Eyewash and Shower Station Locations

When visiting ammonia refrigeration facilities, I am often asked the question “where and how many eyewash and shower stations do I need to install at my facility?”  This is a good question and it should receive some serious consideration.

To start, this is not the first time we have addressed this topic on our blog. In January 2015 we published a blog titled Q&A | Emergency Eyewash and Shower Equipment.  In this blog, I would like to focus on the response by OSHA to the IIAR Request for Interpretation on Hazards and Eyewash Safety Shower Situations which was written on December 17, 2014.

In the letter to OSHA, IIAR was seeking guidance on two issues related to the following eyewash and shower station requirement: 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.”

Below are the questions asked by IIAR and the responses given by OSHA:

1. Would OSHA accept the use of personal protective equipment in lieu of permanent or portable eyewash/safety showers in cold environments?

No. OSHA would not accept the use of personal protective equipment in lieu of eyewash/safety showers regardless of the environment.  Further, there are emergency eye wash and safety shower products that have built-in heating elements for maintenance operations in cold environments.

2. If the ammonia refrigeration is in a sealed container (sic) where there is no intention of opening or repairing the pressure-containing envelope of the piping system, does 29 CFR 1910.151 (c) require an eyewash or emergency shower?

No. However, as you recognized in your letter, for some maintenance operations, such as oil draining, equipment replacement, and valve and piping maintenance or repair, there is potential for exposure to ammonia. In those circumstances, the standard requires the employer to provide facilities for quick drenching or flushing of the eyes or body.

We would encourage you to click here to view the complete letter from IIAR with OSHA’s responses.