The "ADA argument" against floor drains for emergency showers and eyewash stations is a new one for me. I agree, Nonsense. Thanks for sharing that.

The other persistent one that comes up fairly often is the "hazardous waste down the drain argument". This particular con-game goes something like this: If you get a chemical on you, then the rinsate from the emergency eyewash or shower going down the drain will result in a Clean Water Act violation. Again, Nonsense. =A7 261.3 (a) (2) (iv) (D) specifically exempts this material as hazardous waste, i.e. "discharges from safety showers and rinsing and cleaning of personal safety equipment."

Eric Clark, MS, CCHO, CHMM

Los Angeles Trade Technical College

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Hadden, Susan [JRDUS]
Sent: Thursday, February 01, 2018 8:51 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Safety Showers, Drains and ADA Compliance

IMO, if you want to play in the lab sandbox, you have to provide the lab tools.

If you don't put in drains, not only will you have the damage issues others have pointed out, you will constantly fight the battle of having people test them because it makes a mess. So ongoing compliance issues.

As to marking them out, I suggest that you put different textured tiles under the safety eyewash/shower. That way, even if you can't see when you are in the right place, you can feel that you are.

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of ILPI Support
Sent: Thursday, February 1, 2018 10:56 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [EXTERNAL] Re: [DCHAS-L] Safety Showers, Drains and ADA Compliance

Nonsense. The architects must be trying to add in berms to contain the water when all they really need is some very mild pitch in the floor in that area. Even if that's not sufficient to contain all the water it will get a large percentage of it.

ADA-compliant units themselves don't take up much more space, if any, than regular units, however, the space that has to be kept clear is presumably larger. But that has nothing whatsoever to do with drains. BTW, I recommend using floor tape and floor signs to demarcate the area that must be left clear. I hear there are some companies that sell that sort of stuff. :-)

Rob Toreki

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On Feb 1, 2018, at 10:21 AM, Melissa Anderson <mwanderson08**At_Symbol_Here**GMAIL.COM> wrote:

Greetings Everyone,

We're working with architects right now to plan out chem labs for a new science building. We've asked for drains under the safety showers and were told that wouldn't be possible because in order to be ADA compliant and have drains, the safety showers would take up too much space- has anyone encountered such an argument?

(Note, we're extremely constrained on space due to some very complicated politics I won't go into here, so making the labs bigger is not an option.)

Thanks,

Melissa Anderson

Instructor

Pasadena City College

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