Nevada OSHA adopted regulation R069-20, which includes the adoption by reference of ANSI Z358.1-2014 for Emergency Eyewash and Shower Equipment. By adopting ANSI Z358.1-2014, Nevada OSHA has identified the minimum design and installation criteria necessary to meet the definition of suitable facilities, which is otherwise undefined in federal statute. Additionally, training requirements have been introduced as part of this adoption.
Enforcement Guidance
- Nevada OSHA will cite R069-20 for all violations related to installing emergency eyewash stations and equipment that are not deemed suitable facilities pursuant to ANSI Z358.1-2014. Citations may be issued as Other-than-Serious or Serious depending on the likely outcome from exposure.
- Nevada OSHA will cite 29 CFR 1910.1200(h)(1) if no hazard communication training is provided to employees exposed to corrosive chemicals in their work area. Citations will be generally issued as Serious.
- If an employer does provide hazard communication training, but the training does not include information pertaining to the location and use of emergency eyewash and shower equipment, Nevada OSHA will cite for a violation of R069-20.
- Nevada OSHA will citeR069-20 for all violations related to the installation location of emergency eyewash and shower equipment. Employers have installation obligations covered under ANSI Z358.1-2014. Refer to FAQ Question 5 for guidance. Citations may be issued as Other-than-Serious or Serious depending on the likely outcome from exposure.
- Nevada OSHA will continue to cite 29 CFR 1910.151(c) for the failure to install emergency eyewash and shower equipment where a determination is made that such equipment is necessary. Determination will be made by reviewing the chemical’s safety data sheet (SDS) and labeling. Citations will generally be issued as Serious.
Employer Guidance
Employers are required to review all safety data sheets and chemical labeling prior to introducing the chemical into the workplace. This includes reviewing the Hazard Communication Standard (HCS) alignment with the Global Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS alignment with the HCS requires that all chemicals used in the United States possess standardized labeling and safety data sheet documentation. The information below will be included on any and all applicable chemicals used by employers in the United States.
Safety Data Sheets
The following are criteria found within a chemical manufacturer’s safety data sheet that would require the installation of an emergency eyewash station or shower:
- SDS Hazard Category for Skin Corrosion and Irritation – Category 1
- Human experience showing irreversible damage to the skin
Structure/activity or structure property relationship to a substance or mixture already classified as corrosive - pH of 2 or less
- pH of 11.5 or greater
- Human experience showing irreversible damage to the skin
- SDS Signal Word – DANGER
- Highly corrosive substances
- Highly corrosive substances
Chemical Labeling
The following are examples of criteria found on a chemical label that would require the installation of an emergency eyewash station or shower:
- Labels Related to Skin Burns and Eye Damage
Suitable Facilities
Nevada OSHA will determine compliance with R069-20 by evaluating emergency eyewash and shower station installations for compliance with ANSI Z358.1-2014. Employers that comply with the sections below will meet the definition of Suitable Facilities under ANSI Z358.1-2014 as it relates to 29 CFR 1910.151(c).
- Section 4. Emergency Showers
- Section 5. Eyewash Equipment
- Section 6. Eyewash/Face Wash Equipment
- Section 7. Combination Units
- Section 8. Supplemental Equipment
References:
- R069-20AP Penalty Updates and Clean-Up Regulation
- 29 CFR 1910.151 – Medical Services and First Aid
- 29 CFR 1910.1200 – The Hazard Communication Standard
- OSHA – Hazard Communication (HazCom)
- OSHA – Globally Harmonized System (GHS)
Frequently Asked Questions
1. Are employers required to inspect emergency eyewash and shower stations?
Employers are required to activate plumbed emergency eyewash and shower stations at least weekly to verify operation and ensure that flushing fluid is available. Self-contained emergency eyewash and shower stations are required to be inspected weekly to determine if flushing fluid needs to be changed or supplemented. Employers must strictly adhere to manufacturer’s instructions on flushing fluid service. Additionally, all emergency eyewash and shower station equipment shall be inspected annually to ensure compliance with the installation provisions of ANSI Z358.1-2014. It is highly recommended that employers document all inspection efforts with at least a checklist, employee name, and date of inspection. Stations that are not inspected weekly and annually shall be deemed unsuitable facilities.
2. Do emergency eyewash and shower stations require a specific temperature flushing fluid?
Emergency eyewash and shower flushing fluid must be a tepid temperature (60 to 100 degrees Fahrenheit) to promote at least 15 minutes of continuous irrigation. Stations not meeting this criterion shall be deemed unsuitable facilities. For compliance purposes, it is recommended to document verification as part of inspection efforts identified in response to Question 1.
3. Does this new regulation incorporate new training requirements?
The adopted ANSI introduces a new requirement for employers to train employees on knowing where to locate the nearest emergency eyewash and shower station in their work area and understand how to use the station.
4. Are faucet-mounted eyewash stations that require two motions to operate compliant with ANSI Z358.1-2014?
ANSI Z358.1-2014 requires that emergency eyewash and shower stations be equipped with a control valve that can be operated from “off” to “on” in 1 second or less. Faucet-mounted eyewash stations that use a two-step process to discharge flushing fluid may not be compliant with ANSI Z358.1-2014. This is recognized by many common manufacturers of faucet-mounted eyewash stations. Nevada OSHA will consider the pre- existing installation and use of such eyewash stations as a de minimis violation if the employer has taken the necessary steps to train employees on the proper use of such equipment and continues to train employees on an ongoing basis. Nevada OSHA strongly encourages employers to progressively replace such stations to the extent feasible. New installations of faucet-mounted eyewash stations that require a two-step process will be considered non-compliant and citations may be issued.
5. What location considerations must an employer make when installing emergency eyewash and shower equipment?
Distance – Emergency eyewash and shower equipment should be available for immediate use, but in no instance should it take an individual longer than 10 seconds to reach the equipment and utilize the flushing fluid. ANSI Z358.1-2014 recognizes that a distance no greater than 55 feet meets the 10-second requirement.
Obstructions – For highly corrosive chemicals, the employer must ensure that no obstructions exist between the hazard and the emergency eyewash and shower equipment.
Examples of obstructions include:
- Doorways
- Storage racks
- Boxes and other loose work materials
- Railings and other barriers
Other Considerations
Employers must consider exposure to other hazards when emergency eyewash and shower equipment is operated to include:
- Flushing fluid interaction with close-proximity electrical equipment.
- A location that allows the employee to achieve a safe distance from the potentially ongoing chemical hazard.
Source: https://dir.nv.gov/uploadedFiles/dirnvgov/content/Governance/Eyewash%20Regulation%20Guidance%20(10-5-2022).pdf