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.