MIOSHA revises their Eyewash/Shower Equipment requirements

As you know, I love using some of the State OSHA Plan standards as they can be more protective and offer some explanations as to their requirements.  The state of Michigan just renewed its 1910.151 standard as it relates to Eyewash/Shower Equipment and in doing so has offered some excellent insight into their revisions.  Whereas the federal OSHA standard offers little explanation…

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.

The new MIOSHA standard:

1. eliminates the use of pH as the primary measure of defining “injurious or corrosive”, and instead relies upon the chemical manufacturer’s or importer’s hazard classification (see Hazard Communication, Appendix A.2. and 3). Functionally, this means that industrial hygienist/safety officer (IH/SO’s) use the GHS hazard statement on the safety data sheet (SDS) or label “causes serious eye damage” (i.e. Category 1), or “causes serious eye irritation” (i.e. Category 2A) as the primary basis to define “injurious or corrosive”. A GHS classification of “causes eye irritation” (Category 2B) would not require an eyewash/shower. pH may be used to determine corrosivity of a diluted chemical if the SDS fails to provide an eye hazard classification (see Section XIII. A.)
2. eliminates the dual travel distance criteria (i.e., 25 feet for “highly corrosive” chemicals, 100 feet for “injurious or corrosive”). Makes the travel distance requirement consistent with the guidance given in ANSI Z358.1, which is a maximum of 10 seconds (approximately 55 feet).
3. clarifies that more than one motion to activate the eyewash is permitted as long as the activation occurs in one second or less (per ANSI guidance). The prohibition against a second/separate motion to remove nozzle covers remains.
4. previous instructions accepted a cold water pipe carrying potable water <25 psi, equipped with a quick opening valve if the hose was 4 feet long and ¾ inch thick. This instruction does NOT accept that alternative definition of suitable facility except for the DIPPING AND COATING INDUSTRY as specified in the vertical standard OH Part 526, Dipping and Coating Operations [i.e., 1910.124(g)(2)].
5. Previous instructions required either:
   1. an emergency eyewash/shower facility every 25 feet for retail transport of lead-acid batteries, or
   2. personal wash bottles for immediate flushing until an acceptable eyewash/shower facility can be reached. This instruction eliminates that broad guidance. The SO/IH shall be responsible to determine if such transport of batteries in retail establishments poses an exposure hazard.
6. This instruction changes the PPE use policy for the traveling portion of housekeeping/custodial duties that involve injurious or corrosive chemicals. PPE is required for the traveling portion of such housekeeping/custodial duties. There will be continued need for professional judgement regarding the appropriate type of PPE. Typical use of a few ounces of an injurious chemical used at arm’s length may require protective gloves and safety glasses with sideshields. Safety goggles may be necessary if the amount of injurious chemical splash can cause injury by entering around standard safety glasses with sideshields.

Note that there may be certain MIOSHA standards that contain eye flushing requirements different than OH Part 472 Medical Services and First Aid. For example, GI Part 63 Pulp, Paper, and Paperboard Mills, contains a requirement that a deluge shower and eye fountain shall be provided within 25 feet of an area where caustics or acids are used or mixed at a strength that could cause injury to an exposed employee. This is more strict than the distance requirement contained in OH Part 472 (10 seconds or 55 feet). When inspecting or consulting in industries (or on processes) affected by both vertical and horizontal standards refer to the Agency Instruction MIOSHA-COM-15-2, Horizontal or Vertical Standards – Determining Application. The standards listed below contain references to emergency eyewash and/or showers.

A. General Industry Safety Standard Part 21. /R408.12101 et seq., Powered Industrial Trucks.
B. General Industry Safety Standard Part 63. /R408.16301 et seq., Pulp, Paper, and Paperboard Mills.
C. General Industry Safety Standard Part 72. /R408.17201 et seq., Automotive Service Operations.
D. General Industry Safety Standard Part 78. /R408.17801 et seq., Storage and Handling of Anhydrous Ammonia (1910.111).
E. Occupational Health Standard Part 306. /R325.51451 et seq., Formaldehyde.
F. Occupational Health Standard Part 313. /R325.51651 et seq., Methylene Chloride.
G. Occupational Health Standard Part 472. /R325.47201 et seq., Medical Services and First Aid.
H. Occupational Health Standard Part 526. /Rule R325.52601 et seq., Dipping and Coating Operations.
I. Occupational Health Standard Part 554. /R325.70001 et seq., Bloodborne Infectious Diseases (BID).

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