash stations are required wherever there is a possibility that caustic or corrosive chemicals could splash into the eye of an individual. It is important to note that blood and body fluids are not considered to be caustic or corrosive. It is also important to note that the use of Personal Protective Equipment (face shields, glasses, goggles) does not exempt the need for an eye wash station.  Material Safety Data Sheets will specify whether or not an eye wash station is required, by the listed emergency treatment of flushing the eyes with water for 15 minutes.

Accreditation organizations (Joint Commission, HFAP and DNV) as well as CMS does not specify the location for eye wash stations. The organization is expected to conduct a risk assessment (or survey) of their facility’s operation and process areas to determine if and where eye wash station are needed. If the facility has determined that an eye wash station is needed, then it needs to conform with the ANSI standard Z358.1-2009, which has the following specifications:

  • Only eye wash stations that are capable of providing a flow of clean potable water at a rate of 0.4 gallons per minute at 30 psi for 15 minutes are permitted. It is possible that some self-contained eye was stations may provide this flow requirement, but normally only plumbed eye wash stations do.
  • The flow nozzles of the eye wash station must be mounted a minimum of 33 inches and a maximum of 45 inches above the floor, and a minimum of 6 inches from any wall, post or other barrier.
  • Activation of the eye wash station must occur in one (1) second or less of operating the control valve, so this typically eliminates the faucet mounted eye wash stations that requires the operation of three (3) levers to obtain a balanced flow of water. The control valve must remain open on its own until it is intentionally turned off.
  • Approved eye wash stations are required to be located within 10 seconds travel time (or 55 feet) of the hazard and the path to get to an eye wash station must not be hindered or obstructed. The ANSI Z358.1-2009 standard has changed to allow one (1) door in the path to get to an eye wash station, provided the door cannot be locked and the door swings in the direction to the eye wash station.
  • While there is no standard that prohibits the small supplemental personal wash bottles, they cannot meet the flow rate requirements for a 15 minute flush, and therefore are not a substitute for a plumbed eye wash station. They can serve as a supplemental aid but the plumbed eye wash station needs to be located within 10 seconds travel time (or 55 feet) of the hazard. The presence of the small supplemental personal wash bottles indicates a need for a plumbed eye wash station. Check the expiration date on the small bottles.
  • The temperature of the water is required to be tepid. The ANSI standard defines tepid water as being between 60°F and 100°F. In order to achieve this temperature range, the organization may have to install mixing valves. Water temperatures outside of the 60°F and 100°F range may be permitted provide a risk assessment is conducted by qualified individuals which analyzes the hazard and the temperature of the water to flush the hazard. Qualifying individuals must include an individual with clinical or medical training.
  • Weekly activation of the eye wash stations is required to clear any sediment or bacteria. There is no specified time that the water must flow. An annual inspection of the eye wash station is required to determine conformance to installation requirements are maintained.

In response to the question: “How do Accreditation Organizations survey a hospital (or nursing home) in regards to eye wash stations?” Here are my tips and recommendations:

  1. In a healthcare setting, eye wash stations are typically found where cleaning chemicals are mixed (such as housekeeping areas), plant operations, dialysis mixing rooms and laboratories. The surveyor will determine if the organization has conducted a risk assessment to determine the need for eye wash stations.
  2. All required eye wash stations must be the plumbed type, that can operate in one (1) second or less. This means the faucet mounted type that requires turning the hot water lever and the cold water lever and then pulling a center lever is not permitted.
  3. Access to the eye wash station must be within 10 seconds (or 55 feet) of the hazard. The individual seeking an eye wash station may travel through one (1) door to get to an eye wash station, provided the door does not have a lock on it, and swings in the direction to the eye wash station.
  4. If an eye wash station is observed outside of an area where they are typically needed, the surveyor may ask the organization why it is there. They will want to determine if you have a risk assessment that requires it to be there. If there is no valid reason for the eye wash station to be there, it can be removed and may save you time and resources in maintaining it.
  5. Eye wash stations may need to have a mixing valve to maintain a flow of water in the 60°F and 100°F range. The surveyor may ask to see the risk assessment to determine if a mixing valve is required.
  6. Every eye wash station needs to be tested weekly by flowing water to clear any sediment and bacteria. There is no requirement how long the water must flow. Every eye wash station must be inspected annually to determine the eye wash station still conforms to the installation parameters. The surveyor will likely ask to see the weekly and annual inspection reports.
  7. The presence of eye wash bottles indicates someone in the organization decided it was needed. The surveyor will likely investigate and ask why the bottles are located there. If the surveyor determines a need for a plumbed eye wash station within 10 seconds travel time (or 55 feet) of the perceived hazard, then you are ripe for a finding. Conduct a risk assessment to determine if a plumbed eye wash station is required. If so, have one installed or relocate the hazard. If not, then remove the portable eye wash bottles.  Also, if you retain the bottles, check the expiration date to ensure it has not expired.

While there may not be a direct standard in the Accreditation Organization’s manual that addresses eye wash station, any deficiency that a surveyor finds will likely be entered under a standard that addresses general safety in the physical environment, such as EC.02.01.01, EP 1 for Joint commission; 11.02.02 for HFAP; and PE.1, SR.1 for DNV.

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Nov 15 2012

Portable Eye Wash Stations

Category: BlogBKeyes @ 5:00 am
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I was out all last week and when I returned to my office I was inundated with comments (complaints, really) as to why the portable squeeze bottles are not a good idea for a first-aid eye care for staff to use as they walk to the ANSI approved Z358.1 eye wash stations which are plumbed. Forgive me if this is not a Life Safety Code issue, but it certainly is an issue that facility managers in healthcare organizations must deal with.

The placement and eventual use of the portable hand-held squeeze bottles for first-aid eye care are certainly not a violation of any Life Safety Code, Joint Commission, or OSHA compliance standard. However, they present a serious problem for various reasons.

They are a ‘red flag’ for any surveyor or inspector as 90% of these portable first-aid eye care squeeze bottles are placed in locations (and in lieu of) where an ANSI approved Z358.1 eye wash plumbed station would be required. Therefore, a surveyor is used to writing findings for non-compliant eye wash stations when they see the squeeze bottles. What often happens, the organization wants to provide as much emergency care equipment as they can in the event a staff member splashes something caustic or corrosive into their eye, but they don’t want to spend the $500 – $1,000 required to installed the proper ANSI Z358.1 approved station. If the organization decides that a squeeze bottle should be mounted at any specific location, then that is a pretty sure bet that an ANSI Z358.1 approved eye wash station (plumbed) should be installed in the first place. It usually is a decision made from ignorance, where a manager or supervisor wants the best for their employee, but may not have the authority or wherewithal to have a $1,000 eye was station installed.

When the portable squeeze bottles are installed, they often times are ‘out-of-sight, out-of-mind’. Even though they are mounted on the wall, in plain view, staff eventually loses track of them and forgets they are there. The expiration date of the water solution in the bottles are about 2-years, if memory serves me correctly. When staff forgets those bottles are there, then they don’t replace the bottles when they expire. A surveyor will see them very easily as they are mounted out in the open and in plain view, and an expired bottle of water solution will create another round of findings. Also, the worst case scenario is a staff member grabbing an expired eye wash bottle and causing more damage to their eyes with water that may have bacteria growing in it.

Can an organization overcome these scenarios that I have stated? Sure, but it is not likely, and my recommendation is to not start down this slippery slope and do not install portable eye was squeeze bottles. The organization should bite the bullet and pay the $500 – $1,000 each to have an approved eye wash station installed where they are required.

Take a look at the ANSI approved Z358.1 eye wash station to the left. It does not have to be plumbed to a sink or drain. It can be mounted by itself, and an alternate plan to catch the water when it washes onto the floor can be used, such as sand-bags and a mop and bucket.  These types of eye was stations are not that expensive to purchase. Take a look at the Lab Safety or Grainger catalogues to find them.

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